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Examining The Legality: Are Transactions To Mule Accounts A Case Of Unfair Trade Practices

The Securities and Exchange Board of India (SEBI) has taken a decisive regulatory step by prohibiting transactions through 'mule accounts' as part of its broader efforts to curb manipulative, fraudulent, and unfair trade practices in the Indian securities market. Mule accounts, often used to disguise the true identity of individuals behind illegal transactions, facilitate market manipulation by allowing perpetrators to execute trades that can artificially inflate or deflate stock prices, thus misleading investors and destabilizing market integrity. SEBI's prohibition aims to enhance transparency and accountability in financial transactions by targeting these illicit channels.

This regulatory move is part of a larger framework to strengthen market surveillance and enforce compliance with securities laws. By barring the use of mule accounts, SEBI seeks to prevent fraudulent schemes and protect investor interests, reinforcing its commitment to a fair and transparent trading environment. This policy initiative underscores the importance of robust regulatory mechanisms in safeguarding market integrity and promoting investor confidence. The SEBI action reflects a proactive stance against evolving financial crimes, setting a precedent for stricter enforcement and oversight in the Indian financial markets.

Introduction
The Securities and Exchange Board of India (SEBI) plays a pivotal role in regulating and developing India's securities market to ensure its stability, integrity, and transparency. Established in 1988 and given statutory powers under the SEBI Act of 1992, SEBI's primary mandate is to protect investor interests, promote fair trade practices, and prevent fraudulent activities in the stock market.

As financial markets evolve with increasing complexity, SEBI continuously adapts its regulatory framework to counter new forms of financial crimes, such as those involving "mule accounts." Mule accounts, in the context of financial crimes, refer to bank or brokerage accounts opened and operated under the names of individuals who are often unaware of the illicit activities being carried out through their accounts. In some cases, these accounts are willingly provided by individuals in exchange for compensation, while in others, the actual owners might be unaware that their credentials have been compromised. These accounts are instrumental in concealing the identity of perpetrators involved in illegal financial transactions, including money laundering, insider trading, and stock market manipulation.[1]

SEBI has identified the use of mule accounts as a growing threat to market integrity. The rise in digital trading platforms and online account opening procedures has made it easier for individuals or criminal organizations to create mule accounts, often using fake or stolen identities. These accounts facilitate market manipulation by enabling perpetrators to engage in large-scale buying or selling of securities without drawing regulatory attention to their true identities.

By doing so, they can artificially inflate or deflate stock prices, misleading other investors and disrupting the fair functioning of the market. Recognizing the severity of the issue, SEBI has taken decisive steps to prohibit transactions through mule accounts as part of its broader efforts to curtail fraudulent and unfair trade practices. This action aligns with SEBI's ongoing commitment to ensuring transparency and accountability in the financial markets. By targeting mule accounts, SEBI aims to close a major loophole exploited by market manipulators, thereby safeguarding investor interests and promoting a level playing field for all market participants.

The Securities and Exchange Board of India issued a notification for the (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) (Amendment) Regulations, 2024. The regulations empower u/s 30 of the SEBI Act, 1992, amending the 2003 Regulations.[2]The key amendments include defining "mule account" and clarifying acts like diversion of assets and transactions through mule accounts as manipulative practices. To curb fraudulent activities the regulation amended the definition of mule account. The regulation mentioned the definition of mule accounts explicitly.

The definition of "mule account" includes a trading account maintained with a stock broker or a dematerialised account or bank account linked with such trading account in the name(s) of a person, where the account is effectively controlled by another person, whether or not the consideration for transactions in the account are paid by such other person;"[3]

In layman terms, a mule account is defined as an account (whether brokerage or bank account) that is operated under someone's name, but used by third parties for illegal activities, such as market manipulation, without the knowledge or consent of the account holder. In some cases, individuals knowingly rent their accounts to perpetrators in exchange for compensation, often without fully understanding the legal ramifications.

The formal recognition of mule accounts in the regulatory framework is a crucial development. Previously, market manipulation through such accounts was difficult to detect due to the absence of clear guidelines around this illicit practice. By defining mule accounts, SEBI aims to improve the detection, monitoring, and enforcement mechanisms related to these fraudulent activities.

