Frequently Asked Questions: Investment Funds

Everything fund managers and investors need to know about establishing and administering investment funds in Gibraltar — from structure selection through ongoing regulation, reporting, and costs.

• What types of investment fund can be established in Gibraltar?

  Gibraltar offers two primary regulated fund structures: the Experienced Investor Fund (EIF) and the Private Fund. The EIF is a fully regulated collective investment scheme available to experienced investors (minimum subscription £100,000), regulated by the GFSC under the Financial Services (Experienced Investor Fund) Regulations. The Private Fund is available for up to 50 investors with a minimum subscription of £50,000 and has a lighter-touch regulatory regime with faster setup.

• What is an Experienced Investor Fund (EIF)?

  An EIF is Gibraltar's flagship regulated fund structure for professional and sophisticated investors. It requires GFSC authorisation, a licensed fund administrator (such as Resilience Group), a licensed investment manager, and an independent auditor. EIFs can be structured as companies, limited partnerships, or unit trusts, and can pursue any investment strategy including equities, real assets, crypto assets, and alternatives.

• What is a Gibraltar Private Fund?

  A Private Fund is a lighter-regulated fund vehicle for up to 50 investors, typically used for club deals, family investment vehicles, and small alternative funds. The minimum investor subscription is £50,000. Private Funds must be registered with the GFSC but do not require full authorisation, and the regulatory requirements are simpler and less costly than for an EIF.

• How long does it take to set up a Gibraltar fund?

  A Private Fund can typically be registered and operational within 4–8 weeks of submission of complete documentation to the GFSC. An EIF requires full GFSC authorisation, which typically takes 8–16 weeks from submission of a complete application. Preparation of the application — including the prospectus or offering memorandum, constitutional documents, and service provider agreements — takes a further 4–8 weeks depending on complexity.

• Does a Gibraltar fund need a licensed administrator?

  Yes. Both EIFs and Private Funds must appoint a Gibraltar-licensed fund administrator. The administrator is responsible for NAV calculation, investor register maintenance, AML and KYC on investors, regulatory reporting, and financial statements. Resilience Group is licensed by the GFSC as a fund administrator and provides these services for a range of fund types and strategies.

• What GFSC licensing does the fund manager need?

  The investment manager of a Gibraltar fund must hold a GFSC licence under the Financial Services (Investment and Fiduciary Services) Act, or qualify as a Small AIFM. Managers with EEA or FCA authorisation may be able to manage Gibraltar funds under certain arrangements, though this requires GFSC review on a case-by-case basis. Managers operating below the Small AIFM thresholds have a simplified registration pathway.

• Can Gibraltar funds invest in crypto assets?

  Yes. Gibraltar was one of the first jurisdictions to regulate distributed ledger technology (DLT) businesses and is an established hub for digital asset funds. EIFs and Private Funds can invest in cryptocurrencies, tokens, and other digital assets. The fund's offering memorandum must clearly describe the digital asset investment strategy and associated risks, and the administrator must have appropriate systems for valuing and recording digital asset holdings.

• How is NAV calculated for a Gibraltar fund?

  The fund administrator calculates net asset value (NAV) in accordance with the valuation policy set out in the fund's constitutional documents and offering memorandum. For liquid strategies, NAV is typically calculated monthly or quarterly using market prices. For illiquid assets, the valuation policy must specify the methodology (e.g. cost, third-party appraisal, director valuation). Resilience Group's fund administration team performs all NAV calculations and provides investor statements following each NAV point.

• How are investors onboarded to a Gibraltar fund?

  Investors are onboarded via a subscription agreement process. The fund administrator collects and verifies KYC documentation — certified ID, proof of address, source of funds and source of wealth evidence — for each investor before accepting their subscription. For corporate investors, beneficial ownership must be traced to natural persons. Investor onboarding typically takes 5–10 business days for straightforward profiles.

• What AML obligations apply to a Gibraltar fund?

  Gibraltar funds are subject to the Proceeds of Crime Act 2015 and the associated AML/CFT regulations. The fund administrator acts as the AML-responsible party and must conduct risk-based due diligence on all investors, screen against sanctions lists, file suspicious activity reports where required, and maintain records for at least five years. Enhanced due diligence is required for PEPs, investors from high-risk jurisdictions, and complex structures.

• Do Gibraltar funds need to report under CRS and FATCA?

  Yes. Gibraltar funds that qualify as financial institutions under FATCA and CRS must register with the Gibraltar Income Tax Office and submit annual reports disclosing investor account information to the relevant tax authorities. The fund administrator manages this reporting as part of the administration service. FATCA applies to US persons, while CRS applies to investors resident in participating jurisdictions — which includes most OECD countries.

• Does a Gibraltar fund need an auditor?

  Yes. EIFs must appoint an independent auditor approved by the GFSC, and annual audited financial statements must be filed with the GFSC and provided to investors. Private Funds are also required to have audited accounts. The auditor must be independent of both the fund manager and the administrator, and must be registered as an auditor in Gibraltar.

• What is a fund of funds and can it be structured in Gibraltar?

  A fund of funds (FoF) invests in other funds rather than directly in underlying assets. Gibraltar EIFs can be structured as funds of funds, investing in a portfolio of third-party or affiliated funds. The administrator must be able to obtain underlying fund NAVs to calculate the FoF's own NAV, and due diligence must be conducted on each underlying fund at both inception and on an ongoing basis.

• Can a Gibraltar fund have an umbrella structure with multiple sub-funds?

  Yes. Gibraltar's EIF framework supports umbrella fund structures with multiple sub-funds, each with its own investment strategy, investor base, and separate assets and liabilities. This is efficient for managers who wish to run multiple strategies under a single regulated vehicle, sharing the overhead of GFSC authorisation and fund infrastructure. Each sub-fund is treated separately for NAV, investor reporting, and fee purposes.

• What is the Small AIFM threshold and how does it affect fund setup?

  The Small AIFM regime applies to fund managers whose assets under management are below €100m (unleveraged) or €500m (fully levered, with no redemption rights for five years). Small AIFMs are subject to a simplified registration process rather than full AIFMD-equivalent authorisation, with lower regulatory costs and faster setup. However, Small AIFMs cannot passport into the EU under the AIFMD and must comply with Gibraltar's national AIM regime. Many emerging fund managers start as Small AIFMs and seek full authorisation as their AUM grows.

• What are the typical annual costs for a Gibraltar fund?

  Annual costs for a Gibraltar fund include fund administration fees (typically £15,000–£40,000 per year depending on complexity and NAV frequency), audit fees (£8,000–£25,000), GFSC annual fees (£3,000–£10,000 depending on fund type), legal fees for ongoing compliance, and registered office costs. Total annual running costs for a straightforward fund typically range from £30,000 to £80,000, exclusive of investment management fees.

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