De Minimis Provisions for AMTOI SRO Institutionalising Sector Standards 04062026

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Shantanu Bhadkamkar (via Google Docs)

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Jun 4, 2026, 10:10:59 AM (3 days ago) Jun 4
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Shantanu Bhadkamkar (s...@atc.co.in) has attached the following document:
This document is not for current submission but a discussion document for dealing with certain aspects of AMTOI SRO in eventual course. This will help establish AMTOI Policy on De Minimis Provisions and Standards.

Subject: Draft Note on De Minimis Provisions – AMTOI SRO Governance Framework

Dear Members of the Managing Committee and the Secretariat,

Please find attached the draft note regarding the "De Minimis Provisions" for our proposed AMTOI SRO Governance Framework.

Thought it wasn't discussed today, the introduction of a *de minimis* threshold is vital for the maturity of our self-regulatory model. It allows the SRO to filter out minor or trifling matters, ensuring that our disciplinary resources and administrative focus are prioritized for substantive issues that truly impact sector integrity. This approach reinforces our commitment to a trust-based, facilitative regulatory environment rather than one driven solely by penalisation.

Please review this note for alignment with our broader Code of Conduct and Disciplinary Framework. We aim to finalise these provisions as part of our upcoming submissions in eventual course, and the Secretariat may kindly keep record of the same.

We look forward to your feedback, and active participation in our endeavour for AMTOI SRO.

Warm regards,

Shantanu Bhadkamkar
President, AMTOI
De Minimis Provisions for AMTOI SRO Institutionalising Sector Standards 04062026
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De Minimis Provisions for AMTOI SRO Institutionalising Sector Standards 04062026.pdf

R. K. Rubin

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Jun 4, 2026, 11:55:34 AM (3 days ago) Jun 4
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Sorry, I could not participate in the meeting today. 

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On 4 Jun 2026, at 7:41 PM, 'Shantanu Bhadkamkar (via Google Docs)' via AMTOI <am...@googlegroups.com> wrote:


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Shantanu Bhadkamkar

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Jun 5, 2026, 4:51:05 AM (2 days ago) Jun 5
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Dear Rubin,

We missed your participation.

All the same, please read and be thorough with AMTOI Legal position and AMTOI justification. For DG Shipping, as they say in Hindi, it will be "dono haath mein laddoo", it will be under their oversight but we will do all the investments, supervision and monitoring. 

Shantanu Bhadkamkar

President - AMTOI

Shantanu Bhadkamkar

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Jun 5, 2026, 4:52:12 AM (2 days ago) Jun 5
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We must maintain consistent position in all the forums

Shantanu Bhadkamkar

President - AMTOI

R. K. Rubin

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Jun 6, 2026, 12:57:29 AM (yesterday) Jun 6
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I am fully in agreement with you. 

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On 5 Jun 2026, at 2:22 PM, Shantanu Bhadkamkar <pres...@amtoi.org> wrote:


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