The new FPI regulatory framework is complete with the issuance of Operational Guidelines by SEBI. Considering a lot has been written and talked about the new FPI regime through multiple webinars, conference calls and written updates to explain the new regime, we at KCO felt that it may be more worthwhile to offer an opportunity to our clients and readers to rather ask pertinent questions or to clear any doubts that they may have in respect of this new regime. This may not only help addressing your queries but may help others to get a more practical perspective to the new regime.

Accordingly, we will host a Q&A session for our readers/clients with a panel of our experts to answers any questions that you may have in respect of the new regime and its implications to your business. Our panel of experts comprising of Mr. Siddharth Shah, Ms. Bijal Ajinkya and Mr. Vivek Mimani will endeavour to provide their views and answer queries encompassing eligibility, registration process, investment conditions, KYC as well as taxation. The session will offer you an opportunity to ask questions on the call or ask them online. Please refer to covering email for the link to join the Q&A session.


The Securities and Exchange Board of India (SEBI) has notified the new regulations governing Foreign Portfolio Investors (FPIs) on 23 September 2019 (New Regulations) replacing the SEBI (Foreign Portfolio Investors) 2014 (Previous Regulations). The exercise initiated by SEBI in March 2018 for complete overhauling of the FPI regime started with constitution of a committee under chairmanship of Harun R Khan and culminated into notification of the New Regulations incorporating the recommendations of the committee report published on 24 May 2019 (HR Khan Report).

To complete the exercise, SEBI vide circular dated 5 November 2019 has issued the Operational Guidelines for Foreign Portfolio Investors, Designated Depository Participants and Eligible Foreign Investors (Operating Guidelines) which lays down the process to implement the New Regulations and also serves as a consolidated master document replacing all previous circulars and guidance issued by SEBI. We summarise below the key changes for FPI Investors emerging out of the combined reading of the New Regulations and Operating Guidelines.

Key Changes:

  1. Re-categorisation of FPIs: A set of factors has completely revamped the categorisation of FPIs. Firstly, the requirement that a fund has to be 'broad based' in its investor composition has been removed, thereby obliterating Category III. Secondly, Financial Action Task Force (FATF) member countries are accepted as low-risk jurisdictions and therefore appropriately regulated entities from such jurisdictions shall be accorded Category I registration. Thirdly, pension funds, university funds and all such entities which are controlled or at least 75% owned by government or government related investors shall be recognised as Category I FPI. With this massive re-shuffle, the categorisation stands as follows:
  1. Category I FPI shall include:
  1. government and government related investors such as central banks, sovereign wealth funds, international or multilateral organisations or agencies including entities controlled or at least 75% directly or indirectly owned by such Government and Government related investor(s);
  2. pension funds and university funds;
  3. appropriately regulated entities such as insurance or reinsurance entities, banks, asset management companies, investment managers, investment advisors, portfolio managers, broker dealers and swap dealers;
  4. entities from FATF member countries which are: (A) appropriately regulated funds; (B) unregulated funds whose investment manager is appropriately regulated and registered as Category I FPI; and (C) university related endowments that have been in existence for more than 5 years;
  5. entity whose investment manager is from FATF member country or which is at least 75% owned by another entity which is from FATF member country and otherwise eligible to register under either of the above points; and
  6. an entity (A) whose investment manager is from the FATF member country and such an investment manager is registered as a Category I FPI; or (B) which is at least 75% owned, directly or indirectly by another entity, eligible under (ii), (iii) and (iv) and such an eligible entity is from a FATF member country.
  1. Category II FPI shall include:
  1. appropriately regulated funds not eligible as Category I FPI;
  2. endowments and foundations;
  3. charitable organisations;
  4. corporate bodies;
  5. family offices;
  6. individuals;
  7. appropriately regulated entities investing on behalf of their client, as per conditions specified by the Board from time to time; and
  8. unregulated funds in the form of limited partnership and trusts.

The Operating Guidelines have clarified that an entity from FATF member country shall mean an entity having its primary place of business in a FATF member country and if regulated, is appropriately regulated in a FATF member country.

