# BLK Finance — full FAQ

> 46 answers on Slovenian AIFM regulation, jurisdiction choice, fund
> structures and mechanics, investor onboarding and the four strategies.
> Source: https://blkfinance.com/faq/
>
> BLK Finance d.o.o. is a REGISTERED, SUB-THRESHOLD alternative investment fund
> manager under ZUAIS. Registration is not authorisation: there is no AIFMD
> marketing passport and no MiFID investment services. No registration number is
> published, because ATVP issues none in that register. Funds are for
> professional investors only. Nothing here is an offer or a recommendation, and
> capital is at risk.

## The firm & regulation

### What is BLK Finance?

BLK Finance d.o.o. is an alternative investment fund manager based in Ljubljana, Slovenia, registered with the Securities Market Agency of the Republic of Slovenia (ATVP) under the Alternative Investment Fund Managers Act (ZUAIS), the Slovenian transposition of AIFMD. It designs and manages customised alternative investment funds for professional investors, and it is the asset management arm of BLK Group. The firm is deliberately small. It manages a limited number of dedicated funds in four areas where the team and the wider group already operate — trade finance, EU real estate, technology serving fintech, and payment platforms — rather than running a broad product shelf. A mandate outside those four is declined rather than accommodated, because we do not intend to learn an asset class on a client’s money.

### What is an AIFM?

An AIFM is an alternative investment fund manager: the regulated entity responsible for managing an alternative investment fund. Under AIFMD, and under ZUAIS in Slovenia, the manager performs two core functions — portfolio management and risk management — and is accountable for the fund’s investment policy, its valuation, its investor reporting and its regulatory reporting. The distinction that matters is between the fund and the manager. The fund is the vehicle that holds the assets and in which investors subscribe; the AIFM is the firm answerable to the regulator for how that vehicle is run. Every AIF has exactly one AIFM. That manager is either fully authorised, or — where assets under management stay below defined thresholds — registered under the lighter regime.

### What is a registered AIFM, and how does it differ from a licensed AIFM?

A registered, or sub-threshold, AIFM manages assets below the AIFMD thresholds and is entered in a register kept by the national regulator instead of holding a full authorisation. It carries registration and ongoing reporting obligations but is not subject to the complete AIFMD regime, and it does not have the AIFMD marketing passport. A licensed AIFM is fully authorised and subject to the whole directive — including the depositary requirement, minimum own funds, remuneration rules and the full disclosure regime — and can passport marketing across the EEA. The trade-off is proportionality against reach. The registered regime exists so a focused, single-strategy fund sold to a handful of professional investors is not carrying compliance overhead designed for a manager running billions. What it costs you is the passport.

### What are the AIFMD and ZUAIS registration thresholds?

The registration regime applies where total assets under management do not exceed EUR 100 million including any assets acquired through leverage, or EUR 500 million where the funds managed are unleveraged and grant no redemption rights for five years from the date of initial investment. The two limits reflect different risk profiles: leverage amplifies exposure, so the ceiling is lower; a closed, unleveraged, long-locked fund poses less systemic risk and is given more room. The thresholds are calculated across everything the manager manages, not per fund. Crossing one obliges the manager to apply for full authorisation — which is why a registered manager should know where it sits well before it approaches the line, and why we will tell a sponsor when a proposed fund would take us past it.

### Who regulates BLK Finance?

The Securities Market Agency of the Republic of Slovenia — Agencija za trg vrednostnih papirjev, or ATVP — which maintains the register of alternative investment fund managers and supervises compliance with ZUAIS. The register we appear on is titled “AIFM – registered, not supervised”, and that wording is the regulator’s own. It repays reading precisely: entry in the register is a matter of public record and can be checked, but a registered sub-threshold manager is not subject to the ongoing prudential supervision that applies to an authorised firm. We publish a link to the register in the footer of every page so the claim can be verified rather than taken on trust. The ATVP is also the authority to which a complaint about us can be escalated if we do not resolve it.

### What is ZUAIS?

ZUAIS is the Zakon o upravljavcih alternativnih investicijskih skladov, the Slovenian Alternative Investment Fund Managers Act. It transposes Directive 2011/61/EU (AIFMD) into Slovenian law and governs the management and marketing of alternative investment funds in Slovenia, including the registration regime for sub-threshold managers. Because it is a transposition rather than a domestic invention, the concepts an EU allocator already knows carry across intact: the definition of an AIF, the definition of a professional investor, the manager’s duties and the threshold calculations are the directive’s. That matters in diligence. A German family office or a Dutch institution reading a Slovenian fund’s documents is reading the framework it reads everywhere else in the union, not a local regime it has to learn from scratch.