This amendment reflects SEBI's proactive stance to close regulatory gaps, especially those exploited by technological advancements and innovative financial schemes. Below is a detailed explanation of two of the core practices outlined in the amendments:
  1. Diversion of Assets
    Diversion of assets refers to the illegal transfer of assets or funds, intended for a specific purpose, to another account or activity. This diversion often involves mule accounts-accounts used without the knowledge of the rightful owners or, in some cases, willingly by individuals acting as intermediaries for illegal activities. SEBI's 2024 amendment now clearly categorizes such practices as manipulative activities.[4]
     
  2. How Diversion of Assets Affects Market Integrity:
    Deceptive pricing: By diverting funds, market participants can create a misleading financial picture of a company's health or a particular stock's valuation. For instance, if funds meant for operational purposes are diverted into buying shares of the company, this can inflate the stock price artificially. Retail investors, unaware of this manipulation, might buy shares at a price much higher than the actual value.
    Illicit gains: Fraudsters often divert funds to take advantage of insider knowledge or to manipulate stock prices for their own benefit. By using multiple accounts, including mule accounts, they can obscure the origin of the funds and profit from illicit trades at the expense of unwary investors.

    Scholarly research supports that diversion of assets is a common feature of fraud in markets where regulatory oversight is weaker. For example, Bhasin (2015) noted that corporate fraud often involves the unauthorized movement of assets to boost stock prices temporarily, which misleads investors about the real value of a company's stock. Similarly, Saha & Bhattacharya (2017) highlighted the role of asset diversion in financial fraud, emphasizing that regulatory measures like SEBI's amendment are critical to curbing such practices.[5]

    Diversion of assets is a common feature of fraud in markets where regulatory oversight is weaker. For example, Bhasin (2015) noted that corporate fraud often involves the unauthorized movement of assets to boost stock prices temporarily, which misleads investors about the real value of a company's stock. Similarly, Saha & Bhattacharya (2017) highlighted the role of asset diversion in financial fraud, emphasizing that regulatory measures like SEBI's amendment are critical to curbing such practice.[6]

    The diversion of assets has long been considered an indirect form of market manipulation under the general principles of securities law. However, prior to the 2024 amendment, it was often difficult to prove intent or connection to price manipulation. With SEBI's clearer categorization of this activity as fraudulent, it becomes easier to identify and prosecute instances where diverted assets have led to stock price inflation or deflation, thus improving investor protection.[7]

    Mule accounts are a critical tool in the facilitation of financial fraud, particularly in securities markets. These are bank or brokerage accounts used by third parties-often without the knowledge of the actual account holder-to conduct illicit activities. In many cases, individuals willingly allow their accounts to be used for compensation, thus becoming active participants in financial crime. Mule accounts play a significant role in market manipulation by helping to disguise the identity of fraudsters, hide irregular trading activities, and inflate or deflate stock prices artificially.

Sebi's Stance In The 2024 Amendment

The 2024 amendment to the Prohibition of Fraudulent and Unfair Trade Practices Regulations (2003) strengthens SEBI's ability to address the issue of mule accounts. SEBI now explicitly categorizes transactions through mule accounts as manipulative practices. This amendment enables SEBI to more efficiently monitor and takes action against market participants engaged in illegal activities using these accounts.

The primary ways mule accounts are utilized in market manipulation include:
  1. Disguising identity: Fraudsters use mule accounts to distance themselves from suspicious transactions, making it difficult for regulatory authorities to trace the origin of fraudulent trades. This lack of transparency allows illegal actors to engage in insider trading, front running, or other forms of manipulative practices without exposing their identities.
     
  2. Obscuring market activities: Fraudsters manipulate stock prices by using mule accounts to execute numerous trades across various markets. This practice creates artificial demand or supply, causing stock prices to inflate or deflate without any legitimate economic basis. A single individual or entity may use multiple mule accounts to give the false appearance of high trading volumes, deceiving other market participants.

Research and Academic Insights
Numerous academic studies highlight the detrimental effects of mule accounts in market manipulation. Dyck, Morse, and Zingales (2014)[8] discuss how multiple accounts are employed by fraudsters to spread trades across various markets, making it difficult for regulators to detect suspicious patterns.

