hfm gibraltar2015

FEATURING GFIA // Gibraltar Finance // Gibraltar Stock Exchange // Grant Thornton // Hassans // Nexus Fund Administration

G I B R A L T A R 2 0 1 5WEEKHFM

S P E C I A L R E P O R T

COMPLIANT Fully compliant with AIFMD and friendly to non-EU managers

UNIQUE Offers full EU passporting but exempt from EU VAT

SPEED TO MARKETFastest fund vehicle in the EU

H F M W E E K . CO M 3

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ibraltar continues to provide a unique and attractive offering to funds and asset managers within the European context. We remain

completely EU compliant and onshore, with the full benefits of the European passport granted to Gibraltar-based investment firms and AIFM’s, while at the same time remaining outside of the EU for the purposes of VAT.

This is completely unique. The Gibraltar story continues to gather

momentum and in this year's Global Financial Centre’s Index (16th Edition) Gibraltar ranked higher than Cayman, Malta, the Isle of Man or Jersey as a financial centre.

There are a number of factors that continue to make Gibraltar unique, but as the implications of AIFMD are better understood, in particular by those managers from outside of the EU who are looking for gateway solutions, we expect the Gibraltar offering to be an attractive one.

Unlike many other smaller European countries or territories, Gibraltar already has a full suite of AIFM service providers, including (critically) AIFM depositaries. Align this with the AIFM management companies also offering their services from Gibraltar, and the fund regime fully geared up for AIFMD, and you have an excellent and alternative solution.

However, Gibraltar is not resting on its laurels. There are exciting new projects such as

Gibraltar’s new stock exchange, GSX Limited, which is primarily geared up for fund listings and offers both EU and non-EU funds the opportunity to take a European listing on the exchange. The Gibraltar Finance Centre continues to support the industry and the Gibraltar Funds and Investments Association (GFIA) with its activities in promoting the jurisdiction, both in London and further afield, and GFIA itself continues to actively promote the Gibraltar offering through its executive committee, and its members.

There is never a one-size-fits-all approach to any manager or fund, but GFIA certainly believes that there is a real value proposition for Gibraltar. If we are to see the private placement regimes across Europe expire in or around 2018, it is clear that managers will need to consider even more carefully their options for an AIFM compliant framework. The frameworks and solutions on offer in some European jurisdiction can be prohibitive, or very restrictive and while we would never propose Gibraltar as a ‘softer’ option in an AIFM context, the reality is that the same benefit of a European passport can be obtained within a Gibraltar framework that can be more flexible than some of the one-size options that exist elsewhere. Managers should be thinking about long-term planning for their businesses, and as an association, GFIA would encourage those managers to consider Gibraltar.

Joey Garciachairman, Gibraltar Funds & Investments Association

GG I B R A L T A R 2 0 1 5

Joey Garcia, chairman, Gibraltar Funds & Investments Association, for and on behalf of the GFIA Executive: James Lasry, Joanne Sene, Yan Delgado, Carlos Martins, Jon Tricker, Johann Olivera, Benjy Cuby, Moe Cohen.

I N T R O D U C T I O N

REPORT EDITOR Drew Nicol T: +44 (0) 20 7832 6659 [email protected] HFMWEEK HEAD OF CONTENT Paul McMillan T: +44 (0) 20 7832 6622 [email protected] HEAD OF PRODUCTION Claudia Honerjager SUB-EDITORS Eleanor Stanley, Luke Tuchscherer, Mary Cooch CEO Charlie Kerr GROUP COMMERCIAL MANAGER Lucy Churchill T: +44 (0) 20 7832 6615 [email protected] SENIOR PUBLISHING ACCOUNT MANAGER Tara Nolan +44 (0) 20 7832 6612, [email protected] PUBLISHING ACCOUNT MANAGERS Amy Reed T: +44 (0) 20 7832 6618 [email protected]; Jack Duddy T: +44 (0) 20 7832 6613 [email protected]; Alex Roper T: +44 (0) 20 7832 6594 [email protected] CONTENT SALES Tel: +44 (0) 20 7832 6511 [email protected] CIRCULATION MANAGER Fay Muddle T: +44 (0) 20 7832 6524 [email protected]

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4 H F M W E E K . CO M

G I B R A L T A R 2 0 1 5 C O N T E N T S

FINANCIAL SERVICES

STREAMLINING AHEADPhilip Canessa, senior finance centre executive at Gibraltar Finance, discusses Gibraltar’s achievements and plans for 2015 with HFMWeek

ACCOUNTING

GIBRALTAR: THE KEY TO EUROPE FOR US FUND MANAGERSJames Lasry, head of funds at Hassans, and president of the Gibraltar American Chamber of Commerce, speaks to HFMWeek about Gibraltar’s position as the gateway to Europe for US managers

ACCOUNTING

AIFMD – ONE YEAR ONAdrian Hogg, director of Grant Thornton Gibraltar, talks to HFMWeek to explain how AIFMD has been integrated into the business industry in Gibraltar

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17

FUND SERVICES

A ONE OF A KIND OPPORTUNITYMoe Cohen, CEO of Nexus Fund Administration, talks to HFMWeek about what makes Gibraltar unique as an EU-compliant jurisdiction

STOCK EXCHANGE

STOCK EXCHANGE LAUNCHES IN GIBRALTARNick Cowan, managing director, Marcus Wohlrab, marketing director, and Philip Young, finance director, of the Gibraltar Stock Exchange, talk to HFMWeek about the exchange’s recent launch

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In recent years, the fund industry in Gibraltar has seen rapid and impressive growth. Gibraltar is now a serious option for individuals and companies considering where to base investment funds.

Hassans has been at the forefront of this development and in 2004 became the first firm in Gibraltar to set up a funds practice, quickly establishing itself as the “go to” firm.