Transition of existing FPIs: The Operating Guidelines have made the transition seamless and deemed that: (a) all existing Category I FPIs shall continue to be Category I; (b) all existing Category III FPIs shall be Category II; (c) all existing Category II FPIs shall be either Category I or Category II as follows:

Sub-Categories of Category II FPI as per Previous Regulations

Categories as per the New Regulations

Appropriately regulated broad based funds such as mutual funds, investment trusts, insurance/reinsurance companies;

(i) All Insurance entities – Category I;

(ii) Funds from FATF member countries – Category I;

(iii) Funds from non-FATF member countries – Category II

Appropriately regulated persons such as banks, asset management companies, investment managers/ advisors, portfolio managers, broker dealers and swap dealers

All are re-categorised as Category I

University funds and pension funds

All are re-categorised as Category I

university related endowments already registered with the Board as foreign institutional investors or sub-accounts

All are re-categorised as Category I

Unregulated funds/entity categorised as Cat II by virtue of Regulated Investment Manager also registered as Category II FPI

Unregulated funds/entity where regulated Investment Manager is from:

(i) FATF member country and also registered as Category I FPI – Category I

(ii) non-FATF member country – Category II

Any existing Category III FPI fulfilling the eligibility of Category I shall not be deemed as Category I FPI and if so desirous, shall apply to the DDP with the relevant documents and payment of requisite fees. All in-transit applications shall have to be received by the DDP within 90 days from issuance of Operating Guidelines i.e. by 3 February 2020.

Comment: Funds which are not set up in FATF member countries are at a disadvantage and considering that a significant number of FPIs have been traditionally domiciled in Mauritius or Cayman Islands primarily on account of popularity of these jurisdictions for their ease of set up, operations, regulatory certainty and familiarity with investors, the re-categorisation could potentially lead to certain adverse consequences. Such jurisdictions, even though they may be 'associate members' of FATF and appropriately regulated by local regulators, may find themselves having to settle for Category II license. While full implications of such recategorisation are yet to unfold fully, for e.g. continued eligibility to indirect transfer tax which hitherto is available to Category I and Category II FPIs and whether there will be any change in the position post recategorisation.

Similarly, how would the re-categorisation impact Category III FPIs who are now deemed Category II FPIs but would this enable them to be qualified buyers (QBs) under SARFAESI law allowing them to purchase security receipts. Similarly, will all Category II FPIs be in a position to participate in qualified Institutional placements or institutional segment of IPOs as QBs will still need to be determined.

  1. Revision of position limits in derivatives: The FPIs were accorded different position limits for investments in derivatives according to the category of their registration. As a consequence of re-categorisation, the position limits have also been revised by the Operating Guidelines as follows:


Category I

Category II- Individual, family office, corporate

Category II- Rest

Stock derivative

20% of MWPL (market wide position limit)

5% of MWPL

10% of MWPL

Index derivative (separately applicable for index futures and index option)

INR 500 crores or 15% of total open interest

INR 100 crores or 5% of total open interest

INR 300 crores or 10% of total open interest

Interest Rate Futures (8-11 years maturity bucket)

10% of open interest or INR 12 billion, whichever is higher

3% of open interest or INR 4 billion, whichever is higher

10% of open interest or INR 12 billion, whichever is higher

Interest Rate Futures (4-8 years and 11-15 years maturity bucket)

10% of open interest or INR 6 billion, whichever is higher

3% of open interest or INR 2 billion, whichever is higher

10% of open interest or INR 6 billion, whichever is higher

Currency derivatives (US Dollar- Rupee)

15% of total open interest or USD 100 million, whichever is higher

6% of total open interest or USD 10 million, whichever is higher

15% of total open interest or USD 100 million, whichever is higher

Currency derivatives (Euro-Rupee)

15% of total open interest or EUR 50 million, whichever is higher

6% of total open interest or EUR 5 million, whichever is higher

15% of total open interest or EUR 50 million, whichever is higher

Currency derivatives (British Pounds-Rupee)

15% of total open interest or GBP 50 million, whichever is higher

6% of total open interest or GBP 5 million, whichever is higher

15% of total open interest or GBP 50 million, whichever is higher

Currency derivatives (Japanese Yen-Rupee)

15% of total open interest or JPY 2000 million, whichever is higher

6% of total open interest or JPY 200 million, whichever is higher

15% of total open interest or JPY 2000 million, whichever is higher

Currency Derivatives (Euro-US Dollar)

15% of total open interest or EUR 100 million, whichever is higher

6% of total open interest or EUR 10 million, whichever is higher

15% of total open interest or EUR 100 million, whichever is higher

Currency Derivatives (British Pound-US Dollar)

