Vratika Sardesai
HEAD — COMPLIANCE
Vratika brings with her over 16 years of extensive experience across compliance, legal, and secretarial functions within the mutual fund industry. Prior to joining Carnelian, she played a pivotal role in strengthening and overseeing the compliance, legal, and secretarial frameworks at leading mutual fund institutions, including Bandhan Mutual Fund, HSBC Mutual Fund, L&T Mutual Fund, SBI Mutual Fund, Mirae Mutual Fund, and ICICI Prudential Mutual Fund. Her experience is marked by a strong focus on enhancing operational processes, ensuring robust regulatory compliance, and securing licenses and approvals across various asset management businesses. This wide-ranging exposure reflects her deep domain expertise and hands-on understanding of regulatory and governance requirements in the mutual fund space. In her current role at Carnelian Mutual Fund, Vratika will be responsible for end to end oversight of the Compliance and Legal functions, ensuring adherence to regulatory requirements and the effective implementation of compliance policies and processes to support the smooth and efficient functioning of the business.
Roles and Responsibilities for Risk Management
- Responsible for the governance of compliance and regulatory risks.
- Formulate and implement compliance policies including: prevention of front-running; outside business activity; whistle blowing; record retention; outsourcing arrangements; in accordance with the SEBI RMF framework.
- Review and suggest changes to policies; obtain Board of AMC and Trustee approval.
- Ensure identification and communication of regulatory updates to the relevant functions and CXOs; monitor implementation.
- Provide inputs to the CRO to define risk thresholds and risk appetite for compliance risk.
- Provide relevant information to the CRO for monthly and quarterly risk reporting to committees.
- For relevant functional risks, identify, analyse and report to the CRO and CEO (with recommended action plans) on: early warning signals; emerging risks; major findings; near-miss and loss events; fraud incidents.
- Ensure timely and accurate filing of all regulatory returns.
- Review functional risk levels against approved risk thresholds and risk metrics.
- Ensure adherence to the DoP framework.
- Formulate, review and update the RCSA for key compliance risks and controls.
- Identify and implement corrective actions or action plans for control deviations; present to CRO and CEO.
- Ensure timely submission of regulatory reports to SEBI, Board of AMC and Trustee.
- Monitor scheme-related disclosures: disclosure of credit, counterparty, investment and other risks to investors; risk profile in SID and marketing materials; incorporation of risk appetite elements as stipulated in SID.
- Implement process for prevention or detection of possible insider trading at personnel or portfolio level.
- Implement compliance check process for AMC marketing materials, website uploads, digital advertising and performance advertising before use.
- Ensure that roles and responsibilities as per the RMF are disclosed on the AMC website.
Key Result Areas (KRAs) for Risk Management
- Adherence to Risk Management Framework
- Compliance with roles and responsibilities and DoP framework
- Risks and inconsistencies / outliers identified and reported to CEO / CRO
- Timely implementation of corrective actions for the risks and deviations relating to compliance function
- Timely reporting of fraud, loss and near missing events relating to Compliance function
- Timely reporting to the regulator, Board of AMC and Trustee
- Adequacies in disclosure in SID
- Process for performing compliance check on the marketing material
- Identification and timely implementation of regulatory changes
- Risk incidents / events beyond the defined thresholds or tolerance limits, or the elements in the risk registers which are mapped to the compliance function