Axar Digital Services Pvt Ltd


InsiderLens IFCo

Insider trading compliance solution for
Fiduciaries & SEBI regulated Intermediaries


Be risk-free – comply fully with SDD requirements of SEBI’s PIT regulations!

InsiderLens IFCo helps Intermediaries and Fiduciaries meet these compliance requirements, and is up-to-date with all regulatory changes!**
From July 17, 2020, SEBI made the Structured Digital Database (SDD) requirement, under the Prohibition of Insider Trading (PIT) regulations, 2015, mandatorily applicable to Intermediaries (regulated by SEBI, including Banks, Insurance Cos, Brokers, etc) and Fiduciaries (such as Statutory and Secretarial Auditors, Solicitors or Legal advisors, Management Consultants, etc).
If recent announcements by SEBI regarding the need for better PIT Compliance by listed entities are any indication, SEBI will also enquire about SDD compliance by Fiduciaries and Intermediaries, with greater rigour and frequency.
InsiderLens IFCo is the solution for this purpose. It is certified to be compliant and up-to-date with the regulations, by a large PCS firm, which has also implemented the solution – for payment – to ensure they are compliant. The SDD is to be maintained internally, not outsourced, and must be preserved for at least eight years. The database architecture fulfils mandated internal controls, time checks, and audit trails, maintenance of a “Restricted” or “Grey” List of clients, maintaining details and all other related requirements of this regulation.

How InsiderLens IFCo helps Intermediaries and Fiduciaries?

InsiderLens IFCo helps Intermediaries and Fiduciaries to maintain their own SDD and track the Un-published Price Sensitive Information (UPSI) of their listed clients. The software assists in creating Restricted or Grey list of clients. The Compliance Officer (CO) owns this list and maintains its confidentiality. Only Relevant Designated Persons (DPs) are only notified about the names of Grey list entities when they are exposed to Unpublished Price Sensitive Information (UPSI) of those members of the Restricted List.
InsiderLens IFCo helps organisations prevent inappropriate trading activity of their DPs, and the DPs’ Connected Persons (their Immediate Relatives, Material Financial Relationships and Other connected Entities). Further, the platform notifies the CO to issue Tradinge Window Closure (TWC) notices to the DPs, as in InsiderLens LCo.
InsiderLens IFCo maintains the confidentiality of the UPSI from its entry into the system to its cessation as a UPSI or disclosure to the Stock Exchange.
InsiderLens IFCo is a robust, web-based framework that aligns with the SEBI guidelines and facilitates the tracking of UPSI received from (external entities that are part of the Grey Listor internal). Where necessary, InsiderLens facilitates Compliance Officers in maintaining and managinge multiple SDDs.

What if you don’t maintain SEBI-compliant SDD?

SEBI’s objective in creating an SDD is to strengthen the legal framework of the companies, adapt to the changing market dynamics and prohibit insider trading. Failure to maintain an SDD implies the sharing or publishing of the UPSI, consequently influencing the securities and monetary value of the company. Any misuse of UPSI triggers an indicator of non-compliance and provokes undesired actions by the SEBI.

Axar -Your Guide to Create and Manage SDD!

** As certified by an independent PCS firm, which has itself also implemented IFCo for their compliance needs. Certificate available to clients.


Understanding Regulatory Terminologies

** Source: SEBI (Prohibition of Insider Trading) Regulations, 2015.

Insider: A “designated person”, “connected person” or a person possessing or
having access to Unpublished Price Sensitive Information (UPSI)

Designated Person: One who has been associated with the company in any
capacity such as a director, promoter, officer, or employee or in a contractual or
fiduciary relationship with the company; and includes a list of “deemed designated

Connected Person: Any person who is or has been associated with the Company
for six months prior, in any capacity and has direct or indirect access to Unpublished
Price Sensitive Information (UPSI)

Unpublished Price Sensitive Information (UPSI): Any information relating to
securities of a company that is not generally available and, upon being available, is
likely to materially affect the price of the company’s securities. It includes matters
such as financial results, dividends, changes in capital structure, significant
corporate transactions, and changes in key managerial personnel.