RIA profile

Carnelian Asset Management & Advisors Private Limited

MUMBAI, MAHARASHTRA, IndiaCRD 335103Registration Status: ApprovedEffective since May 11, 2026SEC # 801-134884Latest Form ADV May 11, 2026
Assets Under Management
$1.5B
Employees
73
Offices
1 office
Total Clients
4,540

Carnelian Asset Management & Advisors Private Limited is an SEC registered investment adviser organized as a corporation with a primary office location in Mumbai, Maharashtra, India. Its latest Form ADV filing, dated May 11, 2026, reports $1.5B in regulatory assets under management, 73 employees, 1 office, and 4,540 accounts.

Associated firm names

3 names listed
  • CARNELIAN ASSET MANAGEMENT & ADVISOR PVT LTD
  • INVESTMENT MANAGER & PORTFOLIO MANAGER
  • CARNELIAN ASSET MANAGEMENT & ADVISORS PRIVATE LIMITED

Leadership

3 roles identified
CEOSwati Khemani
CCOSwapan Dutta
COOPankaj Namdharani

Advisory services offered

3 types reported
Portfolio management for businesses
Portfolio management for individuals and small businesses
Portfolio management for pooled investment vehicles

Fee models offered

3 types reported
Asset based fees
Fixed fees
Performance-based fees

Offices & Contact

Primary office

MUMBAI, MAHARASHTRA, India

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Primary office regionOther reported regions
India

MUMBAI, MAHARASHTRAPrimary office

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

1 office records listed · 1 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$1.5Bas of May 11, 2026
Discretionary100.0%
$1.5B
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentHNWI represent 99.9% of total clients.
Top client categories% of clientsClients
1
HNWI
99.9%
4,535
2
Pooled Investment Vehicles
0.1%
5

Assets Under Management

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$1.5B
Total Accounts4,540
10Y AUM Change$0 (0.0%)

Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees73
Clients per Employee62:1
10Y Employee Change0 (0.0%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.

Private Funds

Private funds reported by Carnelian Asset Management & Advisors Private Limited

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Custodians

Reported custodian relationships by Carnelian Asset Management & Advisors Private Limited

  • NUVAMA CUSTODIAL SERVICES LIMITED

    $954,920,000

These custodians are disclosed for separately managed accounts under Form ADV’s 10% reporting threshold. This is not a complete list of custodians for all client assets.


Ownership

Reported direct and indirect relationships by Carnelian Asset Management & Advisors Private Limited

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
Vikas KhemaniDirect owner · Schedule AInterest in CARNELIAN ASSET MANAGEMENT & ADVISORS PRIVATE LIMITED
25% to < 50%
Swati KhemaniDirect owner · Schedule AInterest in CARNELIAN ASSET MANAGEMENT & ADVISORS PRIVATE LIMITED
25% to < 50%
Manoj BahetyDirect owner · Schedule AInterest in CARNELIAN ASSET MANAGEMENT & ADVISORS PRIVATE LIMITED
5% to < 10%

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Carnelian Asset Management & Advisors Private Limited.

No indirect ownership information reported in the source’s Schedule B.

Reported ownership and control details

5 entries

Compliance & Disclosures

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that none of the events below involve the firm or its supervised persons.RIA responseNo
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions5 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 1 source block

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

civil judicial · sectionPDF pages 25–26
Full extracted filing text

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

No Information Filed
a t
Exemption from brochure delivery requirements for SEC-registered advisers
SEC rules exempt SEC-registered advisers from delivering a firm brochure to some kinds of clients.  If these exemptions excuse you from delivering a
brochure to all of your advisory clients, you do not have to prepare a brochure.
Yes No
Are you exempt from delivering a brochure to all of your clients under these rules?
If no, complete the ADV Part 2 filing below.
Amend, retire or file new brochures:
Part 3
CRS
Type(s)
Affiliate Info
Retire
Investment Advisor
Execution Pages
DOMESTIC INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the
SEC and all amendments. 
Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the
state in which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to receive
service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for
arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action,
administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or
arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b)
is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939,
the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state
in which you maintain your principal office and place of business or of any state in which you are submitting a notice filing.

Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under
penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other
information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody
or possession of these books and records to make them available to federal and state regulatory representatives.
Signature: 
Date: MM/DD/YYYY 
Printed Name:
Title: 
Adviser CRD Number: 
335103
NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the
SEC and all amendments.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or
other legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons
may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and
you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration
brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in
connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the
provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or
the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a notice filing.
2. Appointment and Consent: Effect on Partnerships
If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws
from or is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this
irrevocable power of attorney and consent shall be in effect for any action brought against you or any of your former partners.
3. Non-Resident Investment Adviser Undertaking Regarding Books and Records
By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in
Washington D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission,
correct, current, and complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940.
This undertaking shall be binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of
attorney or any of your general partners and managing agents.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both certify,
under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any
other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody
or possession of these books and records to make them available to federal and state regulatory representatives.
Signature: 
/S/ SWAPAN DUTTA
Date: MM/DD/YYYY
05/11/2026
Printed Name:
/S/ SWAPAN DUTTA
Title: 
CCO
Adviser CRD Number: 
335103

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix database. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.