Responding to this statement, Hindenburg on its X account wrote, "Buch’s response now publicly confirms her investment in an obscure Bermuda/Mauritius fund structure, alongside money allegedly siphoned by Vinod Adani. She also confirmed the fund was run by a childhood friend of her husband, who at the time was an Adani director."

"SEBI was tasked with investigating investment funds relating to the Adani matter, which would include funds Ms. Buch WAS PERSONALLY INVESTED IN and funds by the same sponsor which were specifically highlighted in our original report. This is obviously a massive conflict of interest," Hindenburg added.

Buch’s statement also claims that the two consulting companies she set up, including the Indian entity and the opaque Singaporean entity “became immediately dormant on her appointment with SEBI” in 2017, with her husband taking over starting in 2019. 

However, per its latest shareholding list as of March 31st, 2024, Agora Advisory Limited (India), is still 99% owned by Madhabi Buch, not her husband. This entity is currently active and generating consulting revenue. Furthermore, Buch remained a 100% shareholder of Agora Partners Singapore until March 16th, 2022, per Singaporean records, owning it during her entire time as a SEBI Whole Time Member. She only transferred her shares into her husband’s name 2 weeks after her appointment as SEBI Chairperson, the short seller posted.

The post further mentioned that the Singaporean consulting entity Buch set up doesn’t publicly report its financials like revenue or profit "so it’s impossible to see how much money this entity has earned during her time at SEBI." 

The Indian entity, still 99% owned by the SEBI Chairperson, has generated Rs 23.985 million (~$312,000) in revenue (i.e. consulting) during the financial years (‘22, ‘23, and ‘24), while she was serving as chairperson, per its financial statements.

Hindenburg cited whistleblower documents to state that "Buch used her personal email to do business using her husband's name while serving as a Whole Time Member of SEBI." 

"In 2017, weeks ahead of her appointment as SEBI Whole Time Member, she ensured the accounts with ties to Adani “be registered solely in the name of Dhaval Buch", her husband, per whistleblower documents. Despite disclaiming control, a private email she sent a year into her SEBI term shows she redeemed stakes in the funds through her husband’s name, per the whistleblower documents. This raises the question: What other investments or business has the SEBI Chairperson engaged in through her husband's name while serving in an official capacity?" it said.

Buch, according to Hindenburg, said her husband used the consulting entities starting in 2019 to transact with unnamed “prominent clients in the Indian industry”. 

"Do these include clients SEBI is tasked with regulating?" it asked. 

"Buch’s statement promised a “commitment to complete transparency”. Given this, will she publicly release the full list of consulting clients and details of the engagements, both through the offshore Singaporean consulting firm, the Indian consulting firm and any other entity she or her husband may have an interest in? Finally, will the SEBI Chairperson commit to a full, transparent and public investigation into these issues?" Hindenburg stated.