### Can BLK Finance market funds across the European Union?

Not under the AIFMD marketing passport, which is available only to fully authorised managers. Funds are made available to professional investors in accordance with the national rules that apply in each case, and never by public offering. In practice this shapes how mandates arise: they are typically investor-initiated, or they come from an existing relationship, rather than from outbound distribution. We would rather state that plainly than let an allocator discover it in diligence. If your requirement is to raise across several member states from a standing start, a registered sub-threshold manager is the wrong instrument, and an authorised AIFM in a passporting domicile is the right one.

### What is the difference between an AIFM and a ManCo?

“ManCo” is industry shorthand for a management company, and the two terms overlap without being identical. Under the UCITS regime the entity is formally the management company; under AIFMD it is the AIFM. A firm holding both permissions is often called a Super ManCo, and in Luxembourg and Ireland the word is also used loosely for any third-party firm providing management services to someone else’s fund. BLK Finance is a registered AIFM under ZUAIS: it manages alternative investment funds only. It does not manage UCITS, it is not a Super ManCo, and it does not hold the range of permissions a large third-party ManCo in Luxembourg would. If a mandate needs a UCITS management company, we are not the right firm and will say so on the first call.

## Jurisdiction & alternatives

### Why use a Slovenian AIFM rather than a Luxembourg one?

For many mandates you should not, and it is worth being direct about that. Luxembourg is the largest fund domicile in the European Union, with the deepest bench of administrators, depositaries, auditors and fund counsel, and a name a great many institutional allocators expect to see on a fund’s documents. If you are raising from institutions with a domicile policy, if you need the AIFMD passport to market across the EEA, or if the fund will grow past the sub-threshold limits, Luxembourg or Ireland is the correct answer. Slovenia suits a different shape of mandate: a focused, single-strategy fund for a defined group of professional investors, where the value sits in the manager understanding the assets rather than in the domicile’s brand, and where a proportionate regime is a feature rather than a compromise. Both are euro-area EU member states operating the same directive.

### Slovenia or Ireland — how should a sponsor choose?

The same way they should choose between Slovenia and Luxembourg, and the honest answer is usually the same. Ireland is a major EU funds centre with an established service-provider ecosystem, well-understood vehicles such as the ICAV, and an authorised-manager market built for scale and for passporting. It is the stronger choice for a fund that needs cross-border distribution, for an investor base that expects a mainstream domicile, or for a strategy heading well past the registration thresholds. What Slovenia offers is proportionality and proximity: a smaller regime for a smaller fund, and a manager close to the Adriatic, Central European and DACH markets where much of our origination happens. Choose on the fund’s actual shape — its size, its investor base and its distribution need — not on the domicile’s reputation.

### What is a RAIF, and can BLK Finance manage one?

A RAIF is a Reserved Alternative Investment Fund, a Luxembourg vehicle introduced in 2016. Its distinguishing feature is that the fund itself is not subject to direct product approval by the Luxembourg regulator; supervision comes indirectly, through the requirement that the RAIF appoints a fully authorised AIFM. That requirement answers the second half of the question: no, BLK Finance cannot manage a RAIF. We are a registered sub-threshold manager, not an authorised one, and appointing us would not satisfy the condition on which the entire RAIF structure rests. If a RAIF is genuinely the right vehicle for your strategy, what you need is an authorised Luxembourg AIFM — and we would rather point you there on the first call than have you discover it in structuring.

### Is a Slovenian AIF recognised elsewhere in the European Union?

The fund and the manager exist under EU law — ZUAIS is the Slovenian transposition of AIFMD — so the vehicle, the manager’s duties and the definition of a professional investor are the ones recognised across the union. Recognition of the framework is not the same as a right to market, though, and that distinction is the one that matters commercially. Because we are registered rather than authorised, we do not hold the AIFMD passport, so a fund we manage cannot be marketed across the EEA on the strength of a single notification. Whether it can be made available to an investor in another member state depends on that state’s own rules. An allocator elsewhere in the EU can invest; what does not exist is a passport that lets us go looking for them.

