Kathmandu: A detailed investigation into alleged insider trading involving businessman Sulabh Agrawal and his son, Krishiv Agrawal, at Himalayan Life Insurance has uncovered a complex, carefully orchestrated scheme that appears to have been designed to bypass regulatory restrictions and extract substantial financial gains.
What initially looked like a routine family property settlement has now emerged as a potential case of regulatory evasion, exposing how internal controls in Nepal’s securities market may have been manipulated.
The inquiry, conducted by the Securities Board of Nepal (SEBON), focused on trading activities linked to Sulabh Agrawal, the then-chairman of Himalayan Life Insurance, and his son. During the investigation, authorities discovered that more than 800,000 shares held in Sulabh’s name, shares that were subject to a mandatory “lock-in” period, were transferred and sold through what appears to have been a staged intra-family property division. This manoeuvre allowed the shares to be offloaded in the market despite legal restrictions prohibiting their sale.
The fact that only one son was granted a large block of shares, precisely those under lock-in restriction, suggests that the settlement may have been structured specifically to enable their liquidation
On the surface, the transaction seemed legitimate. Krishiv Agrawal sold 803,031 shares of Himalayan Life Insurance through Bhirkuti Stock Broking Company, claiming that the shares had been received as part of a family inheritance settlement. The proceeds from the sale, amounting to over 328 million rupees, were deposited into his account at Nepal Investment Mega Bank on October 7, 2025. However, investigators found that the transaction was not as straightforward as it appeared.
According to the findings, the family settlement itself was engineered as part of the scheme. A legal case was filed in the Kathmandu District Court in which Sulabh’s wife, Shubhi Agrawal, accused him of failing to provide proper care and support for her and their children. The case, which also involved their sons Krishiv and Advitya, was ultimately settled through a court-approved compromise. Under this agreement, most family assets remained jointly held, while Krishiv alone received the 803,031 shares of Himalayan Life Insurance and an additional 10 million rupees in cash. In exchange, he waived any future claims to other family assets.
This selective allocation raised immediate suspicion. The fact that only one son was granted a large block of shares, precisely those under lock-in restriction, suggests that the settlement may have been structured specifically to enable their liquidation. The timing of events further reinforces this interpretation. Within days of receiving the shares, Krishiv sold them in the market, and just three days after the sale proceeds were credited to his account, he transferred 230 million rupees—roughly 70 percent of the total—to his father.
This flow of funds is central to the case. While the shares were technically sold by Krishiv, the majority of the financial benefit appears to have been redirected to Sulabh, who was legally barred from selling the shares himself due to his position as chairman. Investigators concluded that this arrangement effectively allowed Sulabh to circumvent the lock-in rule by using his son as an intermediary.
The report titled “Preliminary Investigation into Securities Transactions of Himalayan Life Insurance Limited by Former Chairman Sulabh Agrawal and Krishiv Agrawal, 2026” explicitly characterizes the share transfer as a “fabricated family partition.” It states that the shares were transferred under the guise of inheritance solely to facilitate their sale and that the subsequent redistribution of proceeds confirms Sulabh as the ultimate beneficiary.
Further analysis revealed additional financial trails. From the same pool of funds generated by the share sale, Krishiv transferred 20 million rupees to his grandmother, Lalita Agrawal, and 78.4 million rupees to Jagdamba Steel Limited. These transactions indicate a broader network of fund distribution that extends beyond the immediate father-son relationship, suggesting coordinated financial planning rather than independent actions by Krishiv.
The legal implications of these findings are significant. Under Nepal’s Securities Registration and Issuance Regulations, 2017, insiders such as company executives are prohibited from selling shares during a specified lock-in period. By transferring the shares to his son and orchestrating their sale, Sulabh is believed to have violated Rule 38(1a) of the regulation. SEBON has concluded that the act constitutes a fraudulent transaction under Section 98 of the Securities Act, 2007, which addresses deceptive practices in securities trading.
The mechanics of the transaction further illustrate how the system was navigated. The shares in question were initially credited to Sulabh’s account following a merger on June 18, 2023. Shortly thereafter, they were transferred to a broker account at Bhirkuti Stock Broking. In May 2025, additional bonus shares were issued, and in June 2025, the original block of shares was transferred to Krishiv’s beneficiary account through a “household transfer” process, supported by court documentation.
This transfer was facilitated by submitting identity documents, court orders, and a formal application through the brokerage firm. The broker then coordinated with CDS and Clearing Limited to execute the transfer. Once the shares were released from restriction, they were credited to Krishiv’s account and subsequently sold between late July and early August 2025.
An unusual detail uncovered during the investigation adds to the suspicion: Krishiv’s account was registered using his father’s email address and mobile number. This raises questions about the degree of independence in his financial decisions and whether he was acting autonomously or under direct instruction.
These findings paint a picture of a deliberate attempt to exploit legal and procedural loopholes in Nepal’s securities framework
The pattern of transactions suggests a high level of coordination. Not only were the shares transferred and sold in a narrow timeframe, but the proceeds were also redistributed quickly and systematically. The use of RTGS (Real-Time Gross Settlement) transfers ensured that large sums could be moved efficiently between accounts, leaving a clear but rapid trail of financial activity.
Adding another layer to the case, investigators found that the same computer system was used to execute transactions involving shares purchased under the name of Deepak Bhatt and those sold under Krishiv’s account. This overlap raises further concerns about possible collusion and shared operational control, potentially linking multiple individuals in a broader network of coordinated trading activity.
Taken together, these findings paint a picture of a deliberate attempt to exploit legal and procedural loopholes in Nepal’s securities framework. By staging a family dispute, securing a court-approved settlement, and leveraging brokerage and banking systems, the individuals involved appear to have constructed a pathway to convert restricted shares into liquid assets without triggering immediate regulatory barriers.
The case now stands as a critical test for Nepal’s financial regulators. It highlights the need for tighter oversight of intra-family asset transfers, improved synchronization between legal and financial institutions, and more robust mechanisms to detect beneficial ownership in complex transactions. As the investigation progresses, it may not only determine the legal consequences for those involved but also shape future reforms in the country’s capital market governance.
Comment Here