By James Lasry, Vice Chairman of GFIA and President of the Gibraltar American Chamber of Commerce

The advent of the Alternative Investment Fund Managers Directive (AIFMD or the Directive) has dramatically changed the scope of services that European finance centres, such as Gibraltar can offer non EU managers (such as US, Swiss and Asian managers).

In the past non EU managers would market funds to European investors via the private placement regimes as it was almost impossible to get these funds authorised in the various European jurisdictions. The AIFMD has caused a significant tightening of many of the private placement regimes in Europe. In fact, under the Directive, they are to be phased out by 2018. Therefore, for non EU managers to market their funds in the EU, they must rely on what remains of the private placement regimes or on a concept known as ‘reverse solicitation’.

The safest way for non EU managers to market into the EU is for them to set up a European fund that can be passported into other EU jurisdictions. Depending on the strategy this will be either a Ucits fund or an AIFM fund. In either case it can be legitimately promoted to the appropriate European investors.

It stands to reason that in their search for European vehicles for their funds, non EU managers, particularly those in the US, should look to the jurisdiction which is closest legally, and in regulatory approach to what they are used to in the Cayman Islands. Gibraltar being a common law jurisdiction with the UK Privy Council as the ultimate Court of Appeal and with English as its primary language, is likely to cause less of a culture shock for US managers who have decided to use a European vehicle. Furthermore, Gibraltar is the only European jurisdiction that allows for the pre-authorisation launch of a fund, as Cayman does.

Permissible distinctions – Gibraltar’s advantage

The national private placement regimes, which under the Directive are to be phased out by 2018, have already begun to be tightened by some of the member states. In Germany, for example, a market which is not insignificant, it is nearly impossible for a non-European fund to use their private placement regime. A European fund on the other hand can use Germany’s private placement regime even if it is out of scope of the Directive simply because of the fact it is domiciled in the EU. For this and other reasons, we are seeing US managers setting up parallel or master AIFs (as opposed to feeder) in Gibraltar and other EU jurisdictions in order to assist with their European marketing efforts.

The Gibraltar approach to these issues, following an in-depth consultation involving a collaboration of government, the Financial Services Commission (FSC), and the Gibraltar Funds and Investments Association (GFIA), the representative body of Gibraltar’s funds and investment industries, retains as much flexibility as possible as is offered by the Directive. Accordingly Gibraltar has kept its Experienced Investor Funds (EIF) regime for those funds and managers that are out of scope of the Directive while allowing those that wish to, in order to avail themselves of the EU wide marketing passport, to opt in to the AIFM regime even if they are below the de minimis thresholds. Obviously those that opt in will have to abide by all the terms of the AIFM regime as if they had been in scope.

The streamlined authorisation process for EIFs should not be mistaken as light regulation. The authorisation process may be quicker due to the fact that EIFs require two directors on each board that are resident in Gibraltar and which are authorised by the FSC to act as fund directors. Furthermore, the documentation must be signed off, both by senior Gibraltar Counsel and by the fund administrator. Once the fund is authorised, the FSC has a plethora of investigatory and enforcement powers.

Gibraltar is fast developing into an international funds jurisdiction focussed both on small managers and managers which wish to market within Europe. Gibraltar held its first international funds conference in April which attracted participants from EFAMA, BaFin, AIMA, GSX, Goldman Sacs, Citibank, Society Generale Newedge, BNP Paribas, Laven Partners, Schulte Roth & Zabel, Kaye Scholer and Norton Rose. The Gibraltar Funds and Investments association under the leadership of Joey Garcia is working hard along with the Government of Gibraltar and the FSC to raise Gibraltar’s profile from being one of Europe’s best kept secrets to a jurisdiction which people recognise as a sound, safe and business friendly place from which to do business.

Ultimately, the Alternative Investment Fund Managers Directive has provided European jurisdictions and particularly Gibraltar with an opportunity to genuinely add value to non EU managers in the marketing of their funds to the EU – a market of 520 million people.

The post Gibraltar: the Key to Europe appeared first on Gibraltar International Magazine.

The transitional period for the Alternative Investment Fund Managers Directive (AIFMD) expired on 22 July 2014 and accordingly the non-UCITS funds industry in Europe is now governed by AIFMD.