### How can a fund be offered to investors without an AIFMD marketing passport?

Through the national private placement rules of the member state concerned, and through investor-initiated contact. The passport is a distribution mechanism, not a precondition of an investment: an investor who approaches a manager on their own initiative is generally not being “marketed” to in the directive’s sense, which is why the confirmation on our contact form records that you came to us unprompted. Beyond that, availability depends on where the investor sits, because each member state operates its own private placement regime and they differ materially in what they require and permit. In practice this means mandates here are relationship-led rather than campaign-led, and it is one reason the firm stays small. It also means we assess, per investor, whether a fund can properly be made available to them at all.

## Fund structures & mechanics

### What is a fund of one?

A fund of one is an alternative investment fund with a single investor. The structure gives that investor the governance of a fund — an independent administrator, an appointed auditor, a written investment policy, a defined valuation methodology and a regulated manager answerable for all of it — without pooling their capital with anyone else’s. It is a large part of what we do. The appeal for an allocator is control with oversight: the investment policy, concentration limits, leverage, reporting cycle and fee basis are negotiated bilaterally before launch rather than accepted off a shelf, and with no other investor there is no dilution of terms and no blind-pool risk. The trade-off is cost. A fund carries administration, audit, valuation and legal expense largely regardless of size, and a fund of one carries all of it alone.

### What is an umbrella fund, and what is a compartment?

An umbrella fund is a single legal vehicle divided into ring-fenced sub-funds, each of which is called a compartment. Each compartment has its own assets, its own investors, its own net asset value, its own investment policy and — this is the point — its own liabilities. Ring-fencing means the obligations of one compartment are not met from the assets of another, so trouble in one strategy or one project does not reach across into the others. It matters for two reasons. An investor can take exposure to one strategy without acquiring any part of the rest, which is what lets a single umbrella serve several unrelated mandates. And a sponsor can add a second project or corridor without establishing an entirely new fund. Ring-fencing is only as strong as its documentation, so it is set out in the fund rules at launch.

### When is an SPV used rather than a compartment?

A compartment ring-fences at the level of the fund; an SPV, or special purpose vehicle, is a company beneath it holding a specific asset together with its financing and its contracts. The two are complements rather than alternatives, and real estate shows why. A development is typically held in its own SPV: the company owns the site, signs the building contract, borrows the senior debt and grants the security. That containment is where project risk actually sits, and it is also what makes a single project saleable or refinanceable without disturbing anything else. So a real estate mandate commonly runs fund, then compartment, then one SPV per project. A trade finance programme more often needs the compartment but not the SPV, because its exposures are contractual rather than asset-owning.

### What is a capital call?

A capital call, also called a drawdown, is the notice by which a fund requires investors to pay in part of the capital they have already committed. It exists because most closed-ended alternative funds do not take all the money up front. An investor signs a commitment — a binding undertaking to provide up to a stated amount — and the manager then calls that capital as it is genuinely needed: to fund a drawdown on a development, to settle a receivables purchase, to complete an investment. The mechanics are fixed in the fund documents before subscription and typically cover the notice period, the permitted purposes, the payment mechanism and the consequences of failing to fund a call, which are usually severe. For the investor, uncalled commitment stays on their own balance sheet earning elsewhere — at the cost of having to be ready to fund at short notice.

### What does a fund administrator do?

The fund administrator is the independent firm that keeps the fund’s books. Its work typically covers calculation of the net asset value, maintenance of the investor register, processing of subscriptions and redemptions, preparation of financial statements for audit, and the operational side of capital calls and distributions. The word that matters is independent. The administrator is appointed by the fund and is separate from the manager, so the numbers investors receive are not produced by the same people who make the investment decisions. That separation is much of what distinguishes a fund from a private arrangement, and it is often the specific thing a sponsor’s existing investors are asking for when they push for a fund structure. The manager oversees the administrator’s work; it does not replace it.

### Does an alternative investment fund need a depositary?

Under the full AIFMD regime an authorised manager must appoint a depositary for each fund it manages, responsible for safekeeping of assets, monitoring of cash flows and oversight of certain manager duties. That requirement does not apply in the same form to a registered sub-threshold manager, and it would be misleading to imply otherwise. What we do instead is state the arrangements plainly: for every fund we manage, the safekeeping, administration and audit arrangements are set out in that fund’s own documents and disclosed to investors before subscription, so nobody has to assume a protection exists. If your mandate requires a full AIFMD depositary — because your own rules demand it, or because your investors do — that points to an authorised manager, and we will say so rather than talk around it.

