The Carlyle Group

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CARLYLE REAL ESTATE SGR
S.P.A
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BANK OF ITALY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CARLYLE REAL ESTATE SGR S.P.A VOLUNTARILY AGREED TO PAY A FINE IN THE AGGREGATE AMOUNT OF 60,000 EUROS. ALL VALUES REFERRED TO IN
EUROS HEREIN.
3.
Date Initiated (MM/DD/YYYY): 
05/28/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
1431635
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE BANK OF ITALY RAISED THE BELOW TECHNICAL ALLEGATIONS AGAINST CARLYLE REAL ESTATE SGR S.P.A., A NON-U.S. ADVISORY AFFILIATE THAT
CURRENTLY MANAGES ONE REAL ASSETS-RELATED FUND VEHICLE: - CERTAIN PROCEDURAL SHORTCOMINGS IN CARRYING OUT THE REVIEW OF
CERTAIN BENEFICIAL OWNERS UP CERTAIN INVESTORS' OWNERSHIP CHAINS (NONE OF WHICH RESULTED IN THE ADMISSION OF ANY DISQUALIFIED
INVESTORS) AND - IN CONNECTION WITH THE SALE TO A THIRD PARTY OF A CONDOMINIUM UNIT OF A RESIDENTIAL PROPERTY OWNED BY A FUND
VEHICLE, THE LATE FILING OF A SUSPICIOUS ACTIVITY REPORT (I.E., REPORT NOT MADE AT THE TIME OF DEPOSIT, BUT RATHER IN CONNECTION WITH
THE TRANSACTION CLOSING).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
11/26/2019
 Exact
 Explanation
If not exact, provide explanation:
VOLUNTARILY AGREED TO PAY ADMINISTRATIVE SANCTION
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 60,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
FINE OF 60,000 EUROS WAS PAID BY CARLYLE REAL ESTATE SGR S.P.A ON JANUARY 9, 2020
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CARLYLE REAL ESTATE SGR S.P.A VOLUNTARILY AGREED TO RESOLVE THE MATTER BY PAYING A FINE OF 60,000 EUROS IN THE AGGREGATE. THERE WAS
NO FURTHER ACTION REQUIRED TO RESOLVE THE MATTER ONCE PAYMENT WAS MADE ON JANUARY 9, 2020.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST; CENSURE
3.
Date Initiated (MM/DD/YYYY): 
01/13/2025
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
INVESTMENT ADVISERS ACT OF 1940 RELEASE NO. 6816; ADMINISTRATIVE PROCEEDING FILE NO. 3-22403
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN JANUARY 2025, CARLYLE INVESTMENT MANAGEMENT L.L.C., CARLYLE GLOBAL CREDIT INVESTMENT MANAGEMENT L.L.C., AND ALPINVEST PARTNERS
B.V. (TOGETHER, THE "CARLYLE ADVISERS") ENTERED INTO A SETTLEMENT WITH THE SEC AND CONSENTED TO THE ENTRY OF AN ORDER (THE
"ORDER") FINDING THAT THE CARLYLE ADVISERS DID NOT ADHERE TO APPLICABLE RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS
BY FAILING TO MAINTAIN AND PRESERVE CERTAIN COMMUNICATIONS ON UNAPPROVED WRITTEN COMMUNICATIONS PLATFORMS ("OFF-CHANNEL
COMMUNICATIONS"), AND THAT ITS FAILURE TO IMPLEMENT ITS PROCEDURES REASONABLY EXPECTED TO PROHIBIT THESE OFF-CHANNEL
COMMUNICATIONS LED TO A FAILURE TO REASONABLY SUPERVISE ITS PERSONNEL. THE VIOLATIONS FELL UNDER SECTION 203(E)(6) OF THE
ADVISERS ACT, SECTION 204 OF THE ADVISERS ACT, AND RULE 204-2(A)(7) THEREUNDER. THE ORDER REQUIRED THE CARLYLE ADVISERS TO CEASE
AND DESIST FROM COMMITTING OR CAUSING FUTURE VIOLATIONS OF SECTION 204 OF THE ADVISERS ACT AND RULE 204-2 THEREUNDER, CENSURED
THE CARLYLE ADVISERS, AND REQUIRED THE CARLYLE ADVISERS TO PAY A CIVIL MONETARY PENALTY, NO PORTION OF WHICH WAS BORNE BY THE
CARLYLE ADVISERS' CLIENTS. THE CARLYLE ADVISERS ALSO AGREED TO CERTAIN UNDERTAKINGS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
N/A
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
01/13/2025
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,600,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CARLYLE INVESTMENT MANAGEMENT L.L.C. PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $5,600,000 ON JANUARY 16, 2025.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JANUARY 13, 2025, THE SEC ANNOUNCED THE SETTLED ADMINISTRATIVE ORDER ENTERED INTO BY THE CARLYLE ADVISERS, WHICH IS SIMILAR IN
FORM AND CONTENT TO THOSE PREVIOUSLY ENTERED INTO BY NUMEROUS OTHER BROKER-DEALERS AND INVESTMENT ADVISERS AS PART OF THE
SEC'S SWEEP OF FIRMS' USE OF OFF-CHANNEL COMMUNICATIONS. THE ORDER REQUIRED THE CARLYLE ADVISERS TO CEASE AND DESIST FROM
COMMITTING OR CAUSING FUTURE VIOLATIONS OF SECTION 204 OF THE ADVISERS ACT AND RULE 204-2 THEREUNDER, CENSURED THE CARLYLE
ADVISERS, AND REQUIRED THE CARLYLE ADVISERS TO PAY A CIVIL MONETARY PENALTY. THE CARLYLE ADVISERS ALSO AGREED TO CERTAIN
UNDERTAKINGS. IN THE ORDER, THE SEC RECOGNIZED THE CARLYLE ADVISERS' COOPERATION WITH THE SEC STAFF AND THE REMEDIAL EFFORTS
TAKEN PRIOR TO AND AFTER BEING APPROACHED BY SEC STAFF, INCLUDING BEGINNING TO ROLL OUT TO EMPLOYEES ON-CHANNEL MESSAGING
PLATFORMS FOR EXTERNAL COMMUNICATIONS.