Gibraltar, as a member of the European Union (EU) is well placed to take advantage of the opportunities afforded by AIFMD. In particular, it will now be possible to market larger Gibraltar funds (that are in-scope of AIFMD) throughout the entire EU, on the basis of a single filing with the Financial Services Commission (FSC) in Gibraltar. It represents no less than a marketing revolution for alternative investment funds in the European market.

Naturally attention has focussed on the position of larger funds that are in-scope of AIFMD as the directive necessitates significant changes to their structure and operation. However a great number of fund managers and self-managed funds fall below the threshold levels for applicability, and so fall outside the main provisions of AIFMD altogether. A small fund manager (commonly called a “Small AIFM”) is not that small. A fund manager is a Small AIFM if it has assets under management of less than €100 million, or €500 million if the funds managed are closed ended and unleveraged.

Small AIFMs do not have the benefit of EU passporting rights, so marketing into other EU jurisdictions is subject to the private placement rules of the countries where they wish to market, no matter where the fund manager or its fund may be located. These are generally complex. For some EU jurisdictions however this is about to change. Germany, for example, has indicated that Small AIFMs located in an EU jurisdiction that allows German Small AIFMs to privately place there, will give that jurisdiction reciprocal rights to market their funds privately in Germany. This type of private placement will operate separately from the normal private placement rules applicable in Germany that are complex and restrictive.

A significant competitive advantage

In practice this puts Gibraltar at a significant competitive advantage, as few EU countries have private placement regimes sufficiently open to gain the benefit of these reciprocal rights. Gibraltar however is in the process of introducing a private placement regime which should be sufficiently open to enable Gibraltar funds to gain reciprocal marketing rights of this nature. Such access should be possible on a simplified filing basis.

Gibraltar’s new private placement regime for Small AIFMs will work by means of filings with the FSC. In essence, Small AIFMs based in an EU jurisdiction will be able to privately place in Gibraltar following such a filing accompanied by some basic information. Small AIFMs based in a non-EU jurisdiction will also need to make such a filing, but will not be able to market until receiving authorisation to do so.

Increasingly attractive

It is apparent that Gibraltar is becoming increasingly attractive to foreign fund managers from all over the world looking for an EU jurisdiction to locate their funds. Its advantages are already well known. Its Experienced Investor Fund (the Gibraltar category of fund for high net worth individuals and institutional investors) is widely acknowledged internationally as the quickest to establish and launch to market within the EU (it can take as little as a couple of days), the jurisdiction is genuinely open to non-local managers and non-local administrators, its laws are based on English common law and so are familiar to international business, and the jurisdiction is effectively tax neutral.

AIFMD adds to this attraction by allowing an AIFMD in-scope fund manager to passport its services throughout the EU. As significant as this is, Small AIFMs may see even greater benefit in setting up their funds in Gibraltar, as their exclusion from the EU-wide passporting rights places greater emphasis on their private placement opportunities. Smaller funds and their managers will find they can not only establish themselves in Gibraltar economically and quickly, but should also be able to take advantage of the reciprocal private placement regime which Germany is introducing and which other EU jurisdictions may well in due course follow.

A good solution

What does this mean for European fund managers in practice. In practical terms, Gibraltar is a good solution for fund mangers large or small. Larger fund managers may take advantage of the EU-wide passporting rights now available under AIFMD. Start-up fund managers looking for an optimal location, and existing smaller fund managers which may already have established funds in differing jurisdictions and are looking for the best location for a new fund, may well find the answer in Gibraltar, where funds can be established quickly and economically and have the benefit of reciprocal private placement rights that some EU jurisdictions are introducing.

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One year ago, on 22 July 2013, the Alternative Investment Fund Managers Directive (AIFMD and/or the “Directive”) became EU law. AIFMD introduced harmonised requirements for entities involved in the management of alternative investment funds (AIFs) that are managed and/or marketed to professional investors in the EU.

In terms of scope, AIFMD encompasses all EU AIFs and their managers (AIFMs) as well as all non-EU AIFMs that market to investors in the EU. AIFMD is wide reaching covering all possible strategies and legal forms and, as such, encompasses conventional “trading” funds (trading equity, options, derivatives and such like) to alternative assets classes such as real estate and private equity.

The impact of AIFMD on most existing AIFMs was deferred by a one year transitional period which ended on 22 July 2014 after which AIFs managed and/or marketed in the EU must be compliant with the Directive, unless a relevant exemption applies.