Hassans is ranked as the sole leader for Investment Funds by Legal 500 and EMEA

describe the department as a “Rolls-Royce investment funds practice...led by James Lasry, a leading investment funds lawyer with first-class knowledge of the local and wider market”. (EMEA 2014 Edition)

Hassans is fundamental to any fund being

set-up in Gibraltar whether Private, EIFs,

Non- UCITS Retail Funds, UCITS Funds or

Protected Cell Companies.

Hassans - 75 years in Gibraltar.

TAX PLANNING • CORPORATE & COMMERCIAL • FINANCIAL SERVICES • FUNDS • LITIGATION • PROPERTY • TRUSTS

International Lawyers

When it comes to funds...

...Hassans leads the way

www.gibraltarlaw.com 57/63 Line Wall Road, PO Box 199, Gibraltar. +350 200 79000 • +350 200 71966 • [email protected]


G I B R A L T A R 2 0 1 5

HFMWeek (HFM): How has Gibraltar developed as a jurisdiction in the last year?

Philip Canessa (PC): Th ere have been a number of developments this year, not least of which was the im-plementation of the AIFMD which is no small feat for a jurisdiction of our size. Our regulator the Financial Ser-vices Commission (FSC) did a lot of work on AIFMD, on understanding how it aff ects diff erent types of enti-ties, how to remain competitive and all at the same time meeting EU requirements. Th e FSC created a tailored approach on dealing with some important aspects such as delegation and remuneration and maintaining speed to market for our funds regime. Th is involved collabora-tion between the regulator, the fi nancial services indus-try and the government of Gibraltar.

Th e Gibraltar Stock Exchange (GSX) was recently granted authorisation by the FSC and has invited fi rms to apply for membership as ‘listing members’. It expects to be open for listings during the fi rst quarter of 2015. Th e aim will be to list funds and therefore promote investor awareness of the fi nancial standing and credibility of the issuer due to their obligations to meet the standards of the listing rules. Th is will enable greater transparency and due diligence on the funds listed. We are very excited about the new Gibraltar Stock Exchange.

We have continued to focus on a culture of compliance and in 2014 signed a Fatca intergovernmental agreement with the US. To date we have exchange of agreements to the OECD standard with 77 countries and territories; a small number of which are pending ratifi cation.

Gibraltar received a glowing review from the OECD on our record on exchange of information. Th e 115-page phase 2 review report found that we were ‘compliant’

(top grade) in seven out of the 10 essential elements ex-amined and ‘largely compliant’ (second highest grade) in the remaining three. Gibraltar’s overall rating was ‘largely compliant’; which is the same as the United Kingdom and Germany.

HFM: How is Gibraltar planning to remain a competi-tive domicile in Europe?

PC: We will continue to focus on the three criteria, which we consider give us an edge over our competitors. Th ese are: regulation, reputation and speed to market. HFM: What are the unique advantages of being domi-ciled in Gibraltar?

PC: Our Experienced Investor Fund (EIF) vehicle with its pre-launch approval regime, where an EIF can be launched in 10 working days, makes it the fastest ‘time to market’ fund vehicle in the EU.

Within the AIFMD, an authorised in-scope AIFM – which has already proven that it can meet requirements on risk management and has adequate controls in place – will be able to establish a new EIF and provide the requi-site EIF and AIFM notifi cation forms. Assuming that the requirements have been met, it would be registered as an EIF on the 10th day and passported to the relevant EU ju-risdiction on 20th.

In Gibraltar there is no wealth, capital gains, invest-ment income, value added or inheritance tax. Th ere is only personal income and corporation tax. Since 2010, the standard rate of corporate tax has been 10%. Th e ef-fective personal rate of tax is 25%, but if you are working in an industry such as fi nancial services and possess spe-cialist skills, as defi ned under certain regulations, and fulfi l certain conditions, then your personal level of taxation is capped at just below ₤30,000, assuming that you are earn-ing in excess of ₤120,000 p.a. Th at is also an att raction for investment managers and professionals to relocate toGibraltar.

HFM: What developments have you planned for 2015? PC: We will continue to market ourselves in the UK and Switzerland, which have been our traditional target mar-kets but we also have plans to market further afi eld in Hong Kong and New York.

Within Gibraltar a restructuring of the FSC is planned with the aim of strengthening future delivery with a busi-ness change programme. Th is will further streamline the application and regulatory processes for fi nancial services fi rms.

PHILIP CANESSA, SENIOR FINANCE CENTRE EXECUTIVE AT GIBRALTAR FINANCE, DISCUSSESGIBRALTAR’S ACHIEVEMENTS AND PLANS FOR 2015 WITH HFMWEEK

STREAMLINING AHEAD

WE HAVE CONTINUED TO FOCUS ON A CULTURE OF COMPLIANCE AND IN 2014 SIGNED A FATCA

INTERGOVERNMENTAL AGREEMENT WITH THE US

”

F I N A N C I A L S E R V I C E S

Philip Canessa joined Gibraltar Finance in September 2013 as senior finance centre executive – funds and asset management, focusing on the development of the funds and asset management sectors. He has more than 30 years of experience in the financial services sector and was managing director of an investment firm managing hedge fund portfolios for 11 years. He also served as a board director of a number of funds in different jurisdictions.

GIBRALTAR: THE SPECIALIST FINANCIAL JURISDICTION OF CHOICE IN

THE EU

GFIA members include Funds, Fund Administrators, Stockbrokers, Investment Managers, Audit Firms, Law Firms,

For more information please contact GFIA Executive Coordinator by e-mail on

Established EU Jurisdictionfor a wide range of investment funds

Fully AIFMD compliant, with passportingright across the EU

Specialist European master feeder fundsolutions

Unique asset manager offering, combiningquality of life with fiscal and legislativestability

Professional and internationally recognized fund and investment expertise


G I B R A L T A R 2 0 1 5

The advent of the Alternative Investment Fund Managers Directive (AIFMD or the Directive) has dramatically changed the scope of services that European finance cen-tres, such as Gibraltar, can offer American fund managers.