### What is a real estate fund structure?

In the shape we use, three layers. The fund is the AIF managed by BLK Finance, carrying the investment policy, the valuation policy and the reporting cycle. Beneath it sits a compartment: a ring-fenced sub-fund holding one strategy or one group of projects, with its own investor register and NAV. Beneath that sits an SPV per project — a company that owns the asset, carries its financing and signs its contracts. The purpose of the layering is containment. Development risk is concentrated and lumpy, and one scheme running into planning, construction or market trouble should not be able to reach the investors in another. Layering also makes an individual project saleable or refinanceable on its own terms. The alternative, a single pooled vehicle holding several projects directly, is simpler to set up and materially harder to exit.

## Strategies

### Which strategies does BLK Finance manage?

Four: trade finance financing, including receivables, supply-chain and commodity flows; real estate projects within the European Union; technology supporting the fintech sector; and compliant payment platforms built on new technologies. Each strategy runs in a dedicated fund or a ring-fenced compartment rather than a blended pool, so an investor takes the exposure they came for and no other. The four are not a product shelf assembled to look broad. They are the areas where the team and the wider BLK Group have operating history, existing counterparties and a formed view on how each one goes wrong — the group runs regulated payment, e-money and digital-asset businesses, which is why two of the four sit in that sector. A strategy outside these four is declined rather than accommodated.

### What is a private credit fund?

A private credit fund lends directly to businesses rather than buying traded debt securities, taking the credit exposure onto the fund’s own book and generally holding it to maturity. The category spans a wide range — direct lending, mezzanine, speciality finance, asset-based lending — and the risks differ sharply between them. Our own private credit exposure is trade finance, which sits at the short, self-liquidating end: financing against documented commercial transactions where repayment comes from completion of the underlying trade rather than from a refinancing. That shortens duration and ties repayment to an identifiable event, but it does not make the asset class safe. Private credit is illiquid by construction, valuations are estimates between transactions, and in trade finance specifically the dominant risks are documentation and fraud rather than modelled default.

### What is a trade finance fund?

A fund that provides short-term financing against commercial transactions — invoices, purchase orders, inventory in transit or documented commodity shipments. Repayment comes from completion of the underlying trade rather than from refinancing, so exposures are typically 30 to 180 days and are described as self-liquidating. The attraction for an allocator is duration, and the fact that repayment is tied to an identifiable event rather than to market conditions. The risk is not where a credit model would put it. Losses in this asset class rarely come from a modelled default; they come from paperwork describing goods that were never shipped, the same receivable financed twice, or a concentration nobody added up. That is why the controls are procedural — verifying the trade before funds move, controlling the cash path, testing concentration limits at every drawdown — rather than priced for.

### What is receivables finance?

Receivables finance is funding advanced against money a business is already owed. A company that has delivered goods or services and issued an invoice may wait 30, 60 or 90 days for payment; receivables finance releases most of that value immediately, with the balance settled when the customer pays. It appears in several forms — invoice discounting, factoring, outright receivables purchase — differing mainly in who collects and whether the customer is told. From the fund’s side the credit question is usually about the obligor rather than the supplier, because it is the obligor who ultimately pays. That is why verification matters more than pricing: confirming the delivery happened, that the invoice is valid and unencumbered, that it has not already been financed elsewhere, and that collections route to an account the fund controls or monitors.

### What is supply chain finance?

Supply chain finance, sometimes called reverse factoring, finances the gap between a confirmed order and payment, generally anchored on the credit of a large buyer rather than that of its smaller suppliers. A supplier is paid early against the buyer’s approved payable; the buyer settles on its normal terms. The structural attraction is that the exposure sits against a stronger counterparty than the supplier would command on its own. The structural risk is concentration: a programme built around one anchor buyer is, in credit terms, largely a single exposure however many suppliers it touches. Purchase-order and pre-shipment finance sit adjacent to it, funding production or shipment before an invoice exists — earlier in the cycle, with performance risk still to run, and correspondingly harder to underwrite.

### Which European real estate markets does BLK Finance cover?

Markets the team can reach and monitor in person: Slovenia, the Adriatic region including Croatia, Central Europe and the DACH markets. The coverage is regional by choice rather than by capacity. Development risk is local — planning, permitting, contractor solvency, presale demand and the realistic exit are specific to a market and often to a city — and a manager who cannot visit a site, meet the contractor or read the land register position is underwriting from a spreadsheet. Projects are held in dedicated SPVs within a fund or compartment. We would rather decline a scheme in a market we do not cover than take it and learn on it, and a sponsor is better served by a manager who already knows their planning authority.