It is estimated that there are more than 1,200 firms caught by the Directive across Europe, with the largest number of firms based in the UK. The UK regulator, the Financial Conduct Authority (FCA) expects to receive in the region of 800 applications for AIFM authorisation. The actual number of AIFMD approvals across Europe has been low by comparison. Up until recently, less than 500 firms had been authorised in the UK, Ireland, Luxembourg, France, Germany and other jurisdictions throughout the EU. Despite the requirement to do so it is believed a large number of AIFMs have not yet submitted an application to their regulator. It now seems inevitable that a large number of managers will not be authorised by 22 July 2014 and, whilst not required by the Directive, it remains to be seen whether there are unintended consequences for managers that are not authorised.

What should you do if you are an AIFM that is not authorised

The Directive requires that where an AIFM is unable to ensure compliance with the requirements of AIFMD it shall immediately inform the competent authorities in its home Member State and, if applicable, the competent authorities in the host Member State of the AIF concerned. The competent authorities of the home Member State of the AIFM shall require the AIFM to take the necessary steps to remedy the situation.

If non-compliance persists, and in so far as it concerns an EU AIFM or an EU AIF, the competent authorities of the home Member State shall require that it resigns as AIFM of that AIF. In that case the AIF shall no longer be marketed in the EU. If it concerns a non-EU AIFM managing a non-EU AIF, the AIF shall no longer be marketed in the EU.

If you are an AIFM and you are not yet authorised you should carefully consider your options of which there are principally two; (a) seek an exemption from the scope of AIFMD, or (b) become compliant.

Exemptions from the scope of AIFMD

There are several exemptions to the scope of the AIFMD, the main of which being the de minimus test of an AIFM with aggregate total assets of (a) less than €100 million (including leverage); or (b) less than €500 million (unleveraged) and that does not have redemption rights during a period of five years following the date of initial investment in the AIF. Such AIFMs are referred to as “Small AIFMs”.

Become compliant

AIFMs operating under existing licenses should seek authorisation for a variation of permission from their regulator. Organisations acting as AIFMs, that have not previously been authorised, should submit an application for authorisation to their regulator. In terms of authorisation, AIFMD sets out rules that include but are not limited to conduct, capitalisation and insurance requirements. AIFMs are required to undertake portfolio management and risk management functions (one of which can be delegated under certain circumstances). As with all EU directives, there is a certain amount of complexity and legality to be observed.

The Gibraltar solution

Gibraltar is fully compliant in respect of EU investment business and fund legislation. The Gibraltar regulator, the Financial Services Commission (FSC) and the fund’s industry have been gearing up for AIFMD for years.

Gibraltar based investment firms that comply with AIFMD have access to an EU-wide marketing passport that permits promotion and marketing across the EU. This provides Gibraltar AIFMs access to a market of in excess of 500 million people.

Gibraltar also has the fastest AIFMD fund product to market with its experienced investor fund (EIF) regime whereby an AIFM can start marketing an EIF from the launch so long as within 10 business days it submits all relevant documentation to the FSC. The EIF is extremely flexible with no restrictions on asset type, diversification, investment nor borrowing. With unrivalled speed to market and flexibility, the EIF is one of the most popular fund vehicles in the EU.

Although AIFMD implementation requirements are similar across the EU, it is expected that the cost of implementation may vary from one EU jurisdiction to another. Running costs are low for Gibraltar AIFMs compared to operations based in other EU jurisdictions which are already seeing costs increase as a result of AIFMD implementation.

In addition to this, Gibraltar is also soon to launch a Small AIFM regime which will bridge the regulatory gap between Small AIFMs and fully in scope AIFMs. Gibraltar’s Small AIFM regime will provide a platform for managers to enter into the EU regulatory environment without the burden of the full AIFMD scope requirements. The Small AIFM regime will provide further depth and support to an already strong Gibraltar AIFMD offering.

One year on, Gibraltar has the legislation, rules, regulations and products in place in order to meet the requirements of AIFMD. If you are the one of many AIFMs that are struggling with AIFMD implementation look no further than Gibraltar.

The post AIFMD – One Year On appeared first on Gibraltar International Magazine.

The Alternative Investment Fund Managers Directive (AIFMD) introduced last year, but which came fully into force mid-July, is set to bolster EU fund jurisdictions such as Gibraltar, that are able to offer foreign fund managers access to the whole of Europe.

