Effective fund managers’ licence solutions, covering the entire fund managers’ licensing process management. This includes pre-licensing preparation and assurance, fund managers’ licence application handling, regulator liaison, successful licensing issues remediation and resolution, and a range of post-licensing solutions to support risk and compliance management under the fund managers’ licensing regime and regulated fund managers’ obligations under other laws and regulationsWe offer a comprehensive set of solutions to help you obtain and maintain a fund manager's licence, tailored to:

  • Your business goals and objectives
  • Your client demographics
  • Your countries of operation
  • The size of your business
  • The available human and technology resources
  • Your risk appetite
  • Your governance structure
  • The products that you offer
  • regulated fund managers' obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our financial licensing solutions to help you navigate the complexities of the fund fund managers' licensing regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the fund managers' licensing process, including but not limited to the following aspects:

  • Fund Managers' Licence Guidance: Advising on a wide range of aspects associated with fund managers' licence as it relates to your specific situation
  • Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
  • Pre-licensing support:
  • Drafting the necessary policies and procedures to help you comply with the fund managers' licence conditions and financial markets' regulations
  • Developing internal controls to help you meet your obligations under the fund managers' licensing regime
  • Fund Managers' Licence Application Support: Covering the entire licensing process
  • Post-licensing Support: Covering
  • Ongoing compliance advice
  • Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
  • AML/CFT advice
  • AML/CFT compliance management
  • Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

Jurisdictional Coverage of Our Fund Managers’ Licence Solutions

We can help you apply for the fund managers' licence or its equivalent in the following jurisdictions:

  • United States: We support U.S.-based fund managers' licensing and registration options. Fund managers in the U.S. who manage pooled investment vehicles, such as mutual funds, ETFS, hedge funds, or private equity funds, are generally required to register as investment advisers under the Investment Advisers Act of 1940. Where applicable, they may also be subject to compliance obligations under the Investment Company Act of 1940 or exempt reporting requirements. We assist with SEC investment adviser registration, private fund compliance, and disclosure obligations for both domestic and cross-border fund offerings.
  • New Zealand:
  • Prominent Financial Centres and Offshore Tax Havens: We also offer fund management licensing solutions for prominent financial centres and offshore tax havens, including:
  • MiFID II Authorisation in the European Union
  • Securities Business Licence in the Cayman Islands
  • Securities Licence in the British Virgin Islands (BVI)
  • Securities Licence in Seychelles
  • Fund Services Business (FSB) Licence in Jersey
  • Guernsey Financial Services Commission (GFSC) Licence
  • Man Financial Services Authority (IOMFSA) Licence
  • Securities and Futures Commission (SFC) Licence in Hong Kong
  • Monetary Authority (BMA) Licence in Bermuda
  • Financial Services Commission (FSC) Licence in Mauritius

 

Non-Retail Fund Managers’ Licensing and Registration

Our solutions extend across major financial markets and support fund managers who provide services to non-retail clients, including professional investors, institutional clients, and high-net-worth individuals.

  • Australia: Fund managers providing services to wholesale clients may require an Australian Financial Services Licence (AFSL) under the Corporations Act 2001, supervised by the Australian Securities and Investments Commission (ASIC). Registration with AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 applies only if the firm provides designated services.
  • United States: Fund managers providing services to institutional clients and high-net-worth individuals may be required to register as broker-dealers under the Securities Exchange Act of 1934, supervised by the Securities and Exchange Commission (SEC) and regulated by the Financial Industry Regulatory Authority (FINRA). Fund managers engaging in discretionary asset management for institutional or high-net-worth clients may also be subject to obligations under the Investment Company Act of 1940 if managing pooled investment vehicles. Fund managers operating as trust companies or private banks may be subject to state banking laws or federal oversight by the Office of the Comptroller of the Currency (OCC), depending on their structure and activities.
  • United Kingdom: Fund managers offering services to professional clients and eligible counterparties must obtain authorisation under the Financial Services and Markets Act 2000 (FSMA), supervised by the Financial Conduct Authority (FCA). Prudential and conduct requirements vary depending on firm classification under the Investment Firms Prudential Regime (IFPR).
  • Singapore: Fund managers providing services to accredited investors and institutional clients may require a Capital Markets Services Licence under the Securities and Futures Act, supervised by the Monetary Authority of Singapore (MAS). Exemptions apply in certain cases, depending on the firm's activities and client classification.
  • New Zealand: Fund managers providing services to wholesale clients may be required to register on the Financial Service Providers Register (FSPR) under the Financial Service Providers (Registration and Dispute Resolution) Act. AML/CFT obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 apply if the firm is a reporting entity.
  • European Union: Fund managers providing services to professional clients and eligible counterparties must comply with licensing requirements under the Markets in Financial Instruments Directive (MiFID II), with authorisation issued by national regulators. Conduct and prudential obligations vary based on the firm's classification.
  • Offshore Jurisdictions:
  • Cayman Islands: Fund managers providing services to institutional clients and high-net-worth individuals may require licensing under the Securities Investment Business Act (SIBA), supervised by the Cayman Islands Monetary Authority (CIMA).
  • Bermuda: Fund managers serving institutional clients and high-net-worth individuals may require licensing under the Investment Business Act, supervised by the Bermuda Monetary Authority (BMA).
  • British Virgin Islands (BVI): Fund managers providing services to institutional clients and high-net-worth individuals may require licensing under the Securities and Investment Business Act (SIBA), supervised by the British Virgin Islands Financial Services Commission (BVI FSC).
  • Isle of Man: Fund managers providing services to institutional clients and high-net-worth individuals may require licensing under the Financial Services Act 2008, supervised by the Isle of Man Financial Services Authority (IOMFSA).