They further emphasize that market manipulation through these channels not only distorts market prices but also erodes investor confidence in market fair, Healy and Palepu (2001) examine the role of information asymmetry in market regulation, where mule accounts obscure the flow of critical trading information. This lack of transparency in the trading process prevents proper price discovery, causing market prices to deviate from their actual economic value. The mile accounts, thus, impedes market efficiency and results in significant harm to retail investors who rely on fair and accurate price signals when making investment decisions.

Consequences And Scams Of Mule Account Manipulation

  1. Job Scams: They are a form of fraud where scammers pose as potential employers offering lucrative job opportunities, often without the victim having applied for the position. These scams typically occur in the following ways:
    • Unsolicited job offers: Victims receive messages from so-called employers offering a position that the individual never applied for. These offers usually sound too good to be true, offering high-paying roles with minimal qualifications or experience required. The scammer will often provide vague or no details about the company and offer little to no information about the job responsibilities or the hiring process.
    • Request for personal information or money: Once the victim shows interest, the scammer may request personal information, including Social Security numbers, banking details, or copies of identification documents, under the guise of conducting background checks. In other instances, the scammer may ask the victim to pay upfront for training, software, or equipment necessary for the job, only to disappear after the money is transferred.
    • Consequences: Victims can suffer identity theft, unauthorized use of their bank accounts, and financial losses. In some cases, scammers may even involve victims in illegal activities without their knowledge, such as money laundering through mule accounts. To avoid job scams, it is essential to verify the legitimacy of the employer by researching the company, checking for online reviews, and ensuring that all communications come from official company channels.
       
  2. Romance Scam: Romance scams exploit individuals' emotional vulnerabilities, particularly those seeking companionship or romantic relationships online. These scams occur predominantly through social media platforms, dating apps, or even unsolicited messages in personal emails.
    • The scam process: In a romance scam, the scammer builds a connection with the victim, often pretending to be an ideal partner. They create elaborate stories and fake identities to gain the victim's trust, sometimes maintaining the illusion for weeks or months. The scammer may claim to be from a distant location, making it difficult to meet in person, thus justifying why all interactions must remain online or through messaging apps.
       
    • Requests for money: After establishing trust, the scammer will typically fabricate a story that involves a financial emergency-such as needing money for medical bills, travel expenses, or a sudden business crisis. Once the victim sends money, the scammer continues to invent reasons to ask for more, or they may disappear altogether.
       
    • Emotional and financial harm: Romance scams not only lead to financial loss but also cause significant emotional harm to the victim. Victims often find it difficult to report the crime due to feelings of embarrassment or shame. According to research, romance scams lead to millions in losses annually, making them one of the most profitable types of scams for fraudsters.
       
  3. Investment Scams: Investment scams entice victims with promises of quick and substantial returns on investments with little to no risk. These scams are often perpetrated through cold calls, text messages, emails, or social media platforms. Investment scams typically include the following elements:
    • Promise of high returns: Scammers offer investment opportunities that claim to deliver guaranteed or exceptionally high returns in a short period. These investments are often in areas unfamiliar to the victim, such as cryptocurrency, foreign exchange trading, or real estate schemes in distant locations.
       
    • Pressure tactics: The scammer may create a sense of urgency, pressuring the victim to invest quickly to avoid "missing out" on a lucrative deal. They might claim that the opportunity is only available for a limited time or that a big investor is about to buy in.
       
    • Lack of transparency: Scammers often provide little to no information about the investment's legitimacy or how returns will be generated. They may not disclose any risks or may offer vague explanations. Ponzi schemes or pyramid schemes are common forms of investment scams, where the scammer uses money from new investors to pay off earlier investors, giving the illusion of profitability.
       
    • Consequences: Victims of investment scams often lose significant amounts of money, and because these scams are usually operated online or internationally, it can be difficult to recover the funds. Furthermore, the victims may also face tax liabilities or legal complications if their money was involved in illegal activities unknowingly.
       
  4. Impersonation Scams: Impersonation scams involve fraudsters pretending to be representatives of legitimate organizations, such as government agencies, courier services, banks, or well-known companies, to extract personal or financial information from their victims.
    • Pretending to be government or law enforcement: In many cases, scammers impersonate officials from government bodies such as tax agencies, immigration services, or law enforcement. They may claim that the victim owes taxes, has unpaid fines, or is involved in a legal case, using fear and intimidation to coerce the victim into paying money or revealing personal information.
       
