New Silk Route Advisors, L.P.

Allegations: THE SETTLEMENT ORDER, ENTERED BY THE SECURITIES AND EXCHANGE COMMISSION ON DECEMBER 14, 2016 (THE "SETTLEMENT ORDER"), AROSE FROM INVESTMENTS MADE BY TWO PRIVATE FUNDS (COLLECTIVELY, THE "NSR FUNDS") ADVISED BY NEW SILK ROUTE ADVISORS, L.P. ("NSR") IN FOUR PORTFOLIO COMPANIES IN WHICH ANOTHER PRIVATE EQUITY FUND (THE "RELATED FUND") ADVISED BY VEDANTA MANAGEMENT, L.P., AN INVESTMENT ADVISER AFFILIATED WITH NSR ALSO INVESTED (SUCH INVESTMENTS, THE "CO-INVESTMENTS"). THE SETTLEMENT ORDER INCLUDED FINDINGS THAT (1) NSR FAILED TO OBTAIN THE LIMITED PARTNER ADVISORY BOARD CONSENTS FOR THE CO-INVESTMENTS REQUIRED UNDER THE NSR FUNDS' LIMITED PARTNERSHIP AGREEMENTS AND (2) NSR DID NOT ADOPT OR IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS. AS A RESULT, THE SETTLEMENT ORDER FINDS THAT NSR VIOLATED SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED, AND RULE 206(4)-8 THEREUNDER. NSR CONSENTED TO THE SETTLEMENT ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. Status: Final Sanction Detail: PURSUANT TO THE SETTLEMENT ORDER, NSR WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED, AND RULES 206(4)-7 AND 206(4)-8 THEREUNDER, AND AGREED TO PAY A CIVIL MONEY PENALTY OF $275,000. NSR WAS ALSO CENSURED PURSUANT TO THE TERMS OF THE SETTLEMENT ORDER. Summary: PURSUANT TO THE SETTLEMENT ORDER, NSR WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED, AND RULES 206(4)-7 AND 206(4)-8 THEREUNDER, AND AGREED TO PAY A CIVIL MONEY PENALTY OF $275,000. NSR WAS ALSO CENSURED PURSUANT TO THE TERMS OF THE SETTLEMENT ORDER. THE SETTLEMENT ORDER PROVIDES THAT PAYMENT SHALL BE MADE WITHIN 15 DAYS OF THE ENTRY OF THE ORDER. NO CLAIMS WERE MADE AGAINST ANY OF NSR'S ADVISORY AFFILIATES.

Allegations: THE SETTLEMENT ORDER, ENTERED BY THE SECURITIES AND EXCHANGE COMMISSION ON JULY 17, 2018 (THE "SETTLEMENT ORDER"), AROSE IN CONNECTION WITH THE DISTRIBUTION OF ANNUAL AUDITED FINANCIAL STATEMENTS RELATING TO TWO PRIVATE FUNDS (COLLECTIVELY, THE "NSR FUNDS") ADVISED BY NEW SILK ROUTE ADVISORS, L.P. ("NSR"). THE SETTLEMENT ORDER INCLUDED FINDINGS THAT (1) NSR FAILED TO TIMELY DISTRIBUTE SUCH ANNUAL AUDITED FINANCIAL STATEMENTS TO THE INVESTORS IN THE NSR FUNDS AND (2) NSR DID NOT ADOPT OR IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT SUCH VIOLATION. AS A RESULT, THE SETTLEMENT ORDER FINDS THAT NSR VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED, AND RULES 206(4)-2 AND 206(4)-7 THEREUNDER. NSR CONSENTED TO THE SETTLEMENT ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. Status: Final Sanction Detail: PURSUANT TO THE SETTLEMENT ORDER, NSR WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED, AND RULES 206(4)-2 AND 206(4)-7 THEREUNDER, AND AGREED TO PAY A CIVIL MONEY PENALTY OF $75,000. NSR WAS ALSO CENSURED PURSUANT TO THE TERMS OF THE SETTLEMENT ORDER. THE SETTLEMENT ORDER PROVIDES THAT PAYMENT SHALL BE MADE WITHIN 15 DAYS OF THE ENTRY OF THE ORDER. Summary: PURSUANT TO THE SETTLEMENT ORDER, NSR WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED, AND RULES 206(4)-2 AND 206(4)-7 THEREUNDER, AND AGREED TO PAY A CIVIL MONEY PENALTY OF $75,000. NSR WAS ALSO CENSURED PURSUANT TO THE TERMS OF THE SETTLEMENT ORDER. THE SETTLEMENT ORDER PROVIDES THAT PAYMENT SHALL BE MADE WITHIN 15 DAYS OF THE ENTRY OF THE ORDER. NO CLAIMS WERE MADE AGAINST ANY OF NSR'S ADVISORY AFFILIATES.