The establishment and operation of Alternative Investment Funds (“AIFs”) is governed by the Alternative Investment Funds Law 124(I)/2018 (“AIF Law”) and any secondary legislation issued in the form of directives/circulars by the Cyprus Securities and Exchange Commission (“CySEC”) as well as by the European Securities and Markets Authority (“ESMA”).In addition, and depending on whether an AIF is internally and/or externally managed, the Alternative Investment Fund Managers Law of 2013 (“AIFM Law”) and Directive 2011/61/EU (“AIFMD”) provide further regulation in relation to this sector.

Yes, external managers of AIFs are required to be licensed, authorised, regulated and/or approved by CySEC.

Yes, CySEC is the regulatory body responsible for the licensing, authorisation, and regulatory compliance of AIFs. The Registered Alternative Investment Fund (“RAIF”) does not need to receive authorisation by CySEC; it merely needs to be registered with CySEC.

The production and use of marketing materials is governed by the AIF Law and the AIFM Law.  CySEC has also detailed domestic guidelines issued from time to time. In addition, Regulation (EU) 1286/2014 (“PRIIPS           Regulation”) governs the production and offering of the KIID where units are offered to retail investors. Furthermore, Regulation (EU) 2019/1156 specifies further rules regarding the cross-border distribution of collective investment undertakings.

Under the laws of Cyprus, there is a distinction between:

1) a professional investor (an investor that is considered to be a professional client or may, on request, be treated as a professional client within the meaning of MiFID II);

2) a well-informed investor (every investor who is not a professional investor as defined in the AIF Law). A well-informed investor is an investor who confirms in writing that
a) he has sufficient knowledge and experience in financial and business matters to evaluate the merits and risks associated with the prospective investment, and
b) either his investment in the AIF amounts, at least, to €125 000, or he is assessed as a well-informed investor, either by a credit institution that falls within the scope of the Banking Laws as amended, or by an Investment Firm, or by an AIFM or UCITS management company and the above-mentioned assessment shows that he has the necessary experience and knowledge to be able to evaluate the appropriateness of the investment in the AIF.

3) and a retail investor (an investor who does not qualify as a professional investor nor as a well-informed investor).

Usually, an AIF remunerates investment managers through management or performance fees and/or a combination of both. The remuneration fees must be fully disclosed to the invertors.

There are no restrictions on the participation in AIFs subject to the internal onboarding procedure of each particular AIF and the anti-money laundering restrictions.

The usual starting point is the expression of an investor’s interest to invest in a specific Fund/Investment Compartment. In doing so, the Fund’s External Manager and/or its Fund Administrator provides to the Investor for completion a Subscription Application Package.

Upon completion of this package, the Investor shall also provide its related KYC and AML documentation so as for an effective investor screening to take place. The AIFM is obliged to obtain sufficient information in relation to the investor’s identity, financial profile, investment profile, and knowledge and experience in investment services and financial instruments, before establishing a business relationship. The aforesaid are reviewed by the appointed FA to ensure the completeness, accuracy, and adequacy of the provided investor information.

Prior to officially accepting the investor for onboarding in the Fund, the Fund’s AML Officer and the External Manager’s Board of Directors shall review the provided information and grant their approval for onboarding, respectively.

The depositary will also be provided with the aforesaid Investor information so as to obtain the necessary comfort needed to accept the investor’s transfer of funds or in-specie asset in the Fund and to overall satisfy its duties as these are prescribed in the AIF Law (i.e. safe-keeping, cash monitoring and oversight).

It is also worth noting that in case a potential investor wishes to subscribe in the Fund by means of an in-specie contribution of an asset other than cash, an independent valuer shall be engaged by the Fund’s External Manager to provide a valuation of that in-specie asset. The value of the in-specie asset contributed will determine the number of investment shares the Investor will be allotted upon entry.

As per the EU Directive for the Prevention and Suppression of Money Laundering and Terrorist Financing, Altinvest must request documents which would be sufficient to understand you, as our Client (KYC), apply the Risk Based Approach (RBA) and to build-up the Economic Profile for each client. Each case will be examined individually by the AML Compliance Officer and in accordance with the Law and the internal policies established by Altinvest.

A risk-based approach (RBA) is central to the effective implementation of the AML/CFT legislation. It means that Financial Institutions identify, assess, and understand the ML/TF risks to which they are exposed, and implement the most appropriate mitigation measures.