The EU-wide AIFMD provides for monitoring and supervision of risks posed by alternative investment funds, including hedge funds, private equity funds, and real estate funds.

“In this new environment, with significant opportunities available to professional, focused jurisdictions, Gibraltar has positioned itself to maximise business opportunities under AIFMD”, pointed out James Lasry, Gibraltar Funds & Investment Association (GFIA) now-retired chairman.

For funds being established now, “or funds that wish to continue to market in the EU – particularly those wishing to market in Germany, France, Italy and the Netherlands, where the private placement regimes have been substantially restricted – they will have to consider a European onshore option and, depending on size, AIFM-compliant
structures,” said Jon Tricker, Partner at Deloitte (Gibraltar).

Moves by Gibraltar lawyers, accountants and other financial intermediaries to attract funds business have been in place for the past few years, but the number registered as Experienced Investor Funds (EIFs) remains doggedly below 100 – small beer by comparison with other main competing centres such as Malta, Ireland and, particularly, Luxembourg.

As Joey Garcia, acknowledged fund expert at law firm Isolas, explains, that the near-static number does not signify inactivity. “Some funds have been completed or been unable to reach investment targets, whilst other funds have been launched in their place”, he said. A couple of funds have recently relocated to Cayman Islands, to avoid AIFMD reporting requirements for funds with over £100m assets.

“But I agree the full potential growth has not yet been realised; the AIFMD is a positive event for us going forward,” Garcia remarked. He and Lasry point to government investment – “time, effort and resources”- in funds promotion at an expanded and renamed government-funded Gibraltar Finance.

The boost in jurisdiction visibility at global funds events in Paris, Hong Kong, Geneva, Monaco and London this year, contrasts sharply with a previous relatively low-key international presence, and begins to match the efforts made by Guernsey and Malta, for example.

Philip Canessa, Gibraltar Finance Centre funds marketing specialist believes the territory is “in an excellent position” to experience growth, after its dedication to implementation and preparation of regulations like AIFMD.

To make The Rock more funds friendly, the government in 2012 cut by half, requirements for individuals to qualify for investment in EIFs. Last year Gibraltar altered legislation permitting large funds to register locally, but still use their preferred administrators in other well-regulated jurisdictions and earlier this year made changes to the Companies Act to assist administrators reporting changes in shareholder / investor ownership.

In early May, 27 fund managers new to Gibraltar attended a London briefing by lawyers, Hassans and accountants, Deloitte (Gibraltar), as part of a series of joint promotional events in addition to those with the Finance Centre. The fund managers had been identified as likely soon to structure new fund offerings; within days two planned to find out more.

Fast to market

However, Hassans funds specialist partner Lasry, revealed: “It’s a struggle to get the attention of fund advisors, because they keenly support Cayman Islands that they know well, unlike fund managers, who are much more open to Gibraltar possibilities.

“I think we have the most competitive offering for AIFMs in Europe, if they had to find a European jurisdiction in which to put funds instead of Cayman Islands. Those based in London we hope will consider Gibraltar because it is close – culturally, legally and regulatory – to that in Cayman, and in addition, we offer the quickest to market in Europe,” Lasry asserted.

Feedback from Invest’tour Gibraltar, a first-of-kind 2-day seminar attended by 48 Swiss wealth management investors in April revealed “attendees were especially impressed by the mood that prevails in the territory – very much business oriented and solutions driven”, according to organiser Voxia Communications senior partner, Alexandre Bonnard.

Few attendees had previous knowledge and experience of the territory, showing “that more could be done in terms of dedicated communication towards the Swiss financial intermediaries and independent advisors and asset managers”, Bonnard told Gibraltar International. A follow-up event is planned for later this year.

Swiss move symbolic

Garcia revealed: “At least two serious Swiss enquiries concerning establishment of investment management firms have been received” with high expectation they will shortly progress. “It won’t be a huge change to our market, but it is symbolic of Swiss firms seeking to become regulated for marketing in Europe,” he explained.

There are ten Gibraltar licensed fund administrators with some £3.7bn of assets in around 218 local and foreign funds, but with sub funds – separate cells with the impact of each protected from each other – the number rises to around 250 funds.