    • Courier or bank impersonations: Scammers often pretend to be representatives from courier companies, claiming that a package needs to be delivered and requesting personal details, like the victim's address or identification. In some cases, they impersonate bank officials, asking for sensitive financial information to "verify" transactions or prevent fraudulent activities.
       
    • Tech support impersonation: A common variation of this scam involves fraudsters impersonating tech support from well-known companies. The victim is told their computer is infected with malware and that they must grant remote access to fix the issue. Once access is given, the scammer can steal personal files, passwords, or bank details.
       
    • Consequences: Victims of impersonation scams often suffer from identity theft, unauthorized access to their financial accounts, and financial losses. Scammers may also use the stolen information for fraudulent activities, further complicating the recovery process for victims. Once personal information is compromised, the victim may face long-term issues related to credit scores and financial credibility.
       
  5. Market Distortion: The 2024 SEBI amendment explicitly categorizes transactions through mule accounts as a direct threat to market efficiency due to the significant distortions they cause in price signals. The primary role of a financial market is to ensure accurate price discovery, where the price of securities reflects their true underlying value based on market demand, company performance, and economic factors. However, the use of mule accounts disrupts this crucial function, leading to artificial price inflation or deflation, thus sending false price signals to the market.
    • Artificial Price Movements: Mule accounts allow fraudsters to conduct trades that have no basis in the real economic performance of the securities involved. By coordinating buy or sell orders through multiple accounts, these individuals can create an illusion of heightened market activity. For example, a fraudster could use mule accounts to rapidly purchase large volumes of a stock, giving the appearance of rising demand. Conversely, mule accounts can also be used to depress stock prices, leading to unwarranted panic selling.
       
    • Broader Market Implications: These distortions affect not only the particular stock being manipulated but also the broader market environment. If multiple stocks are manipulated simultaneously, the entire market may experience volatile price swings, which reduces investor confidence and harms the overall health of the financial ecosystem.
       
  6. Investor Harm: One of the most significant consequences of mule account manipulation is the harm it causes to retail investors. Retail investors, unlike institutional investors, often lack the sophisticated tools and expertise to detect market irregularities or spot manipulative trading patterns. Instead, they tend to rely heavily on price movements as a key signal when making investment decisions. The use of mule accounts to manipulate stock prices, therefore, disproportionately impacts these investors by presenting misleading information that leads to poor investment choices.
    • Misleading Price Signals: Retail investors often use price movements to gauge a stock's performance or the broader health of a company. When fraudsters use mule accounts to artificially inflate stock prices, retail investors may interpret the price increase as a sign of strong demand or positive market sentiment, only to lose substantial amounts of money when the fraud is uncovered.
    • Undermining Investor Confidence: The emotional and psychological effects of such schemes on retail investors are also significant, causing some to withdraw from stock trading altogether, which harms market liquidity and vibrancy.
    • Institutional vs. Retail Investors: While institutional investors may also suffer from price manipulation, they have more resources to identify unusual trading patterns, unlike retail investors who are at a disadvantage.
In the long term, repeated incidents of mule account manipulation can lead to a market exodus among retail investors. When market manipulation goes unchecked, it creates a perception that the market is rigged in favor of fraudsters or insiders, which can deter new investors from entering the market. This erodes the broader public's trust in the financial system and reduces the attractiveness of stock markets as a viable means of investment. In such an environment, market participation dwindles, liquidity dries up, and the overall efficiency of the capital markets declines, making it harder for businesses to raise capital through public listings.

Criteria For Mule Accounts To Fall Under Unfair Trade Practices

Mule accounts, used in financial markets to facilitate manipulative schemes, have been classified as a significant threat to market integrity in the 2024 SEBI Amendment. The amendment aims to address market manipulation by regulating accounts that engage in unfair trade practices. This section outlines the criteria for an account to be identified as a mule account and classified under unfair trade practices, based on SEBI's recent regulatory framework.