15% of total open interest or GBP 100 million, whichever is higher

6% of total open interest or GBP 10 million, whichever is higher

15% of total open interest or GBP 100 million, whichever is higher

Currency Derivatives (US Dollar-Japanese Yen)

15% of total open interest or USD 100 million, whichever is higher

6% of total open interest or USD 10 million, whichever is higher

15% of total open interest or USD 100 million, whichever is higher

The Operating Guidelines have also clarified that short positions in index derivatives cannot exceed the FPI's holding of stocks whereas the long position cannot exceed the FPI's holding of cash, government securities, T-bills and similar instruments.

  1. Processing of applications by DDPs: The Operating Guidelines have issued uniform guidance to be followed by all DDPs for processing both new and in-transit applications. The DDP shall run various checks prescribed in the Operating Guidelines such has: (a) country check to determine IOSCO/FATF membership; (b) declaration that investment by NRIs/OCIs/RIs shall be within permissible limits subject to conditions prevailing in Previous Regulations; (c) declaration on fit and proper person status; (d) Category I FPI check to verify the eligibility of government related entities; (e) regulatory check to verify that the applicant is regulated by banking or securities market regulator either by obtaining a copy of certificate or verification of details directly from registry or website of regulator.
  2. Separate registrations for appropriately regulated entities: The New Regulations stipulate that regulated entities such as banks, investment managers, broker dealers, etc can invest proprietary money as Category I FPI but if they wish to invest their clients' money, they shall have to separately register as Category II FPIs. However, the Operating Guidelines have clarified that Category II registration shall be granted in such cases only when (a) clients are individuals or family offices; (b) clients should also be eligible for FPI registration and should not be dealing on behalf of third party; (c) identification and verification of beneficial owner of clients shall have to be done by FPI as per rules of home jurisdiction of the FPI if FPI is from FATF country otherwise as per Indian KYC laws; (d) the FPI shall provide complete details of its clients on a quarterly basis to the DDP in the format prescribed in the Operating Guidelines.

Comment: Dual FPI registration for such entities managing their own as well as client funds should provide required clarity and addresses the arbitrage that may have existed under the Previous Regulations. However, omnibus accounts will now need to disclose the identity of the underlying investors, and some of the private banks may find this to be a challenge from their clients.

  1. Simplified KYC requirements: The Operating Guidelines have prescribed list of documents required for KYC of both Category I and Category II FPIs at the level of applicant and ultimate beneficial owners (UBOs). The underlying principle of risk-based KYC has been continued with Category I FPIs having lesser KYC documentation having been exempted from providing board resolution and proof of identity of UBOs. Consequently, Category II FPI applicants which are appropriately regulated funds from non-FATF countries shall have the same KYC requirements as Category I FPIs except UBO details. On the other hand, those Category I FPI applicants which are from high risk jurisdictions shall have to meet KYC requirements equivalent of Category II FPIs.

The onerous requirements have been simplified and made easy for the applicants in the following manner: (a) acceptance of power of attorney in lieu of board resolution and as address proof; (b) online verification of PAN or use of e-PAN; (c) acceptance of prospectus/information memorandum in lieu of constitutional document; (d) no requirement of board resolution and authorised signatory list if there is no exchange of physically signed documents and medium of instruction is SWIFT; (e) duplication of producing KYC documents, one at the time of application and second at the time of opening bank account is avoided by permitting DDPs to share relevant KYC documents in their possession to the bank; (f) DDPs permitted to rely on the KYC undertaken by entities forming part of their financial group if such entities are acting as global custodians or investment managers to the applicants and coming from an FATF member country where KYC is carried out as per their home jurisdiction standards provided that local custodian shall collect constitution documents of FPI and upload evidence of KYC reliance. The UBOs shall continue to be identified in accordance with principles already part of Previous Regulations.

KYC review: The KYC shall have to be reviewed every year for Category I and Category II FPIs incorporated in high risk jurisdictions except government and government related investors under Regulation 5(a)(i) and all Category II FPIs from low risk jurisdictions except regulated entities under Regulation 5(b)(i) and Regulation 5(b)(vii). All other FPIs shall have to undertake review of their KYC only at the time of continuance of registration i.e. every 3 years.