Gibraltar Finance Centre in April joined Europe’s industry elite at EuroHedge Summit in Paris which “was very good, because of the seriousness of the managers represented – top Euro managers – which some might argue are too big for Gibraltar, but we were surprised at how many delegates showed interest in our offer”, Lasry reported.

“They may not have wanted Gibraltar for a fund now, but they may well find us suitable in the future. Rather than looking to Luxembourg, they will get from Gibraltar both a lot better service and access to the Regulator for speed of processing applications, as well as a cost advantage.”

Nicola Smith, CEO of Helvetic Fund Administration Ltd, which manages 80 funds in the Cayman and British Virgin Islands, as well as Gibraltar. The company became the first licensed Gibraltar funds administrator in 1998, and holds a similar position in Malta.

Smith notes that whilst Ireland and Luxembourg offer similar tax advantages to Gibraltar, those jurisdictions lose on the grounds of difficulty in getting funds established.

“Dublin is saturated with funds and the process of launching a fund with regulatory approval there can take up to a year and in Luxembourg it can be even more problematic, because of the cost – both jurisdictions are way more expensive – and, basically, they seem to be interested only in very large funds”, she said. “Malta offers an underlying structure for funds similar to Gibraltar’s EIF, but it can take six months to get regulatory approval.”

Ray Spencer

Surprise review of key fast-to-market process

Gibraltar’s Financial Services Commission (FSC) chief executive, Samantha Barrass is looking again at the key Experience Investor Fund (EIF) process that allows funds to be pre-authorised by industry professionals.

The EIF regime means funds can be launched within just ten days of its application submission unless the FSC spots something amiss, enabling the jurisdiction to market itself strongly on an internationally competitive ‘fastest to market’ basis.

However, it’s a process the regulator regards as “very unusual”, because the prior approval is of licensed EIF Directors only – there are 90 listed as ‘active’ at present; the FSC registers the fund “after it is up and running”.

Gibraltar Minister for Financial Services, Albert Isola, emphasised: “I don’t think there is any chance that the pre-authorisation of funds process will be disturbed, but if we can improve on it, then that is only right.

“Do not be surprised by the approach being taken by Samantha Barrass; it is entirely within her scope to review the process – she has a duty to consider and to review the EIF process”, he told some 200 people attending the Gibraltar Funds & Investment Association (GFIA) 2nd annual dinner at end-May.

Nevertheless, retiring GFIA chairman James Lasry, admitted: “The new Regulator’s remarks have caused a bit of a stir, but they have been received by the industry positively. We regard our ability to launch funds without prior FSC authorisation as a privilege, not a right and we always flag up to the Regulator anything that is of an unusual or different nature.”

Around 10% of Gibraltar’s nearly 200 EIFs and EIF sub funds are believed now to be causing the FSC team some concerns, Gibraltar International understands. The regulator has been worked in recent months with EIF directors in funds considered ‘problematic’. “We are looking at new and existing funds and whether we have any concerns,” Mrs Barrass revealed.

As a result, she explained to the FSC industry-based funds panel in June how the regulator is looking to help EIF directors “raise the bar” with standards that build on a new GFIA ‘code of conduct’.

The ability to launch without any regulatory downtime is not a new concept – Luxembourg did it for seven years until 2012, and Caribbean jurisdictions still offer this facility.

Gibraltar funds need to register 10 days after establishment – having involved senior legal counsel, an authorised EIF director and, as appropriate, a regulated funds administrator – or if they want to register before they start conducting licensable activity, the FSC expects to turn an application around within 10 days assuming documentation and information is correct.

Mrs. Barrass told the 90+ industry professionals attending a concurrent GFIA corporate governance seminar: “We are having to do quite a lot of work to manage risks arising from [EIF] Directors not properly taking account of the inexperience in practice of investors, not fully being on top of the risks of fraud and not ensuring skill and competence more generally – particular with respect to investments in more esoteric markets and illiquid markets.”

Where those funds involve “investors who despite their ‘experienced’ status, in practice are heavily reliant on strong governance of the fund to ensure their interests are protected”, EIF directors need “to take their duties of fiduciary and due care, skill and diligence seriously”, she said given the EIF swift-to-market ability.

The FSC’s prime consideration, the regulator reminded, was consumer protection and Gibraltar’s financial services sector reputation. Mrs. Barrass noted that “unlike the larger jurisdictions, when the greater freedoms are abused and we see fraud – investors exposed to greater risk than anticipated – I think a disproportionate international spotlight is shone than when the same things happen in the larger jurisdictions”.