### What kind of fintech companies does BLK Finance invest in?

Business-to-business technology companies that sell into regulated financial institutions rather than consumer fintech brands: onboarding and KYC automation, transaction monitoring and risk intelligence, core ledger and wallet infrastructure, and treasury and reconciliation tooling. Diligence is run from the buyer’s perspective, because group entities are themselves buyers of exactly this software. The questions that decide it are the ones a regulated purchaser asks — whether the product would survive a security and compliance review, whether the revenue is contracted or merely hoped for, whether a rule change is an existential threat or a roadmap item, and who the credible acquirers are. Selling into regulated institutions means long procurement and heavy scrutiny, which is simultaneously the risk in the investment and the moat around a company once it is in production.

### Does BLK Finance invest in crypto assets?

The payments strategy invests in businesses and infrastructure, not in speculative token exposure. Where a platform uses digital assets or stablecoins for settlement, the investment case rests on regulated flows, custody arrangements and auditability rather than on token price appreciation. The distinction is deliberate and it is a hard line. Settlement rails that move value across borders and produce a complete audit trail are infrastructure with a business model behind them; directional exposure to crypto-asset prices is something else, and it is not a strategy we manage. Where digital assets feature in a portfolio company’s model, values are volatile and custody arrangements carry their own risks, and both are underwritten as risks rather than treated as upside.

## Investing & onboarding

### Who can invest in a fund managed by BLK Finance?

Professional investors only, as defined by ZUAIS and MiFID II: regulated financial institutions, large undertakings meeting the size tests, public bodies, and investors who qualify for elective professional classification — a category that includes many family offices, investment holding companies and experienced individuals. Funds are not offered or marketed to retail investors, and that is a legal boundary rather than a preference. It shapes the whole site: the professional-investor confirmation on arrival, the absence of any public offering, and the fact that fund-specific material is not shared until classification has been assessed and documented. If you are unsure whether you qualify, say so on the enquiry form. Classification is ours to determine, not yours to assert.

### How does professional investor classification work?

Some investors are professional per se, by virtue of what they are: credit institutions, investment firms, insurers, collective investment schemes and their managers, pension funds and other authorised or regulated financial entities, national and regional governments, and public bodies managing public debt. Large undertakings qualify per se where they meet the size tests. Everyone else may be treated as professional only on request, and only where they meet the criteria and confirm in writing that they accept the consequences — which principally means giving up protections a retail client keeps. We assess and document classification before any fund-specific material is shared, and we record the basis for it. Getting this wrong is not a paperwork problem: it determines whether we are permitted to discuss a fund with you at all.

### Who qualifies as an elective professional client?

An investor who is not professional per se may be treated as one on request, subject to both a qualitative and a quantitative test under the MiFID II client categorisation rules. The qualitative side assesses the investor’s expertise, experience and knowledge, and whether they can realistically make their own investment decisions and understand the risks involved. The quantitative side requires at least two of three conditions: a portfolio of cash and financial instruments exceeding EUR 500,000; transactions of significant size on the relevant market at an average frequency of ten per quarter over the previous four quarters; or at least one year in a professional position in the financial sector requiring knowledge of the transactions concerned. The investor must also request the classification in writing and acknowledge the protections they give up.

### What is a MiFID professional client?

MiFID II divides clients into retail clients, professional clients and eligible counterparties, and its client categorisation rules set out who falls where. Professional clients are those presumed to possess the experience, knowledge and expertise to make their own investment decisions and properly assess the risks they incur. The category covers entities required to be authorised or regulated to operate in financial markets; large undertakings meeting the size tests on balance sheet total, net turnover or own funds; national and regional governments and public bodies managing public debt; central banks and international institutions — plus investors admitted on request as elective professionals. ZUAIS follows the same definitions, which is why a professional investor elsewhere in the EU is recognisable as one here without a separate local test.

### What does investor onboarding involve?

Professional-investor classification, AML and KYC checks including identification of beneficial owners and source of funds, review of the fund documentation, execution of subscription documents and agreement of capital call mechanics. The full document list is provided at the first substantive meeting, deliberately and in writing, because late AML requests are the most common cause of a delayed subscription. Source-of-funds evidence is usually the item that takes longest, particularly for a family office or holding company with a layered ownership structure, and it is far easier to begin assembling in week one than in the week of a close. Nothing in the process is unusual for a regulated fund. What varies between managers is whether you are given the whole list at the start or discover it in instalments.

