Authority: Amarjeet Singh, Whole Time Member, Securities and Exchange Board of India

Order Date: August 18, 2026

Case Overview

SEBI conducted an inspection of Alliance Research (proprietor Mr. Mudassir Hasan), a SEBI-registered Investment Adviser (INA000002934), during February 11-15, 2020, covering the period from April 1, 2018 to February 15, 2020. The inspection revealed multiple violations of SEBI Act, SEBI (Investment Advisers) Regulations, 2013 (IA Regulations), and SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 (PFUTP Regulations). An interim order was passed on January 6, 2021, directing Mr. Hasan to cease investment advisory activities and not access the securities market, which was confirmed on July 29, 2022. Separate enquiry and adjudication proceedings resulted in a two-month suspension of registration and a ₹6,00,000 penalty in October 2025. Summary proceedings for non-payment of renewal fees led to cancellation of registration on July 21, 2026. The present order deals with violations not covered in the adjudication proceedings.

Key established violations include:

  • Carrying unregistered investment advisory activities prior to obtaining registration on April 16, 2015, with evidence of fee receipts (₹6,71,650) and operational expenditures between January-April 2015
  • Failure to conduct KYC, risk profiling, and suitability assessment for 14 out of 46 sample clients
  • Selling high-risk products to 21 clients categorized as having low/medium risk appetites
  • Not communicating risk profiles to clients and collecting fees before risk profiling for 31 clients
  • Charging unfair fees where amounts exceeded clients' annual income (19 clients) and proposed investments (17 clients)
  • Not disclosing material change of office address to SEBI
  • Not conducting mandatory annual compliance audit
  • Employing Mr. Ravi Chouksey as CEO while he was prohibited by SEBI order until June 3, 2019
  • Displaying expired Brickwork rating (SME-4) on website beyond January 18, 2019 expiry date
  • Violating PFUTP Regulations through fraudulent conduct and deceit of clients

The Noticee's defenses including misconception of law, coercion during inspection, and client consent for fees were rejected by SEBI.

Final Outcome

SEBI imposed a total penalty of ₹6,00,000 under Sections 15EB (₹1,00,000) and 15HA (₹5,00,000) of SEBI Act, 1992. The penalty must be paid within 45 days of order receipt through SEBI's online portal. The interim order restrictions are vacated, though directions from other proceedings (suspension, cancellation, previous penalty) remain in effect.

Topics: Investment Advisory Compliance, SEBI Enforcement, Investor Protection