US fund managers are very used to setting up Cayman funds with Delaware feeder funds for US taxable investors. In the past they would market these funds to European in-vestors via the private placement regimes as it was almost impossible to get these funds authorised in the various Eu-ropean 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 American 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’.

It is genuinely arguable whether a fund that targets European investors can rely on the premise of reverse so-licitation. It is an artificial doctrine at best. Furthermore, it places existing investors at risk. If a fund is deemed to have been promoted improperly in a jurisdiction, the investor may rescind the investment contract at any time. This means that the investor may be able to obtain a restitution of the amount initially invested. This amount would be payable by the fund to the detriment of the other inves-tors. It is arguable that funds that rely on reverse solicita-tion should add a risk warning, informing investors of the dangers that it may present.

The safest way for American 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 ap-propriate European investors. Structures often used are such that the Cayman fund will itself act as a feeder into the European fund, which will then make the relevant in-vestments (see Fig 1: European/Gibraltar master fund).

Alternatively, the European fund can serve as a parallel fund to the Cayman fund (see Fig 2: European/Gibraltar parallel fund).

It is unlikely, because of EU regulatory constraints, that the EU fund will be able to act as a feeder into the Cayman as is the case, for example, with Delaware feeders for US investors.

US managers may continue to use Cayman vehicles for their non-EU business, but these managers will now

be looking to European jurisdictions to be able to market to European investors. It stands to reason that in their search for European vehicles for their funds, they should look to the jurisdiction which is closest legally, and in regulatory approach to what they are used to in the Cay-man Islands. Gibraltar being a common law jurisdiction with the UK Privy Council as the ultimate Court of Ap-peal 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, Gibral-tar is the only European jurisdiction that allows for the pre-authorisation launch of a fund, as Cayman does.

JAMES LASRY, HEAD OF FUNDS AT HASSANS, AND PRESIDENT OF THE GIBRALTAR AMERICAN CHAMBER OF COMMERCE, SPEAKS TO HFMWEEK ABOUT GIBRALTAR’S POSITION AS THE GATEWAY TO EUROPE FOR US MANAGERS

GIBRALTAR: THE KEY TO EUROPE FOR US FUND MANAGERS

James Lasry, is head of funds at Hassans Law Firm. He has been instrumental in setting up many of Gibraltar’s funds, including the first Experienced Investor Fund and Protected Cell Company Fund and advises the Government of Gibraltar on funds legislation.

US taxable investors

Non-taxable & offshore investors

European investors

Investment

FIG 1: EUROPEAN/GIBRALTAR MASTER FUND

Delaware feeder

Cayman feeder

Gibraltar parallel fund

US taxable investors

Cayman feeder

Investment

Gibraltar parallel fund

Non-taxable & offshore investors

European investors

Delaware feeder

FIG 2: EUROPEAN/GIBRALTAR PARALLEL FUND

L E G A L


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

”

THE ALTERNATIVE INVESTMENT FUND MANAGERS DIRECTIVESince 22 July 2013, European Alternative Investment Fund Managers (AIFMs) managing EU Alternative In-vestment Funds (AIFs), such as Gibraltar AIFs, have been able to obtain authorisation under AIFMD and therefore benefit from the EU marketing passport pro-vided for by the Directive. Such AIFMs will be able to market to professional investors freely within the EU. There is the possibility that managers from third jurisdic-tions such as those in the US, the Caribbean and the Channel Islands will be able to obtain au-thorisation and therefore access to the EU mar-keting passport under AIFMD subject to certain conditions, but only from mid-2015 at the earli-est. There is some doubt in the industry, which is probably justified, as to the true willingness of Esma to approve certain non-European jurisdic-tions, particularly some of those in the Carib-bean as authorised third jurisdictions under the Directive. At least one member of the European Parliament who was involved in the drafting of the Directive has expressed such doubts.

There will no doubt remain a place for the bet-ter offshore jurisdictions. The ‘if it ain’t broke, don’t fix it’ attitude that structures the vast major-ity of funds through the Cayman Islands is simply less relevant in an investment industry that has changed almost beyond recognition from that which existed just a few years ago.

PERMISSIBLE DISTINCTIONS – GIBRALTAR’S ADVANTAGEThe 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.

In their implementation of the Directive, member states were free to decide how they exercise the deroga-tions provided for in AIFMD. They also decided whether they wished to ‘gold plate’ the Directive by adding provi-sions to their national fund regimes that were not required by the Directive. Critical distinctions in implementation may exist in such topics as regulation of the national fund regimes for funds and managers that are below the de minimis thresholds of the Directive (i.e. €100m for open-ended funds and €500m for closed-ended funds without leverage), including application of the depositary regime in the Directive to funds that are out of scope of the Di-rective and applicability of any private placement regimes.

The Gibraltar approach to the above issues, following an in-depth consultation involving a collaboration of govern-ment, 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 of-

fered 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.

EIFs will therefore form the basis for the regulatory re-gime to be used as the in scope AIF. As they have to comply with the terms of the Directive they will essentially be ‘super EIFs’. This is very significant because, as mentioned below, this is likely to dra-matically reduce the licensing time of in scope AIFs thus retaining Gibraltar’s place as the European jurisdiction with the quickest potential for time to market for new funds.

AIFMs wishing to set up Gibraltar funds will be able to do so by establishing super EIFs utilising the existing pre-authorisation launch process avail-able to out of scope EIFs. In other EU jurisdictions, AIFMs wishing to establish in scope AIFs will have to undergo an authorisation process for those AIFs (which can take anywhere between a few days in some cases to several months depending on the fund and the jurisdiction). The Gibraltar process, however, is simply to establish and commence trading the EIF on the basis of the pre-authorisa-tion launch process. This entails the submission of

the EIF documentation to the FSC along with an opinion from Gibraltar Counsel stating that the fund has been properly established. At the same time the passporting no-tices can be submitted to the FSC. The FSC will then have up to 20 business days to consider the AIF documentation and the passporting notices.