Comment: The streamlining of KYC requirements reduces room for discretion by the DDPs and promotes fast track registration. It makes the regulator's intentions clear which is to ease business for foreign investors coming under FPI route.

  1. Flexibility to make certain transactions without stock-broker: The New Regulations permit FPIs to transfer or sell corporate bonds, unlisted shares (acquired pursuant to involuntary corporate actions) and even purchase illiquid (which are not 'frequently traded' in terms of rules laid down by SEBI) or suspended or delisted securities without a stock broker i.e. off-market in accordance with pricing guidelines laid down in FEMA rules. Further inter-se transfers between FPIs which are part of multiple investment manager (MIM) structure and have a common PAN can also be made off-market subject to approval by the DDP.

Comment: The ability to make off-market transfers is a much-needed leeway that FPIs have been vying for long. FPIs have now also been allowed to make off-market sale of listed NCDs acquired by them which otherwise was fairly illiquid and incurred additional cost for negotiated transfers. The ambiguity around whether FPIs can hold unlisted shares pursuant to involuntary corporate actions has also been clarified.

  1. Clarification on 'to be listed' shares and 'to be listed' debt securities: FPIs are permitted to acquire shares to be listed pursuant to IPOs, FPOs, rights issue, private placement or shares received through involuntary corporate actions. Further, FPIs are eligible to invest in corporate debt issues which are 'to be listed' without any end use restriction applicable on unlisted debt securities but if the listing does not happen within 30 days then the FPI shall either dispose the investment to domestic investor or issuer.
  2. Flexibility to invest in corporate bonds under default: The Operating Guidelines have given FPIs the flexibility to acquire NCDs or bonds which are under default, either fully or partly. The investments shall have to be made in accordance with the norms prescribed by RBI on FPI investment in corporate debt. Such investments shall be reckoned against the corporate debt limit prescribed by RBI from time to time.

Comment: This gives much needed impetus and fresh inflow of funds to corporate debt market which faces distress in recent times. The NCD subscribers whose money was subject to default have the opportunity to sell their investment so they can channel into fresh round of corporate debt.

  1. Removal of restriction on opaque structures: FPIs were not permitted to have opaque structures such as protected cell company or segregated portfolio company (SPC) where the assets and liabilities of each cell are ring fenced or where the details of the beneficial owners were not accessible unless ring fencing is mandated under the laws of their home jurisdiction. The New Regulations has lifted such restrictions but the FPI shall have to provide BO declaration of each sub-fund/share class/ equivalent structure that invests in India.

Comment: As identification of beneficial owners has already been mandated for each FPI in accordance with money laundering laws, the restriction on opaque structures served no purpose. This should lend further flexibility for fund/investment structures to take advantage of such segregated liability structures resulting in cost optimisation and investor comfort. Even for multifamily asset managers and portfolio managers, this move should be hugely welcomed.

  1. Mandatory registration of offshore funds of mutual funds: The New Regulations have made it compulsory for offshore schemes (OFO structures) floated by asset management companies (AMCs) of mutual funds to register as FPI within 180 days from the date of commencement of New Regulations in order to invest in India.
  2. Conditions related to offshore derivative instruments (ODIs):

Eligibility: ODIs can only be issued by Category I FPIs and subscribed by or transferred to investors which are eligible for Category I FPI registration only. The limited relief provided herein is that investors which qualify for Category I registration on the basis of FATF membership of their investment manager need not have their investment manager register as Category I FPI. ODIs issued in accordance with the Previous Regulations before the commencement of the New Regulations have been grandfathered, however if the ODI subscriber has become ineligible under New Regulations, it can continue to hold its existing position only till 31 December 2020.

Allowance of ODIs referencing: The Operating Guidelines have imposed a general restriction that neither ODIs can have derivatives as underlying nor the FPI can hedge their ODIs with derivative positions. However, the ODI issuing FPI can take a separate registration if it wants to hedge its ODIs with derivative positions on stock exchanges or if it wants to make proprietary derivative transactions. Thus, through a separate registration FPIs can hedge their ODIs with derivatives subject to a position limit of 5% of MWPL in case of single stock derivatives and 5% of total open interest or INR 100 crores, whichever is higher for index derivatives. The FPIs can also issue ODIs referencing derivatives through separate registration, provided the FPI holds cash equity and has short future position exactly against the cash equity in the same security (one-to-one basis) and it retains the cash equity for the life of ODI.

