The SEBI (Prohibition of Insider Trading) Regulations, 2015 (‘PIT Regulations’), were amended on July 17, 2020 with immediate effect, to provide as follows:

i.    The board of directors or head of every organization required to handle unpublished price sensitive information (‘UPSI’) is required to maintain a structured digital database containing the nature of UPSI, the names of persons who have shared such information, the names of persons with whom information is shared (along with their Permanent Account Number (‘PAN’) or equivalent where PAN is not available);

ii.    This database is required to be maintained internally and cannot be outsourced. Further, the database is required to be maintained for a period of not less than eight years after completion of the relevant transactions and if SEBI initiates any investigation or enforcement proceedings relating to such matters, the relevant information is required to be preserved till the completion of such proceedings;

iii.   Any amounts collected by the relevant companies or organizations under their codes of conduct formulated under the PIT Regulations are required to be remitted to SEBI for credit to the Investor Protection and Education Fund. Further, such companies or organizations are now required to report violations of the PIT Regulations to the relevant stock exchanges (instead of SEBI), in the revised reporting format issued by SEBI by its Circular dated July 23, 2020.