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 Gibral-tar 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. American managers will be used to this more business-friendly regulation as it echoes some of the ways in which American managers are regulated by the Securities and Exchange Commission.

The FSC will follow the UK/FCA’s proportionality approach in respect of remuneration. Furthermore, del-egation will be permitted so long as overall supervision and responsibility remains within the jurisdiction. De-positary requirements are probably the most difficult of the three issues with many operational questions remain-ing open among all of the European jurisdictions. In any case, the depositary provisions have been deferred until 2017 so that any European depositaries may be used un-til that time.

Ultimately, the AIFMD has provided European juris-dictions and particularly Gibraltar with an opportunity to genuinely add value to US managers in the marketing of their funds to the EU – a market of 520 million people.

A C C O U N T I N G


G I B R A L T A R 2 0 1 5

On 22 July 2013, the Alternative Invest-ment Fund Managers Directive (AIFMD and/or Directive) became EU law. AIFMD introduced harmonised require-ments for entities involved in the man-agement of alternative investment funds

(AIFs) that are managed and/or marketed to profes-sional 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, etc) to alter-native asset classes such as real estate and private equity.

Th e impact of AIFMD on most existing AIFMs was deferred by a one-year transitional period which ended on 22 July 2014, aft er which AIFs managed and/or mar-

keted in the EU must be compliant with the Directive, unless a relevant exemption applies.

It is estimated that there are more than 1,200 fi rms caught by the Directive across Europe, with the largest number of fi rms based in the UK. Th e FCA (the UK regulator) expects to receive in the region of 800 appli-

THE IMPACT OF AIFMD ON MOST EXISTING AIFMS WAS DEFERRED BY A ONE-YEAR TRANSITIONAL PERIOD

WHICH ENDED ON 22 JULY 2014

”

ADRIAN HOGG, DIRECTOR OF GRANT THORNTON GIBRALTAR, TALKS TO HFMWEEK TO EXPLAIN HOW AIFMD HAS BEEN INTEGRATED INTO THE BUSINESS INDUSTRY IN GIBRALTAR

AIFMD – ONE YEAR ON

Adrian Hogg joined Grant Thornton Gibraltar in 2005 and became a director in 2007. He has been involved in the funds profession in Europe and the Caribbean for over a decade. He is a fellow of the Institute of Chartered Accountants in England and Wales, is a former chairman of the Gibraltar Funds and Investments Association and is a former member of the Gibraltar Finance Centre Council.

A C C O U N T I N G

1 2 H F M W E E K . CO M

G I B R A L T A R 2 0 1 5

cations for AIFM authorisation. The actual number of AIFMD approvals across Europe has been low by com-parison. 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.

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 au-thorities 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 mar-keted 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: (i) seek an exemption from the scope of AIFMD, or (ii) become compliant.

EXEMPTIONS FROM THE SCOPE OF AIFMDThere are several exemptions to the scope of AIFMD, the main of which being the de minimus test of an AIFM with aggregate total assets of (a) less than €100m (in-cluding leverage); or (b) less than €500m (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 COMPLIANTAIFMs operating under existing licences should seek authorisation for a variation of permission from their regulator. Organisations acting as AIFMs, that have not previously been authorised, should submit an ap-plication 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 portfo-

lio 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 com-plexity and legality to be observed.

THE GIBRALTAR SOLUTIONGibraltar is fully compliant in respect of EU investment business and fund legislation. 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 with 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 or borrowing. With unrivalled speed to mar-ket 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. Gibral-tar’s small AIFM regime will provide a platform for man-agers to enter into the EU regulatory environment with-out 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, reg-ulations and products in place in order to meet the re-quirements of AIFMD. If you are the one of many AIFMs that are struggling with AIFMD implementation, look no further than Gibraltar.

IF YOU ARE AN AIFM AND YOU ARE NOT YET AUTHORISED, YOU SHOULD CAREFULLY CONSIDER

YOUR OPTIONS

”

GIBRALTAR 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

”

Experienced Investor Funds (EIF)

An EIF is an authorised collective investment scheme exclusively for investment by experienced investors and is designed to invest in a wide range of traditional or alternative asset classes.

Gibraltar Finance is the growing success story in Europe for investment funds and investment managers. It offers robust fund legislation, a favourable fiscal regime, an EU framework, efficient regulation, the flexibility of a small jurisdiction and quality infrastructure.

As an EU domicile, Gibraltar Finance provides investors

thereby enabling passporting throughout the member states of the EU. Gibraltar also presents both political and economic

international standards and full employment rights for EU/EEA and Swiss citizens.

Asset Management

Management firms can establish themselves as a firm under

2006, or the Financial Services (Alternative Investment Fund

GATEWAY TO THE EUROPEAN UNION SINGLE MARKET

For more information visit the Gibraltar Finance website:

www.gibraltarfinance.gi

One of the attractions of Gibraltar as a fund domicile is that no regulatory approval is required before an EIF can begin to raise capital and commence its investment activities. An EIF may be launched based on a legal opinion that confirms that the EIF has met all legal and structural requirements for its operations, and provided that the fund’s documentation is submitted to the


G I B R A L T A R 2 0 1 5

HFMWeek (HFM): How has Gibraltar fared in 2014 and which of its industries have been most successful?Moe Cohen (MC): Gibraltar continues to develop in a number of ways. Generally, the fi scal and regulatory incentives continue to att ract a number of businesses to the region, as well as non-Gibraltar compa-nies looking to re-domicile or restructure via Gibraltar, in both the regulated and non-regulated space, including private clients and international companies.

