AFFINIS helps organizations ease compliance with the Structured Digital Database requirements of SEBI.


Jonosfero International LLP launches AFFINIS© (SDD), the Structured Digital Database specifically designed for compliance with the SEBI requirement under the “Prohibition of Insider Trading Regulations” to maintain a Structured Digital Database.

SEBI continues to tighten its oversight to crack down on insider trading. Stock Exchanges have recently required Listed Entities to publicly certify compliance with the mandate to maintain a Structured Digital Database to track the flow of Unpublished Price Sensitive Information (UPSI). Further measures, including external audits and reviews, are expected.

To bolster stability and confidence in the capital markets, Listed Entities, and Intermediaries (including Fiduciaries) have been exposed to increasingly stringent regulatory requirements and surveillance rolled out by SEBI and its Stock Exchanges. For their part, the actions of SEBI and its stock exchanges can be well appreciated, considering the ever-increasing number of legal cases that have established insider trading in the Indian stock markets. With penalties levied in the hundreds of crores just in recent times, PIT orders in their hundreds, and even eleven cases of Compliance Officers penalized, the trend of regulatory enforcement is only expected to increase.

Fundamentally, anyone who possesses UPSI for a particular listed entity is prohibited from any action vis-à-vis that stock. To tighten compliance with this requirement, SEBI has mandated that Listed Entities and Capital Market Intermediaries must maintain a Structured Digital Database, i.e. SDD. SEBI requires all individuals in organizations to centrally record all flows of UPSI in the SDD, whether internal or external, with key details for each flow (the SDD must capture names and identifiers, organizations, and PAN for internal and external persons, whether sending or receiving); each detail must be captured along with the date and time of UPSI flow and a brief generic description of the nature of UPSI exchanged.

Furthermore, the structured digital database needs to be securely maintained internally by the regulated entity, cannot be outsourced or on a cloud service, and must be non-tamperable, access controlled, and time-stamped with integrated audit trails. These requirements, notified by SEBI to maintain accountability, security, confidentiality, and control, exclude all current solutions; basic tools like Microsoft Excel or maintaining email records remain non-compliant.

AFFINIS© (SDD), recently launched by Jonosfero International, enables organizations to internally and securely maintain their own Structured Digital Database to comply with SEBI Prohibition of Insider Trading regulations. Jonosfero International LLP, a joint venture between two award-winning consulting and risk-management technology firms (Jackstien Practices & Consulting International LLP and Acies Consulting LLP) is headquartered in the Indian financial capital of Mumbai and has been established to meet the complex and growing long-term technology needs of the BFSI sector. Mastered by leaders in risk, finance and technology, AFFINIS© (SDD) promises to meet or surpass each stringent regulatory criterion while remaining intuitive and easy to use.

The AFFINIS family of applications helps organizations remain in compliance with the ever-tightening Insider Trading regulations. AFFINIS SDD is designed to comply with and to be in compliance with SEBI regulations. It is the critical need of the hour and is a great example of the comprehensive risk management thought process here at Jonosfero. AFFINIS combines intelligent design with a natural interface that works the way our clients do,” said Nishant Shah, Managing Partner & CEO of Jonosfero.

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