All concerned with the EIF process needed to ensure the regime was being used for its original intent and boards of directors and senior managers, either in the fund or service providers (such as administrators or investment managers), were “particularly important to the delivery of a sound risk culture, she emphasized. “It is critical that they are able to demonstrate adherence to sound risk management and integrity and competence in risk governance”.

Lasry believes: “The great majority of firms and individual involved with the funds sector are GFIA members, but worryingly of the 90 EIF licensed directors only 21 are members, which is of concern.”

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Since 2008 Gibraltar has been listed in the Global Financial Centres Index published by the City of London Corporation increasing its reputation as an attractive location for business in a variety of areas.

An obvious choice for funds and fund managers

Gibraltar offers a well-established fund regime based on UK legislation and is the only British overseas territory that is part of the European Union (EU) and applies European laws. Fund legislation in Gibraltar was drafted in close consultation with key members of the industry and has resulted in a comprehensible regime that most European based managers and compliance teams find easy to adhere to.

Investment manager licence

A fund manager may set up operations in Gibraltar as either a licensed MiFID (Markets in Financial Instruments Directive) EU investment manager, a licensed AIFM (Alternative Investment Fund Manager Directive) EU investment manager or a licensed UCITS (Undertaking for Collective Investment in Transferable Securities) compliant manager. Once obtained, the manager would be regulated by the FSC and have a fully transferable licence to passport the licensed services throughout the EU.

If a manager does not want to obtain a full AIFM licence but does want to continue to be able to market its services under a MiFID licence, then Gibraltar service providers can offer a platform solution whereby the portfolio management is outsourced to the MiFID manager by a fully and regulated AIFM manager established by the service provider for this purpose.

Service providers

Gibraltar has been servicing the finance sector for many years. There are numerous long established banks, law firms, tax advisers, insurance companies, custodians, auditors and fund administration companies which have a wealth of knowledge to offer to clients.

The focus of Gibraltar service providers has always been to offer a personal tailor-made service to each client. As a smaller jurisdiction, the service providers are more flexible and value each client and their requirements as unique, striving to provide a service which in a larger jurisdiction would simply not be available.

Where in the world

Gibraltar is one of only four EU based jurisdictions where a fund can be domiciled in a tax efficient way. Historically, people have established funds in Dublin and Luxembourg as an onshore location due to their advantageous tax regimes, however in recent years, a saturation of funds on the market and cost issues have paved the way for alternatives such as Gibraltar and Malta to offer investors additional options.

The client should be confident that the parties involved in the development of its fund will work together to ensure that any counterparties who go on to work together post-launch appreciate the needs of the fund’s manager, so tailoring their work accordingly. It is not the case that the set up of the fund is seen as a distinct and separate matter from the ongoing operation after launch.

Redomiciliation and relocation

As an increasing number of regulations are being introduced worldwide, the focus for managers and the funds they manage has moved towards ensuring their operations are domiciled and regulated in an EU location. Laws are already in place in Gibraltar to ensure the re-domiciliation process is as simple and efficient as possible for a streamlined process and Gibraltar based fund administrators can offer services to funds domiciled in another jurisdiction such as the Caribbean, to relocate to Gibraltar and ensure the smooth transition of the fund.

For EU fund managers it is very easy to deal with counterparties in and possibly even relocate their business to Gibraltar. With a similar legal structure to the UK, issues that can be found when dealing with offshore jurisdictions outside of the EU do not exist and Gibraltar offers a good geographical location. Gibraltar is very accessible with regular flights into Gibraltar from the UK and Malaga international airport is one hour’s drive away, which connects to the whole of Europe. Many people relocating to Gibraltar not only enjoy doing business in a regulated EU jurisdiction but also to relax in the attractive national park and beaches surrounding the Rock or on one of the numerous golf courses in the area at weekends.

There are no restrictions for EU citizens or Swiss nationals wishing to work in Gibraltar and there are very beneficial tax opportunities for highly skilled staff brought over to Gibraltar. Settling in Gibraltar can be an attractive proposition, not only from a lifestyle point of view, but also a financial perspective. More and more managers based in London and Switzerland are looking for a viable alternative jurisdiction and Gibraltar is becoming more recognised for offering this.

www.helveticfund.com

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