Characteristics of Mule Accounts

  1. Intent to Disguise the Real Identity of the Trader: A primary characteristic of a mule account is the intent to conceal the identity of the person or entity conducting the trades. By hiding behind third-party accounts, manipulators avoid regulatory scrutiny and traceability. According to SEBI's regulations, if an account is being used with the deliberate intent to disguise the true identity of the trader, it constitutes unfair trade practices (Securities and Exchange Board of India [SEBI], 2024).
     
  2. Facilitating Artificial Price Movements: Mule accounts often facilitate market manipulation schemes that artificially influence stock prices. These manipulative practices, such as creating false price signals by inflating or deflating stock values, mislead market participants and harm market efficiency. According to Dyck, Morse, and Zingales (2014), the creation of fictitious demand through multiple accounts leads to misleading price movements, undermining market integrity (Dyck et al., 2014).
     
  3. Lack of Genuine Economic Transactions: Mule accounts are often involved in trades that are not based on genuine economic rationale. If trades carried out through these accounts serve no real economic purpose and are instead aimed at speculation or manipulation, SEBI classifies this as an unfair trade practice under the 2024 amendment (SEBI, 2024). Transactions that inflate prices through coordinated buy/sell activities fall within this criterion (Healy & Palepu, 2001).
     
  4. Transfer of Assets or Funds for Manipulative Purposes: One of the critical indicators of mule accounts is the diversion of assets or funds meant for legitimate purposes into accounts that are used for market manipulation. According to the 2024 SEBI amendment, this includes the transfer of funds into mule accounts for practices such as pump-and-dump schemes or circular trading, where securities are bought and sold between connected accounts to artificially inflate volume and prices (SEBI, 2024).
     
  5. Involvement in Market Manipulation Schemes: Mule accounts are commonly used in broader market manipulation schemes like insider trading and front-running. By spreading trades across multiple accounts, manipulators can obscure their activities and engage in these illicit practices with reduced detection risk. SEBI considers any involvement in such schemes as grounds for identifying an account as a mule account under unfair trade practices (SEBI, 2024).
     
  6. Lack of KYC Compliance: In many cases, mule accounts are opened using false or incomplete Know Your Customer (KYC) documentation, making it harder to trace their activities. Accounts that lack transparency and do not comply with KYC norms are more likely to be flagged as mule accounts, as per SEBI's regulations (SEBI, 2024).
     
  7. Pattern of Unusual Trading Activity: Mule accounts often exhibit abnormal trading behaviours, such as frequent, large trades that are disproportionate to the account holder's financial profile. Such trading patterns are common indicators of market manipulation schemes. SEBI regulations focus on identifying these patterns to classify mule accounts under unfair trade practices (Healy & Palepu, 2001).
     
  8. Use of the Account in Conjunction with Other Illicit Activities: Mule accounts are sometimes part of broader illegal financial schemes, including money laundering and tax evasion. The 2024 amendment reinforces SEBI's commitment to identifying and freezing such accounts to prevent them from contributing to market fraud (SEBI, 2024).

SEBI Clauses to Control Mule Transactions

  1. Regulation 3: The regulation explicitly prohibits any transaction or act that results in fraud, deception, or manipulation of the market. Mule transactions, where third-party accounts are used to conduct illicit trades, fall under this prohibition. Regulation 3 prohibits anyone from engaging in any activity that directly or indirectly manipulates the securities market, including but not limited to fictitious transactions through mule accounts.
     
  2. Regulation 4(2)(e): The 2024 SEBI amendment under Regulation 4(2)(e) prohibits the diversion of funds or assets intended for specific purposes to other unauthorized uses, including the misuse of mule accounts. Such practices are considered fraudulent, as they undermine transparency and fairness in the securities market. This provision empowers SEBI to take action against entities or individuals that misuse funds through mule accounts for manipulative purposes.
     
  3. Regulation 4(2)(a): This regulation prohibits the use of accounts, including mule accounts, to create false or misleading market activity, including the artificial inflation or deflation of stock prices. Manipulators often use mule accounts to conduct multiple trades, creating the illusion of market movement. SEBI's regulation targets these practices and classifies them as unfair trade practices.
     