Specifi cally, in terms of funds, Gibraltar has been very busy in the last few months with the adoption of the AIFMD, which has been fully integrated on time, and there are a number of licensees in place already. In the meantime, Gibraltar continues to att ract and grow funds. Impor-

tantly, we at Nexus now have an AIFM private equity de-positary licence, which is a new development in Gibraltar and crucial for Gibraltar-based AIFM PE funds that need

an AIFM depositary.

HFM: What is the relation-ship like between Gibraltar’s regulators and the businesses domiciled there? MC: Both the Gibraltar gov-ernment and its regulator have been working very closely with the industry in order to launch AIFMD successfully, as well as on many other fronts in order to make the industry att ractive from an international perspec-tive. Th is has been proven by the result of having new busi-nesses coming to Gibraltar. Th e FSC specifi cally is very proac-tive in terms of liaising with the

IN TERMS OF FUNDS, GIBRALTAR HAS BEEN VERY

BUSY IN THE LAST FEW MONTHS WITH THE ADOPTION

OF THE AIFMD, WHICH HAS BEEN FULLY INTEGRATED

”

MOE COHEN, CEO OF NEXUS FUND ADMINISTRATION, TALKS TO HFMWEEK ABOUT WHAT MAKES GIBRALTAR UNIQUE AS AN EU-COMPLIANT JURISDICTION

A ONE OF A KIND OPPORTUNITY

Moe Cohen FCA is a founder of Benady Cohen & Co, Chartered Accountants, as well as the CEO for Nexus Fund Administration Services. He is also a member of the executive board of GFIA and Finance Centre Council. Cohen advised the Government on the initial establishment of regulated funds in Gibraltar in 2004.

F U N D S E R V I C E S


WITH RESPECT TO FUNDS, ANOTHER USP IS THAT THE EIF IN GIBRALTAR HAS A PARTICULAR CHARACTERISTIC WHICH IS THAT THIS TYPE OF FUND

IS VERY QUICK TO MARKET

”

industry in order to ensure that everyone is on the same page; notably that all the reporting requirements from an AIFMD and a technical perspective are being met, mak-ing sure the actual suppliers of businesses have been given sufficient time to meet the different requirements and deadlines and, importantly, that they were not under any undue pressure as a result. Being able to plan in advance is the sign of a good regulator, especially when it comes to implementing large pieces of legislation that will affect many funds and service providers.

HFM: How does Gibraltar stand out as a jurisdiction compared to its other EU competitors?MC: Gibraltar has a number of unique selling points (USPs) that makes it stand out. Firstly, as I mentioned Gibraltar has a very efficient, accessible and dynamic regu-lator. This aids anyone looking to set up in Gibraltar and is not to be taken lightly as there are other jurisdictions out there that have very rigid and inaccessible regulators that make the process of taking product to market very protracted.

With respect to funds, another USP is that the EIF in Gibraltar has a particular characteristic which is that this type of fund is very quick to market. It doesn’t require excessive approval, it is simply licenced through notifica-tion. Fund promoters and directors need to work with service providers, administrators and lawyers, and at least two authorised directors in Gibraltar, to get their package ready. Once this is complete they will present it to the FSC and within 10 working days the fund can launch so it doesn’t require any further approval from the FSC. This is vital for time sensitive investment objectives because by the time a fund can be authorised in another part of the world you may lose commercial and business opportunities.

The third USP is that Gibraltar is home to professionals from all over the world, in particular the UK. These highly qualified professionals from global accounting, invest-ment management and law firms give funds based here a very professional environment. In addition, our cost-base is much lower than other jurisdictions which means solu-tion is more cost-effective. The combination of these fac-tors alone make Gibraltar a very attractive option.

It must also be mentioned that a new Gibraltar Stock Exchange (GSX) has been launched which will give funds the ability to be able to be listed in a European recognised

exchange. That can be very attractive from a marketing perspective. Its existence will only add to the overall at-tractiveness of Gibraltar.

HFM: How does Gibraltar benefit from its unique re-lationship with the UK? MC: The UK has always been an important source of busi-ness for Gibraltar and will continue to be so for many years to come. The natural connection of Gibraltar being a Brit-ish overseas territory and the proximity and accessibility to London and other major UK cities like Birmingham and Manchester makes Gibraltar very closely connected to mainland UK.

From this historic relationship Gibraltar has developed as a common law jurisdiction and its laws are very much akin to the UK’s. For example, in November 2014 Gi-braltar implemented the new Companies Act which is in line with the UK’s own act. This enables individuals with knowledge of common law, such as in the UK, to come to Gibraltar and carry out business easily.

There is also a very friendly fiscal relationship which al-lows for some structured solutions to be setup quickly and efficiently.

HFM: Where is Gibraltar headed as a business juris-diction in 2015? MC: AIFM is certainly an area with great potential. Al-though 2014 was a year of growth for us, this was despite the fact that the AIFMD’s implementation caused quite a lot of distraction in its setting up. Now that is settled, li-cences are being issued and the general business world is beginning to implement the Directive, Gibraltar can offer

itself as an excellent jurisdiction for non-European funds to use as a stepping stone into Europe, aided by the exist-ence of GSX as appropriate.

In 2015, Gibraltar is also looking to forge links with the US and the Far East, as well as developing its existing links with more familiar areas such as Switzerland. This will hopefully generate a lot of funds and fund solutions and Gibraltar is very well placed to crystallise those opportuni-ties here on the Rock of Gibraltar. Further, as well as tradi-tional large funds, Gibraltar is also using the EIF as a fund solution for family offices, which are having an increased presence in Gibraltar. Therefore, we have found ourselves becoming an attractive option both to larger funds and also more niche businesses such as family offices.

THE UK HAS ALWAYS BEEN AN IMPORTANT SOURCE OF BUSINESS

FOR GIBRALTAR AND WILL CONTINUE TO BE SO FOR MANY YEARS TO

COME

”

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THE HEDGE FUND sector is

hopeful that last-minute chang-

es to the small print of new

Basel III global capital rules

have prevented the prospect of

huge increases in stock borrow-

ing costs.

