- S&P 500 7,659.44 −1.09%
- Dow Jones 52,002.41 −0.34%
- Nasdaq 26,713.03 +0.08%
- VIX 19.99 +21.45%
- 10-year Treasury 5.09% −0.01
- Dollar index 121.40 −0.14%
- WTI crude $101.91 +1.04%
New Silk Route: investment adviser
New Silk Route Advisors, L.P., doing business as New Silk Route, is an investment adviser registered with the SEC (file 801-74149, CRD 161339). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.
- Assets managed
- $531.5M
- Discretionary
- 100%
- Accounts
- 2
- Employees
- 5
- In advisory roles
- 3
- Disclosures
- 2
SEC adviser record · Full Form ADV (PDF)
The firm reports that it or a related person has custody of client cash and securities.
Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.
Clients and fees
Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.
| Client type | Clients | Assets | Share |
|---|---|---|---|
| Private funds and other pooled vehicles | 2 | $531.5M | 100.0% |
How it is paid
- A percentage of assets under your management
- Fixed fees (other than subscription fees)
- Performance-based fees
Services
- Portfolio management for pooled investment vehicles (other than investment companies)
Who owns it
Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.
Direct owners (Schedule A)
| Owner | Type | Role | Stake | Since | Control | Public company |
|---|---|---|---|---|---|---|
| Tagusi Holdings, LLC | Company (U.S.) | Limited partner | D 50% to 75% | Jan 2011 | ||
| Saxena Holdings LLC | Company (U.S.) | Limited partner | C 25% to 50% | Jan 2011 | Yes |
Indirect owners (Schedule B)
| Owner | Owns a stake in | Type | Stake | Control | Public company |
|---|---|---|---|---|---|
| Margaret Ann Riley | New Silk Route Partners, Ltd. | Person | F General partner, trustee or managing member | Yes | |
| Parag Saxena | Tagusi Holdings, LLC Member | Person | E 75% or more | Yes | |
| Parag Saxena | Saxena Holdings LLC Member | Person | E 75% or more | Yes | |
| Parag Saxena | New Silk Route and Partners, Ltd. Shareholder | Person | D 50% to 75% | Yes | |
| Tagusi Holdings, LLC | New Silk Route Partners, Ltd. | Company (U.S.) | C 25% to 50% | Yes |
Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.
Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.
Disciplinary history
What the firm disclosed under Item 11 of Form ADV. A disclosure is the firm's own report: pending matters are allegations, not findings, and many settlements are made without admitting or denying them. Text is quoted from the filing, set in sentence case.
Item 11 questions answered Yes
These questions cover the firm and its advisory affiliates.
- Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
- Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: entered an order against you or any advisory affiliate in connection with investment-related activity?
- Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
Actions about the firm (2)
- Jul 17, 2018Regulatory Action: SEC FinalSanctions: Cease and Desist; Civil money penalty, censure · Fine: $75,000 · Begun Jul 17, 2018 · Resolved Jul 17, 2018 · Settled · Docket FILE NO. 3-18599
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.
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.
- Dec 14, 2016Regulatory Action: SEC FinalSanctions: Cease and Desist; Civil money penalty, censure · Fine: $275,000 · Begun Dec 14, 2016 · Resolved Dec 14, 2016 · Settled · Docket FILE NO. 3-17722
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.
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.
Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.
The brochure
No brochure text was read for this firm.
Other brochures on file
- Form ADV Part 2A, Mar 26, 2026
Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.