Separate registration: With the intention to segregate the proprietary derivative investments and ODI activities of the FPI, the Operating Guidelines have prescribed that separate registration shall be required for both the activities. Thus, an FPI issuing ODIs cannot invest in derivatives under the same registration and vice-versa.

Clubbing of holdings of ODI investor: The holdings of two or more ODI subscriber shall be clubbed for the purpose of adherence to 10% single portfolio company limit if such ODI subscribers have common ownership, directly or indirectly, of more than 50% or common control. Further both investments as an ODI subscriber and as an FPI shall be aggregated for the purpose of 10% limit.

KYC of ODI subscribers: The ODI issuing FPI is required to identify and verify the beneficial owners of ODI subscribers in accordance with the same principles as applicable on BO identification of FPIs. The ODI issuing FPI shall collect and maintain KYC documents of ODI subscriber and its BOs and maintain information about intermediate material shareholder of ODI subscriber. The KYC shall be reviewed every year for ODI subscribers from high risk jurisdictions and every 3 years for others.

Comment: The conditions to issue, subscribe or transfer ODIs have been made stringent under the New Regulations. However, the absence of an express restriction on Category II FPIs (unlike the Previous Regulations which prohibited Category III FPIs) and deliberate use of phrase 'eligible for registration as Category I FPI' gives strength to the argument that Category II FPI need only demonstrate its eligibility as a Category I FPI in order to subscribe ODIs and not required to be registered as a Category I FPI per se.

The Operating Guidelines clarify that the onus shall be on the ODI issuing FPI to satisfy itself of the ODI subscriber's eligibility, but it could have done better to lay down minimum standards and document requirements in this regard and eliminate discretion of ODI issuer. The fallout of the New Regulations is that all those jurisdictions which are non-FATF members, even though may be associate members of FATF, will not be restricted from purchasing or issuing ODIs. Two of the more common jurisdictions amongst global investors investing in India viz. Mauritius and Cayman, will both be impacted by the change. However, if funds based in these jurisdictions establish their manager in a FATF jurisdiction where it is regulated, then such entities should qualify for ODI dealings.

Further, investors need to plan their ODI activities at the time of FPI registration itself as the application form prescribes a check-box declaration for separate registration if the FPI intends to hedge ODI with derivatives as underlying.

  1. FPIs can make foreign direct investment (FDI) investments: If the holding of a single FPI or an investor group (which has the same definition as under Previous Regulations) in a particular company exceeds 10% of paid-up capital on a fully diluted basis, then it shall be required to divest its excess holding within 5 trading days from the date of settlement which caused the breach. Failure to divest however will result in excess investment be recognised as investment under FDI and reckoned towards the sectoral cap and norms prescribed by RBI from time to time. The FPI shall not be permitted to trade in securities of that particular company under the FPI route anymore. The FPI or investor group can sell such securities so reclassified as FDI under the FPI route.

Comment: The New Regulations have expressly allowed foreign investors to invest in an Indian company under various routes of investment available to them under Indian laws. This gives foreign investors the opportunity to plan their investments more strategically. However, in a bid to align with the Foreign Exchange Management (Non-Debt Instruments) Regulations, 2019 (FEMA Regulations), the 10% threshold shall be calculated on a fully diluted basis which gives FPIs more headroom for equity structured investments in a company. Further, possibly to avoid misuse, a two-way fungibility between FPI and FDI route has not been granted whereby once the FPI investor invests in the company under FDI, they will no longer be allowed to invest further in that company under FPI. At the same time, exit has been made easier for the FPIs in case they opt to reclassify their investment.

The Operational Guidelines have further clarified the transition of an investment from FPI to FDI. Further, it has clarified that exit methodology for the investment which has got classified as FDI would still need to follow conditionalities as applicable to the mode in which the investment was made. For e.g. investment acquired under the FPI route cannot be sold off market and also once an investment has been classified as FDI, not further purchase on market would be permitted under the FPI route.

  1. Alignment with respect to rules on FPI investment in different instruments: In a bid to harmonise with the rules laid down by RBI on FPI investments and to promote consistency of interpretation, the Operating Guidelines prescribes that investments in debt securities by FPIs shall be guided by directions issued by RBI from time to time. Further, the New Regulations have expressly permitted FPIs to invest in units of real estate investment trusts (REITs), infrastructure investment trusts (InvITs) and Category III alternative investment funds (AIFs) which were not there in Previous Regulations. The Operating Guidelines have clarified that the FPI shall not hold more than 25% stake in a Category III AIF.

