BVI: Introduction of Registration Regime for Closed-Ended Funds

On 31 December 2019, the British Virgin Islands government enacted the Securities and Investment Business (Amendment) Act, 2019 and the Private Investment Funds Regulations, 2019 (together, the “Law”). On the same day, the British Virgin Islands Financial Services Commission (the “FSC”) published the Private Investment Funds Regime Guidelines and the Fund Safekeeping Arrangements Guidelines (the “Guidelines”). This advisory summarises the key features of the Law and the Guidelines and their likely impact on closed-ended funds and their managers. While the publication of the Law and the Guidelines have answered certain of the key questions that we identified when the consultation draft of the Law was published, there remain areas where further guidance is anticipated. As any of the matters discussed in this advisory develop in the coming months, we will publish additional advisories and guidance.

Private funds have until 1 July 2020 to complete their initial registration (whether new funds or existing ones).


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Daniel WoodManaging PartnerT +971 4 363

Mark CummingsPartnerT +852 2596
Thomas GrangerPartnerT +852 2596

Patrick OrmondPartnerT +44 (0)20 7220
Hughie WongPartnerT +44 (0)20 7220

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