Final rules from the Basel

Committee on upcoming Net

Stable Funding Ratio require-

ments for banks, published last

Friday, contained a significant

carve out for institutions offer-

ing securities lending services

to hedge funds.

Short-term repo borrowing

costs for trading with non-bank

entities have also been reduced

through a lower required stable

funding ratio than originally

proposed, although experts

warn charges will still rise.

Lobby groups Aima and the

MFA had both been urging the

Basel Committee to revisit the

new rules, warning that treat-

ing stock borrowing as a loan

under the new calculations

would have undermined the

ability of banks to provide such

services to hedge funds. Some

lobby groups forecasted a five-

fold increase in the cost of stock

borrowing.

Under the final rules, due

to be introduced in 2018,

stock lending transactions can

be treated as neutral from a

funding requirement

perspective as long as

But experts warn new

rules will be open to local

interpretation

BY MAIYA KEIDAN

03

COMMENT N U T S A N D B O LT S O F L E V E R A G E C O N C E R N S 14

Hedge fund sector

welcomes Basel III

NSFR carve out

MAKING HEDGE

FUNDS LOOK CHEAP

MORNINGSTAR ANALYST JASON

KEPHART ON THE COSTS AND

LACK OF TRANSPARENCY OF

CERTAIN LIQUID ALTSFEATURE 21

The long and the short of it

ISSUE 359 6 November 2014

CLOSURE 10

HERMES SHUTS FOHF ARM AND NEW YORK OFFICE

New multi-asset team will be led by Tommaso Mancuso

REGULATION 03

AIFMD PASSPORT ‘LIKELY’ TO GET NON-EU AIF EXTENSION

Industry vet confi dent of Esma recommendation next year

LEGAL 07

INVESTORS DROP MORNINGSTAR LAWSUIT OVER FUND FRAUD

High-profi le case saw investors lose $17m in ‘fi ve-star’ hedge fund

FE ATURE 16Latest data on the top 20 admins,

auditors, custodians and prime brokers

for SEC-registered hedge funds

SNAPSH

OT

THE

ALPHAPIPE-

HFMWEEK

SERVICE PROVIDER

Q 3 : 14

s indd 1

04/11/2014 16

www.hfmweek .com

TOP HEDGE FUND seeders

have reduced the amount of dry

powder at their disposal after

a number of deals were struck

this year with more in the pipe-

line, HFMWeek’s latest annual

survey has revealed.The top five seeders have

$1.95bn of dry powder availa-

ble, a 17% drop on the $2.35bn

ready to be invested this time

last year, according to our fifth

annual survey. Asset management giant

Blackstone has moved up from

second place last year to top

the list with $600m of dry pow-

der available. It also came top

in terms of seeding activity,

with three deals this year total-

ling $600m.Blackstone replaces Reservoir

Capital after the $7.5bn New

York-based firm put $200m of

last year’s $700m of available

funding to work seeding new

venture Abberton Capital, a

London-based activist fund run

by Former TPG Axon partner

Fredrik Juntti.Reservoir Capital moved

down to joint second spot,

with $500m still available to be

deployed, although the firm is

looking to use this up by early

next year via three new seeding

deals. Protégé Partners has $500m

of dry powder avail-able and so joins

Dry powder of top five seeders falls 17% year-on-

year BY ALEX CARDNO

03

COMMENT F E E S A N D E X P E N S E R AT I O S

14

Blackstone tops seeders list as dry

powder levels drop

ARE YOU INVESTING RESPONSIBLY?

VARMA’S JARKKO MATILAINEN

TELLS HFMWEEK WHY THE

FINNISH FIRM IS PLANNING TO

FOCUS ON ESG

FEATURE 22



LAUNCH 11

FORMER UBS DUO PREPARE TO LAUNCH FIRST HEDGE FUND

Reaching Value and Opportunities Fund should launch by year-end

PEOPLE MOVES 03

BLUEBAY HIRES EX-MAN GROUP CTO AS GLOBAL TECH HEAD

Andy Archer replaces BlueBay veteran Simon Lumsdon

PERFORMANCE 05

PERSHING SQUARE ASSETS GROW TO OVER $18BN

Ackman’s fi rm weathered tough month for event-driven strats

FE ATURE 16

It has been a busy year for seeding

fi rms, although many have taken a

cautious approach. Our fi fth annual

HFMWeek seeding feature looks in

detail at the top fi ve seeders who

have seen the most success in 2014

SEEDINGTOP 5

THE HFMWEEK

001_003_HFM360_News.indd 1

11/11/2014 16:35

www.hfmweek .com

US AGENCY THE NFA has

become the first regulator to

proclaim its desire to work

towards global reporting har-

monisation, in an exclusive

interview with HFMWeek.

In June, HFMWeek revealed

regulators were in early stage dis-

cussions about a unified report-

ing regime that could reduce the

burden on hedge funds report-

ing in different jurisdictions,

although no regulator would

comment publicly on the talks.

In an interview with

HFMWeek, NFA vice presi-

dent, compliance, Regina

Thoele said the NFA would

like to work with the SEC, and

alongside the CFTC, to harmo-

nise the SEC’s Form PF and the

CFTC/NFA Form PQR. She

also said the NFA is “very open”

to engaging with the UK’s FCA

on harmonisation, as firms pre-

pare to file their first Annex IV

submissions under the AIFMD

by the 31 January deadline.

She cautioned it would not

be an easy task. “It’s going to be

hard to do – you’re bringing a

lot of regulators together.

“But I think it’s important

for us to collect the data that

we can use and make sure it’s

meaningful data.”