Comment: It is not clear whether 25% exposure limit in AIFs shall be applicable on FPI or investor group at large.

  1. Eligibility of FPI based on its underlying investors: The New Regulations provide that if the FPI applicant or its underlying investors contributing 25% or more of the corpus or identified on the basis of control are mentioned on the United Nations sanctions list or belong to countries identified in the public statement of FATF for anti-money laundering (AML) or combating terrorist financing (CFT) deficiencies, the applicant shall lose eligibility to register as FPI.
  2. Designated depository participants (DDPs) to face tighter scrutiny: SEBI has imposed stricter monitoring norms on DDPs which grant registrations to FPIs on behalf of it. They shall be required to segregate their activity as DDPs and other activities undertaken by them. Further, DDPs have to carry annual review of its systems, procedures and controls by an independent professional and shall be required to furnish audit report of its systems and report on action taken on such audit report to SEBI within prescribed timelines.

Comment: DDPs which act as the point of registration for the FPIs are typically major banks which undertake many other activities that a bank is permitted to do including acting as a custodian. Thus, the interests of the organisation as a custodian may be in conflict with that as a DDP. To mitigate this, SEBI has mandated Chinese walls between its activities as a DDP and other businesses. This is a welcome step in our view.

  1. FPIs operating in International Financial Service Centres (IFSCs): An FPI operating in an IFSC is deemed to satisfy the eligibility criteria of not being a resident Indian and being resident in an IOSCO or BIS country. The Operating Guidelines state that registered FPIs proposing to operate in IFSCs shall be permitted, without undergoing any additional documentation and/or prior approval process.

Comment: This could further pave way for offshore entities to explore IFSC as a viable option for trading in Indian securities. Further, since IFSC would be located in India, entities organised in IFSC would qualify for Category I FPI license thereby making it eligible to deal in ODIs. This may encourage some of the fund structures organised in non-FATF jurisdictions such as Mauritius or Cayman to explore relocation of their operations or their managers to IFSC to qualify themselves for a Cat I license.

  1. New Application Form: The Operating Guidelines have issued the new application form for registration as an FPI. The application form requires check box declarations for MIM structures, ODI hedging activities, non-investing FPIs, investing on behalf of clients, NRI/OCI/RI participation, etc. It further contains undertakings for the investment manager and eligible entities on whose strength the applicant is eligible for FPI registration.

Comment: The new application form is streamlined according to the sub-categories within Category I and Category II under which the applicant proposes to register. Hence, on one hand the application form is self-sufficient in many aspects and obviates the need for additional documents, at the same time a prudent reading of the FPI categorisation including sub-categories is necessary to fill up the form. This is because the application form refers to the provisions of the New Regulations at various places where information is required according to the provision being cited and sub-category under which applicant proposes to register. Thus, assessing and choosing the right sub-category becomes important which was not asked in the application form under the Previous Regulations.


The New Regulations read with the Operating Guidelines have definitely infused freshness in the governance of FPIs which has been requiring a retooling since it was notified 5 years ago. Many of the changes it has introduced are in line with the recommendations of the HR Khan Report. Requiring the fund to be broad based had increased the cost of compliance and was also cumbersome particularly for exchange traded funds which had free entry and exit for its underlying investors. Removal of broad-basing and opaque structure restrictions is a welcome step at the right time. It therefore becomes crucial to understand and assess the sub-category under which an applicant intends to register as FPI. Understanding the sub-categories also becomes important because the investment limits accorded to sub-categories of Category II FPIs who were previously under Category III shall differ from the rest of sub-categories.

The Operating Guidelines shall go a long way in reducing regulatory gap and promoting uniformity of interpretation. While a fast track registration and lower KYC requirements has now been extended to a broader set of investors who come under Category I, making FATF membership a pre-requisite to qualify for Category I may come across harsh for some affected structures.

Further, IFSC seems to be coming closer to a reality which these set of changes which may see some movement from global fund managers to start setting up base in GIFT, the first IFSC and make the government's motto of 'manage in India' a reality.

The content of this document do not necessarily reflect the views/position of Khaitan & Co but remain solely those of the author(s). For any further queries or follow up please contact Khaitan & Co at