 

Service Coverage

We offer comprehensive support for a wide range of fund managers' licence applications tailored to meet the specific needs of the following businesses:

  • Private Fund Managers
  • Wholesale Fund Managers
  • Retail Fund Managers 
  • Institutional Fund Managers 
  • Boutique Fund Managers 
  • Family Offices
  • Robo-Advisors
  • Cross-Border Investment and Tax Planning Advisors
  • ESG-Focused Fund Managers

You can find more information about our fund managers' licence solutions below:

 

Fund Managers’ Licensing Preparation

Comprehensive set of pre-licensing solutions to support fund managers’ licensing process preparation, helping you meet fund managers’ licensing regime requirements and demonstrate compliance with regulated fund managers’ obligations. Our solutions cover fund managers’ licence guidance, compliance framework and internal controls development, pre-application compliance assurance, and fund managers’ licence application pack completion and review.Pre-licensing Compliance Assurance

Our fund managers' licence solutions cover the following focus areas:

  • Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for a fund manager's licence
  • Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the fund managers' licensing process
  • Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your fund managers' licence, tailored to suit your:
  • business objectives,
  • operational capacity,
  • client base,
  • markets of operations,
  • and other relevant factors
  • Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
  • Fund Managers' Licence Application Plan: We help you establish a roadmap to effectively meet the fund managers' licence requirements

 

Fund Managers’ Licence Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our fund managers' licensing solution covers:

  • Compliance Model Selection: To help you best comply with the fund managers' licensing regime and related risk and compliance obligations.
  • Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
  • Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the licensing requirements for fund managers and other applicable regulated fund managers' obligations, keeping in mind your specific circumstances, available resources and business goals.

 

Entering Fund Managers’ Licensing Environment

We help businesses transition from an unregulated environment to operating under the fund managers' licensing regime, helping them meet their obligations as a fund manager's licence holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the fund managers' licensing regime requirements.

Our focus areas for this service include:

  • New businesses
  • Existing fund managers operating in unregulated markets
  • Regulated fund management expanding into foreign jurisdictions
  • Financial institutions and/or service providers with established risk and compliance frameworks seeking to introduce regulated fund management services as a new product.

 

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with regulated fund managers' obligations globally.

 

Fund Managers’ Licence and Wholesale Markets

Getting a fund manager's licence may not always be the best fit for all. For example, a retail market expansion may not always align with your goals or the products you offer.

Operating in the wholesale environment can sometimes be a more suitable option. We offer a wider range of risk and compliance management solutions to assist fund managers that:

  • Operate in the wholesale markets
  • Operate under exemptions from the fund managers' licensing regime
  • Offer services to sophisticated, eligible, and wholesale investors

 

We help them comply with the regulatory compliance obligations that are not caught by the fund managers' licensing regime, but that still have to be addressed and handled, including:

  • Advertisement Rules
  • Fair Dealing Regulations
  • Risk Management
  • Outsourced Providers' Oversight
  • Restrictions on offering services to retail investors without a licence (an integral part of the fund managers' licensing regime)
  • Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) laws and regulations
  • Data Management Laws and Regulations

 

For example, a retail market expansion may not always align with your goals or the products you offer.

Operating in the wholesale environment can sometimes be a more suitable option. We offer a wider range of risk and compliance management solutions to assist fund managers that:

  • Operate in the wholesale markets
  • Operate under exemptions from the fund managers' licensing regime
  • Operate under a fund manager's licence, limited to sophisticated, eligible, and wholesale investors

 

We help these businesses comply with the regulatory compliance obligations that still apply despite the absence of the fund managers' licensing regime or apply under the wholesale-only licensing framework, including:

  • Advertisement Rules
  • Fair Dealing Regulations
  • Risk Management
  • Outsourced Providers' Oversight
  • Restrictions on offering services to retail investors (an integral part of the fund managers' licensing regime)
  • Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) laws and regulations
  • Data Management Laws and Regulations

 

Fund Managers’ Licence Application

Comprehensive fund managers’ licence application management, including document compilation, pre-submission review, application management, and regulatory liaison to help you efficiently navigate the fund managers’ licensing process, meet fund managers’ licence criteria, comply with fund managers’ licensing regime requirements, and manage regulated fund managers’ obligations effectively.We assist with your licence application through ongoing engagement in the fund managers' licensing process:

  • Document Compilation and Review: We compile and review all required supporting documents to support your fund managers' licence application.
  • Application Form Completion: We help you complete the forms so that all material information is accurate and complete.
  • Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
  • Fund Managers' Licensing Process and Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the licensing process.
  • Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving Fund Managers’ Licence Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our fund managers' licence solutions include a range of services to address and resolve these issues effectively:

  • Remediation Solutions for Fund Managers' Licence Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with fund managers' licensing regime requirements.
  • Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your fund managers' licence, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.
  • Licensing Issues Handling: We address common licensing issues encountered during the fund managers' licensing process, providing you with solutions to navigate and resolve these challenges efficiently.
  • Further Information: You can visit our Compliance Remediation Solutions page for more information.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for licensed fund managers. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

  • Regulated Fund Managers' Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the fund managers' licensing regime and other regulatory compliance obligations. You can visit our Compliance Consultancy Service page for more information.
  • Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our Specialised Compliance Management Solutions page for Fund Managers.
  • Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
  • Compliance Training Solutions: We offer training programs to different teams on complying with:
  • Regulated Fund Managers' obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
  • Fund managers' AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.
  • Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
  • Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for fund managers. For more information, visit our Specialised AML/CFT Solutions page for Wealth Managers.
  • Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.

 

 

Risk and Compliance Obligations for Fund Managers’ Licence Holders

A set of post-licensing risk and compliance solutions for the fund managers’ licensing regime and related regulated fund managers’ obligations, tailored to your commercial objectives, products, resources, size and specific goals. Comprehensive fund managers’ licensing guidance that covers ongoing compliance, licence renewal, remediation process management, and other fund managers’ licensing issues to help you successfully maintain your fund managers’ licence.Fund management licence holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support in different areas. The list below is not exhaustive:

Fund Managers’ Licence and Regulatory Compliance Obligations

  • Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more.
  • Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil regulated fund managers' obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks.
  • Policy and Procedure Development: We can assist you in drafting and implementing policies and procedures that align with the fund management licensing requirements.
  • Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the fund managers' licensing regime.
  • Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
  • Capital Adequacy Requirements: We can help you implement controls to comply with capital adequacy requirements, helping your businesses meet regulated fund managers' obligations for maintaining required financial resources.
  • Liquidity Management Requirements: We can help you develop controls to meet liquidity management requirements.
  • Financial Auditing Standards: We can assist in establishing procedures to help you comply with the audit and assurance requirements under the fund managers' licensing regime.
  • Digital Payment Token Services: We can assist in developing controls to comply with regulations for digital payment tokens, cryptocurrencies, and digital assets, including obligations under the fund managers' licensing regime and AML/CFT requirements for transaction monitoring and reporting.

 

Fund Managers’ Licence and Operational Oversight Obligations

  • Oversight of Outsourcing: We can establish a set of effective controls to comply with fund managers' licensing obligations for overseeing outsourced services, also covering related obligations under AML/CFT compliance, ISO requirements, and more.
  • Structures for Governance: We can help you establish effective governance structures to comply with regulated fund managers' obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
  • Senior Management Accountability: We can help you comply with regulated fund managers' obligations for senior management and key staff conduct and competence.
  • Maintaining Operational Resilience: We assist in developing continuity plans to meet regulated fund managers' obligations for operational resilience, helping critical business services withstand disruptions.
  • Managing Technology Risks: We provide guidance on technology risk management obligations under the fund managers' licensing regime.

 

Fund Managers’ Licence and Market Integrity/Transparency Requirements

  • Standards for Market Conduct: We can help you implement controls for regulated fund managers' obligations to maintain fair and transparent market conduct, including preventing manipulation and insider trading.
  • Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients.
  • Standards for Conduct and Disclosure: We can help you comply with fund managers' licensing standards for conduct and disclosure.
  • Product Suitability and Governance: We can establish tailored controls to help regulated fund managers' obligations comply with product suitability and governance obligations, including risk management and governance arrangements across the product life cycle.
  • Protection of Client Assets: We can help you comply with fund managers' licensing obligations to protect and segregate client assets.
  • Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients.

 

Fund Managers’ Licence and Resource Management Obligations

We can help you comply with the following requirements of the fund managers' licensing regime:

  • Adequacy of Resources: Covering financial, technological, human and other resources.
  • Competence of Professionals: Covering key personnel, their necessary skills, knowledge, and professional competence.
  • Our focus areas include:
  • Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the licensing regime.
  • Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
  • Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
  • Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
  • Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, and compliance regulations.
  • Competence and Accreditations of Advisors and Representatives: We can advise you on certifications and continuing professional development (CPD) requirements for compliance professionals and senior management.
  • Representative Vetting: We can help establish a framework for assessing the competence and suitability of advisors and representatives before appointment.
  • Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
  • Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.
  • Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.

 

Fund Managers’ Licence and Reporting

  • Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
    • Fund Managers' licensing obligations
    • Fund Managers' AML/CFT obligations (SMRs, STRs, SARs, cross-border transaction reports, cash transaction reports, and other reporting obligations)
    • Regulated fund managers' obligations under financial market conduct regulations
  • Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
  • Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the fund managers' licensing regime, applicable operational standards, and more.

 

 

Hot Topics for the Fund Managers’ Licensing Process

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