The SEC would not comment

on the NFA’s call. However, a

source within the reg-

ulator warned Form

US regulator says CFTC,

SEC and FCA should work

towards unified reporting

BY MAIYA KEIDAN

03

COMMENT L E V E R A G E D I S C LO S U R E A N D M E A S U R E M E N T14

NFA calls for

global reporting

harmonisation

HFMWEEK MEETS

THE NFA

REGINA THOELE DISCUSSES

FEES, EXAMS AND COMMON

DEFICIENCIESFEATURE 16



LAUNCH 11

FORMER UBS DIRECTOR PREPS MARKET-NEUTRAL FUND

Australian Qato Capital to launch market-neutral fund

STRATEGY 03

BH MACRO CHAIR FORECASTS ‘FERTILE’ TIME FOR MACROS

Economic divergence to boost strategy, says Plenderleith

BUYOUT 05

STATE STREET GLOBAL ADVISORS TO SELL SSARIS IN MBO

Senior management to buy 60% stake in FoHF platform

FE ATURE 19The Shanghai-Hong Kong Connect

pilot scheme is not the only big

opportunity for hedge funds in China

CHINESE TAKE-OFF

18/11/2014

www.hfmweek .com

THE TOP 10 alternative Ucits umbrellas saw a huge 43%

growth this year as experts noted US managers reacting to

the AIFMD and the success of ’40 Act funds as a major con-

tributor to nearly $9bn of fresh assets.

The year-on-year increase from $20.14bn to $28.86bn,

for the year to 31 October, is the biggest asset growth since

HFMWeek began its Ucits plat-form survey in 2010. Assets

grew by $6.33bn in 2013, $5.26bn in 2012 and $4.49bn

in 2011.

Seven out of the 10 grew assets by over 50% over the

previous 12 months, with Bank of America Merrill Lynch

(Baml) adding the most assets ($2.95bn) and Schroder Gaia

tailing closely behind, with an increase of $2.68bn. Lyxor

added $1.22bn as its assets more than quadrupled from

last year.“The single biggest trend has been the rise in interest from

US-based managers looking to launch a Ucits,” Andrew

Dreaneen, head of Schroder GAIA Product & Business

Development, told HFMWeek. “There are a number of reasons

for this, including the need to have an AIFMD or Ucits pass-

port to market widely in Europe.”

Seven out of 10 umbrellas enjoy over 50% YOY asset

increase BY MAIYA KEIDAN

03

COMMENT S H O RT S E L L I N G A N D T I G E R G LO B A L14

US effect helps Ucits platforms surge by nearly $9bn

THE BIGGEST UCITS PLATFORMS THIS YEARALTERNATIVE UCITS HEDGE FUND

UMBRELLAS ENJOYED RECORD GROWTH

ANALYSIS 22


ISSUE 362 4 December 2014

LAUNCH 10

TENOR CAPITAL PLANS TO LAUNCH ARBITRATION FUND

New York fi rm targeting $150m raise and H1 2015 fi rst close

LEGAL 05

DECURA CLAIMING $167M AS UBS COURT BATTLE BEGINS

UBS is accused of reneging on 2012 marketing deal

PEOPLE MOVES 08

SKYBRIDGE CAPITAL’S EUROPEAN CEO TO LEAVE

Max von Bismarck will depart at the end of the year UCITS

ANALYS IS 16

HFMWeek’s 23rd biannual assets under administration survey –

Part 1: Single managers

ASSETS UNDER ADMINISTRATION

001_003_HFM362_News.indd 1

S TO C K E X C H A N G E


G I B R A L T A R 2 0 1 5

HFMWeek (HFM): Gibraltar opened its fi rst stock ex-change on 10 November 2014. What will the introduc-tion of the Gibraltar Stock Exchange (GSX) mean for the jurisdiction?Nick Cowan (NC): Gibraltar was the last EU jurisdiction without an exchange, which has been a key factor in Gi-braltar lagging behind its peers in terms of capital markets evolution. Th is was something that we needed to address.

When Marcus Wohlrab (GSX co-founder) and I fi rst set about applying for the exchange licence, we needed to understand a number of things: what type of exchange was the jurisdiction looking for? What was the risk appe-tite and what type of exchange would be acceptable to the regulator? What types of assets and products would be appropriate to the jurisdiction? What was the knowledge base and what were the areas of strength in terms of assets in Gibraltar? Additionally, we needed to look at other factors such as what was happening in the regulatory picture globally and within the EU.

Th e process commenced in 2012 and we engaged at the earliest opportunity with the key stakeholders including the government, the regulator and the Gibraltar-based service pro-viders who would be our target member fi rms. What became apparent quite quickly was that there was an extremely strong infrastructure supporting the investment funds business in Gibraltar, but that without an exchange they had struggled to develop the business to where it should be in terms of its standing within the glob-al community and also within the EU. With the regulatory changes and the alternative investment fund manager di-rective (AIFMD), there was clearly an opportunity here for the jurisdiction to raise its game.

Gibraltar’s transition into the leading EU fi nance cen-tre it is today evolved over a period of many years. Th e off shore or ‘brass-plate’ mind-set has long gone with the focus being on regulation and reputation. Th erefore, the exchange was structured to minimise risk while comple-menting the existing strengths of the jurisdiction, leading us to open initially as a technical listing exchange for open-ended funds.

When fund managers look at the criteria in helping them choose a jurisdiction, the following are important consider-ations: a fl exible and accessible regulator; the jurisdiction’s approach to the AIFMD; the ease with which one can re-domicile funds to the jurisdiction; a pro-business govern-ment; speed-to-market, pricing; the passporting benefi ts that come with being a member of the EU; but just as im-portant as all that, is the presence of a stock exchange.

In summary, we anticipate GSX will be the catalyst that elevates Gibraltar to be a realistic alternative to other juris-dictions – somewhere att ractive for collective investment schemes to domicile and list. Not having an exchange has been to Gibraltar’s detriment, and now we hope it will be a slightly bigger drawing pin on the map.