  4. Regulation 11A: SEBI mandates Know Your Client (KYC) norms as a means to prevent the misuse of accounts for fraudulent purposes. Regulation 11A requires all trading accounts to adhere to stringent KYC norms. Mule accounts often bypass these norms through the use of fraudulent documents or identities. SEBI's enforcement of KYC regulations aims to prevent such accounts from being used for illicit activities, ensuring transparency and traceability in market transactions.
     
  5. Regulation 9A: In cases where SEBI suspects that an account is being used for market manipulation or fraudulent transactions, Regulation 9A allows SEBI to freeze such accounts. This provision gives SEBI the authority to prevent further fraudulent activities through mule accounts by blocking any suspicious financial activity until a full investigation is conducted.

Conclusion
The 2024 Amendment to the Securities and Exchange Board of India (SEBI) regulations represents a pivotal step in combating financial malpractices, particularly the use of mule accounts in the Indian securities market. Mule accounts-bank or brokerage accounts used without the account holder's knowledge for illicit activities-pose a significant threat to market integrity by facilitating market manipulation, money laundering, and insider trading. SEBI's recognition of these accounts as vehicles for fraud highlights the urgency of addressing this issue. The regulatory measures introduced in the 2024 amendment empower SEBI to combat mule account misuse more effectively.

By explicitly categorizing transactions through these accounts as manipulative practices, SEBI enhances its ability to monitor and take enforcement actions against violators. Key provisions, such as prohibiting asset diversion and enforcing strict Know Your Client (KYC) norms, are critical for promoting transparency and accountability in the market.

The implications of these regulations extend beyond SEBI's jurisdiction; they also impact financial institutions and individual investors. Financial institutions must implement stringent KYC procedures to prevent the misuse of accounts, while retail investors need to enhance their financial literacy to recognize potential fraud. A transparent market fosters investor confidence, which is essential for attracting domestic and foreign investments. Looking ahead, SEBI must continue adapting to emerging financial crimes and technological advancements.

Integrating advanced technologies, such as artificial intelligence (AI) and machine learning (ML), into regulatory practices will enhance the detection of suspicious activities. Collaborating with other regulatory bodies can also strengthen the overall regulatory framework. SEBI's proactive measures against mule accounts and related fraudulent activities signify a commitment to maintaining market integrity and protecting investor interests. By fostering a transparent and accountable trading environment, SEBI not only safeguards investors but also contributes to the long-term stability and growth of the Indian financial markets.

End Notes:
  1. https://www.sebi.gov.in/
  2. SEBI, The Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) (Amendment) Regulations, 2024, s. 30, SEBI Act, 1992.
  3. https://www.sebi.gov.in/
  4. M.L. Bhasin, Corporate Accounting Fraud: A Case Study of Satyam Computers Limited, 10 Int'l J. of Bus. & Mgmt. 1 (2015).
  5. https://www.scirp.org/journal/paperinformation?paperid=30220
  6. https://www.osmania.ac.in/UGCMRPfinalReports2018/FFPANDIP-PROJECTFINALREPORT.PDF
  7. A. Saha & A. Bhattacharya, Financial Frauds – Data Analysis and Impact on Indian Economy, 4 Int'l J. of L. & Legal Jurisprudence Stud. 133 (2017).
  8. A. Dyck, A. Morse & L. Zingales, Who Blows the Whistle on Corporate Fraud. 69 J. Fin. 221 (2014).
  9. https://www.interpol.int/en/Crimes/Financial-crime/Money-mules-what-are-the-risks
  10. https://www.interpol.int/en/Crimes/Financial-crime/Money-mules-what-are-the-risks
  11. https://www.interpol.int/en/Crimes/Financial-crime/Money-mules-what-are-the-risks
  12. SEBI, The Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) (Amendment) Regulations, 2024, s. 30, SEBI Act, 1992.
  13. Dyck, Alexander, Morse, Adair, & Zingales, Luigi, Who Blows the Whistle on Corporate Fraud?, 65 Journal of Finance 2213 (2014).
  14. SEBI, The Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) (Amendment) Regulations, 2024, SEBI Act, 1992.
  15. SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003, Regulation 3, Amended in 2024.
  16. https://www.sebi.gov.in/
  17. SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003, Regulation 4(2)(a), Amended in 2024.
  18. SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003, Regulation 11A, Amended in 2024.
  19. https://www.sebi.gov.in/
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