Continuing obligations for approved funds The board and officers Functionaries and other service providers Notice requirements Event triggering an obligation to notify the FSC Time frame Annual regulatory and government requirements Due by date Action Reporting and financial statements Anti-money laundering obligations Fund policies and arrangements Obligations under FATCA and CRS Beneficial ownership regime

As a mutual fund, your approved fund is regulated by the British Virgin Islands (BVI) Financial Services Commission (the FSC). This note provides a quick reference to your approved fund's ongoing BVI obligations.

Approved funds are governed by the Securities and Investment Business (Incubator and Approved Funds) Regulations, Revised Edition 2020 (the Regulations) and the Incubator and Approved Funds Guidelines.

An approved fund must:

At all times have at least two directors, at least one of whom must be an individual

Appoint an appropriately qualified and independent individual as Money Laundering Reporting Officer (MLRO) for the fund who may, in practice, be a director of the fund itself or a person provided by one of the functionaries to the fund (see below for more detail on anti-money laundering obligations)

Appoint a Foreign Account Tax Compliance Act (FATCA) Responsible Officer and a principal point of contact for the BVI International Tax Authority (ITA)(see below for more detail on obligations under FATCA and CRS).

An approved fund is required to have an administrator at all times.

It is also required to have an FSC licenced authorised representative (Authorised Representative) at all times to act as a point of contact between the fund and the FSC. This is a service offered by our strategic alliance partner, Craigmuir Authorised Representative Limited.

It is not required to have any other functionaries or service providers, although it is free to appoint them should it wish to.

On the happening of certain events, an approved fund is required to notify the FSC. The table below summarises these notification requirements and the timeframe for providing notice.

A change of administrator

Immediately

An Authorised Representative ceasing to hold office (for whatever reason)

Immediately

Any change to the information provided to the FSC with the application ie:

change of Authorised Representative;

change of director or general partner or to any details provided in relation to a director or general partner;

amendment to constitutional documents;

amendment to offering document (if applicable); and/or

change to investment warning and/or description of investment strategy (where there is no offering document)

Within 14 days

Total number of investors exceeds the threshold for two consecutive months

Within seven days of the

end of the second

month

Maximum value of the fund's assets exceeds the threshold for two consecutive months

Within seven days of the

end of the second

month

Any matter related to the conduct of the business activities of the fund which may have a material impact on the fund (for example a suspension of subscriptions or redemptions or becoming subject to legal or regulatory proceedings)

Immediately

Number of directors falls below two (for whatever reason)

Immediately

There are various reporting and payment deadlines for an approved fund throughout the year.

31 January

File annual return in respect of previous year ending 31 December with the FSC

31 March

Pay approval fee of US$1,200 to the FSC. Failure to pay may attract administrative penalties and/or other enforcement action

30 April

For funds that are limited partnerships, pay the licence fee of US$750 to the Registrar of Limited Partnerships (together with the Registrar of Corporate Affairs, the Registry)

31 May

FATCA reporting deadline and Common Reporting Standard (CRS) reporting deadline

31 May

For funds that are companies incorporated from 1 January to 30 June, pay the Registry licence fee*

1 June

Pay annual enrolment fee of US$185 to the ITA through the ITA's online portal

By the date six months after the end of its financial year (30 June assuming financial year end is 31 December)

Provide a copy of the fund's financial statements (which do not need to be audited) to the FSC

Pay annual enrolment fee of US$185 to the ITA through the ITA's online portal

30 September

CRS additional information form filing deadline

30 November

For funds that are companies ...