HFM: What is the signifi cance of the timing?Philip Young: Post-crisis, the regulatory environment has changed dramatically, and the AIFMD has catapulted Gibral-tar to one of only four EU juris-dictions that has a competitive and fi scally att ractive off ering in terms of funds domiciling.

At the macro level, two things are happening since the crisis: there is a shift from off shore to onshore in the funds industry due to the EU regulatory envi-ronment gett ing stricter; there is a drive to listing on exchanges. Post-crisis, investors are de-manding more of their manag-ers and a listing off ers increased

confi dence from the investor as the fund has been through a regulatory process providing increased transparency and visibility. A listing on an EU exchange provides visibility to the EU investor audience. Th ese things are increasingly important when investors are looking to allocate their as-sets, as a listing can provide an extra degree of comfort. In-vestors wish to know that funds have been through a due diligence process that includes a regulator; in our case, an EU regulator.

In many ways, therefore, the timing has worked out well for Gibraltar as a jurisdiction to launch its fi rst stock exchange. Th ough it was clear that Gibraltar needed an exchange, the regulatory changes have helped provide the catalyst. If you’re looking to domicile and list your fund,

WITH THE REGULATORY CHANGES AND THE ALTERNATIVE INVESTMENT FUND MANAGER DIRECTIVE (AIFMD), THERE WAS

CLEARLY AN OPPORTUNITY HERE FOR THE JURISDICTION TO

RAISE ITS GAME

”

NICK COWAN, MANAGING DIRECTOR, MARCUS WOHLRAB, MARKETING DIRECTOR, AND PHILIP YOUNG, FINANCE DIRECTOR, OF THE GIBRALTAR STOCK EXCHANGE, TALK TO HFMWEEK ABOUT THE EXCHANGE’S RECENT LAUNCH

STOCK EXCHANGE LAUNCHES IN GIBRALTAR

Nick Cowan, managing director, has over 30 years’ investment industry experience in developed and emerging markets including five years as the global head of equities for ING Barings serving as a member of executive committee. Responsible for 2,500 employees in 43 countries, including 40 stock exchange memberships, as well as numerous restructurings, turnarounds, acquisitions and divestments.

Marcus Wohlrab, marketing director, has over 26 years’ investment industry experience working for Paine Webber, UBS, director for Europe and the Middle East for NASDAQ and executive vice president, EASDAQ running the exchange and reporting directly to the board.

S TO C K E X C H A N G E


G I B R A L T A R 2 0 1 5

you are more likely to go to somewhere that has the in-frastructure to support you to provide the single solution. It would be ineffi cient to domicile in Gibraltar and list on another stock exchange due to the additional fees. You achieve economies of scale by being in the same jurisdic-tion so it had to happen in my view. I think the regulatory tailwind is supportive of the strategy that we have. In ad-dition, it’s a strategy that fi ts with the jurisdiction. It’s very small and very simple, but has an ambition to grow.

HFM: Gibraltar has already witnessed a few att empts to set up a stock exchange. What is diff erent about GSX and why do you believe it will be successful? NC: I think there are a number of reasons why we are optimistic about our success. We believed that the key is-sue in building the exchange was to keep it simple, focus on the products where there already existed a knowledge base, and structure a business model that would ensure economic viability in a robust control environment, thus protecting the reputation of Gibraltar itself.

However, I believe our key to future success is the fact that we are based in Gibraltar. Our size brings many advan-tages. Th e relationship we have between the government, the service providers and the regulator has created a col-lective ambition. GSX will be the fastest and lowest cost exchange in the EU when it comes to listing funds. GSX provides the perfect listing complement to our Experienced Investor Fund (EIF) vehicle with its pre-launch approval regime, where an EIF can be launched in 10 working days, making it the fastest time-to-market fund vehicle in the EU.

Our marketing confi rms a clear demand for a low-cost alternative to other exchanges. A GSX listing can provide a stepping-stone to Europe for off shore AIFs off ering in-creased marketability, visibility and transparency. Our

unique portal also provides the opportunity for managers and investors to connect in a protected environment, pro-viding managers the opportunity to grow assets by listing on GSX.

Finally, I think we have a strong management team with over 80 years of experience between the three execu-tives. I was the global head of equities (and before that the global head of equity trading) for one of the world’s largest banks, and operated over 40 exchange seats around the globe. My role was centred on managing risk on a large scale, which I think has provided comfort, and has hope-fully built confi dence with the regulator. Marcus Wohlrab was a top marketing executive at Nasdaq and Easdaq for many years, while our fi nance director, Philip Young, has spent a career on the buy-side within hedge funds and private equity as a member of investment committ ees. In addition, we have a strong board with Marcus Killick (the previous CEO of the Financial Services Commission) as our chairman, Simon Brickles (the ex-CEO of AIM and Plus Markets) as our deputy chairman and Adrian Hogg from Grant Th ornton as non-executive director.

HFM: Where are potential markets for you to seek list-ings from? Marcus Wohlrab: Th e fi rst answer is the funds infrastruc-ture in Gibraltar. Some of those funds are quite interested in listing, which probably makes sense. However, we see GSX’s sweet spot as being off shore alternatives, of a certain size, looking for an EU listing, particularly Asian funds. We don’t see listings moving from Ireland and Luxembourg to Gibraltar. Th at would be fantastic but we’re realistic. Th at is not our market. We’re looking for the smaller fund man-ager who might fi nd a listing on Luxembourg perhaps be-yond his cost limits. Th at’s our fi rst push.

Philip Young, finance director, has over 26 years’ investment industry experience. Young began his career in investment banking before moving to investment management where he spent five years with a start-up hedge fund and, latterly, five years with a principal emerging market private equity firm. Young is a CFA Charterholder.

Authorised and regulated by the Financial Conduct Authority.

Member of the London Stock Exchange.

hfm gibraltar2015

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