The Economic profile is created individually for each of our clients. It reflects all economic activities relevant to the investment amount. For example, if the investment amount is EUR 125K, it means that the client should provide well-documented source of legally possessed EUR 125K, that will allow to understand the origin of funds, including (i.e., Audited Financial Statements for a company, Tax Returns for individuals, bank statements, etc.)

You may provide us with scanned copies of the certified true copy of the originals of the documents requested by sending us an email to info@alptinvestpro.com or via registered post at our business premises providing us also with the track number:

4 Annis Komninis Street,
Solea Building, Office 204
CY 1060, Nicosia, Cyprus,

Alternatively, you can provide us with the originals of the documents, and we can arrange to certify them as ‘true copy’ at our offices and return the originals to you. It is noted that all documents must be in English or Greek language. If the document is in another language, then official translation in English or Greek is needed.

All investors receive, free of charge, the latest Annual and Half-yearly report of the AIF (or RAIF) that the invested in, the Offering Documents of the Fund, and its Instruments of Incorporation. In case of an umbrella Fund, all investment compartments will share same Offering Document, Annual and Half-yearly reports.

Potential investors can receive all abovementioned documents upon request.

In addition, investors receive the Key Investor Information Document (KIID), the NAV report or any other Risk Reports, of the AIF/RAIF they have invested in, as soon as it is published by the Fund Administrator and according to the internal regulations and policies of each compartment.

The Fund shall prepare in accordance with the provisions of the AIF Law the following reports:

Annual report

Must prepare an audited annual report in accordance with IFRS which must be submitted to CySEC and made available to the unitholders no later than six months following the financial year end. Annual reports are prepared, audited, submitted and published in accordance with section 29 of the AIFM Law, which is applicable directly to AIFs which are externally managed by an AIFM and internally managed AIFMs, and mutatis mutandis to all other forms of AIFs.

Minimum content of annual report
•    a balance sheet or a statement of assets and liabilities of the AIF
•    income and expenditure account of the AIF for the financial year
•    a report on the activities of the AIF of the financial year
•    any material changes in the information disclosed to the unitholders during the financial year
•    the total amount of remuneration for the financial year and (where relevant) carried interest paid by the AIF, and the aggregate amount of remuneration
•    (Where applicable) the aggregate amount of remuneration broken down by senior management and members of staff of the AIFM, whose actions have a material impact on the risk profile of the AIF

Half yearly report

Half-yearly reports must be prepared in accordance with IFRS at the end of the first semester of each calendar year and submitted to CySEC, as well as made available to investors within two months of the end of the semester. CySEC has the discretion to issue a directive regarding the minimum content of the semi-annual report.

Altinvest is licensed and authorized by CySEC to manage investments under Alternative Investment Funds (“AIFs”) or Registered Alternative Investment Funds (“RAIFs”). All decision-makers (i.e., Portfolio Manager, Risk Manager, Compliance and AML Officer) in the company are highly experienced professionals and are holders of the CySEC Advanced Certification that prove their qualifications. Moreover, our Portfolio and Risk Management teams tend to keep the conservative approach to the investments. However, we would like to emphasize that alternative investments are subject to risk, and you can lose all invested funds.

The funds of investment compartments, under our management, may be invested in liquid (stocks, fixed income, etc.) or illiquid assets (i.e., private equity, real estate, etc.), in accordance with their investment strategy described in the Offering Documents.

To ensure that it can fulfil the investment objectives and the requirements of each project, the Fund Manager may set a lock-up period whose time-length is specified in the prospectus. Investors may transfer or assign their units with the Directors’ consent but cannot redeem their units until the expiry of the lock-up period, unless another provision applies as documented in the managed funds’ internal regulations, policies, and prospectus.

The lock-up period is typically calculated from the initial investment date or as may change by simple majority of votes cast at a general meeting or with the prior written approval of the investors of the relevant investment compartment.

The investment objectives and the rules of each of the funds or investment compartments are available to each of the investors, including the prospect investors, free of charge. Each investment compartment has its own strategy as stipulated in the terms of the offering memorandum and its supplements, or as a final distribution upon dissolution of the Fund. In the case that the fund or the investment compartment does not provide any dividends to investors, then all future income will be re-invested in the investment compartment, as part of its strategy.

Investors, however, should note that payment of any future dividends is not guaranteed and will be at the discretion of the external manager after considering various factors including the investment compartment’s operating results, financial condition, and current and anticipated cash needs.