SEBI’s Enforcement Surge, SAT’s Procedural Guardrails

SEBI’s Enforcement Surge, SAT’s Procedural Guardrails


SEBI’s enforcement strategy now prioritises early detection and deterrence. Administrative warning letters are increasingly used to flag suspected insider trading, allowing entities to self-correct the non-compliance issues. The Integrated Market Surveillance System has enabled the regulator to detect proxy trading, coordinated patterns, and violations during blackout periods, often routed through third parties or connected entities.

This tech-enabled vigilance has enhanced market transparency. However, it has also caused procedural compression. Interim orders are sometimes issued without fully disclosing the relied-upon documents. Searches and seizures are being done by SEBI with approval of the magistrate, designated court, and confidential reports are cited without redaction. Response timelines are shortened, and urgency is emphasised even in cases without imminent market risk.



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