Photo of Vasudha Goenka

Partner in the Dispute Resolution practice at the Mumbai office of Cyril Amarchand Mangaldas with a special focus on Securities Regulatory work. Vasudha has over 16 years of experience, before joining the firm, Vasudha was a Deputy General Manager with SEBI. She can be reached at

FIG Paper - Navigating SEBI’s Definition of UPSI


The objective of the PIT Regulations is to prohibit insiders with access to Unpublished Price Sensitive Information (“UPSI”) from making illicit gains and to ensure timely, adequate and even disclosure of UPSI to the public. Hence, the determination of what constitutes as UPSI becomes necessary. In this regard, the Securities and Exchange Board of India (“SEBI”) has signalled a shift from a principle-based regime to a more prescriptive regime, which is likely to result in increased compliance obligations for the listed companies.Continue Reading FIG Paper (No. 26 – Series. 3): Navigating SEBI’s Definition of UPSI