### What is the minimum investment?

There is no single figure. Minimum commitment is set per fund and depends on the strategy, the number of investors and the cost base of the structure, and it is stated in the fund documents. The arithmetic behind it is worth understanding, because it is the same arithmetic that decides whether a dedicated structure makes sense at all. A fund carries administration, audit, valuation and legal costs largely independent of its size, so those costs weigh far more heavily on a small fund than a large one. Below a certain commitment the structure consumes a meaningful share of the return it exists to protect. We would rather show a prospective investor that calculation and decline the mandate than charge a fee for a vehicle that cannot work economically.

### How are fees charged?

The fee basis is agreed and documented per fund before subscription: typically a management fee and, where relevant to the strategy, a performance-related element, alongside disclosed operating costs such as administration, audit, valuation and legal fees. There are no undisclosed charges, and the full basis appears in the fund documents, which prevail over anything stated here or elsewhere on this site. Two things are worth negotiating hard at launch, because launch is the only point at which an investor has real leverage: what the performance element is measured against, and which costs sit inside the management fee rather than being charged to the fund on top of it. We would rather have that conversation during structuring than field it as a complaint in year two.

### What reporting do investors receive?

A reporting pack agreed at launch and written into the fund’s terms: net asset value and position-level reporting each NAV cycle, quarterly manager commentary covering portfolio developments, pipeline and risk limit utilisation, annual audited financial statements prepared by an independent auditor, and notification of material events such as limit breaches, significant valuation changes, service provider changes, litigation or default in the portfolio. Regulatory reporting is made to the ATVP for the funds managed. Content and frequency vary by strategy — a trade finance programme with 60-day exposures reports differently from a development measured in years — but the commitment is fixed before subscription rather than settled later. Position-level means position-level: the reporting shows what the fund holds, not a category summary.

### How liquid is an investment in one of these funds?

Assume illiquid unless the fund documents say otherwise, and read them rather than inferring from the asset class. Real estate and private technology positions are long-dated by construction: a development completes when it completes, and a private company is realised at a transaction that may be years away. Trade finance is where intuition most often misleads. Its exposures are short-dated at asset level — commonly 30 to 180 days — but that does not make the fund redeemable, because a revolving programme reinvests as exposures mature and unwinding it takes as long as the book takes to run off. Liquidity terms, including any lock-up, notice period, redemption mechanics and gating provisions, are defined per fund and fixed before subscription.

## Sponsors & structuring

### How do I start an investment fund?

In outline: settle the strategy and the investor base, choose a domicile and a vehicle, appoint a manager, draft the fund rules and investor documentation with counsel, appoint the administrator, auditor, valuer and bank, complete the regulatory notification, then onboard investors and hold a first close. The step most sponsors underestimate is the manager. An AIF must have an AIFM, and establishing your own means a registration or authorisation process, qualified staff, capital, written policies and permanent supervisory overhead — months of work and a fixed annual cost a first fund often cannot carry. That is precisely the problem a third-party AIFM solves. The step most sponsors overestimate is the documentation, which is largely a known quantity once the structure and the economics are genuinely settled.

### What service providers does a fund need?

At minimum: a manager (the AIFM), an administrator to calculate NAV and keep the investor register, an auditor for the annual financial statements, legal counsel to draft the fund rules and investor documentation, and banking. Depending on the strategy and the domicile you may also need a valuer where assets are not readily marked, a depositary, a tax adviser, and local counsel in each jurisdiction where assets sit. Two points sponsors often miss. These are appointments of the fund, not of the sponsor, and they must be genuinely independent of the manager for the governance to mean anything. And their combined cost is largely fixed rather than proportional to size, which is why the scale and duration of a proposed fund have to justify the structure before anything is drafted.

### Does BLK Finance act as a third-party AIFM?

Yes. Acting as manager of a fund whose strategy and origination come from a sponsor is what the industry calls a third-party AIFM, an outsourced AIFM or fund hosting. The sponsor contributes the strategy, the pipeline and the sector expertise; BLK Finance provides the registered manager, the governance framework, the risk function and the reporting, and holds the investment decision within the policy agreed at launch. The arrangement is defined contractually and disclosed to investors. One point in it is not negotiable: the manager cannot delegate away the responsibility it is registered to carry. A sponsor who needs the final investment decision to rest with them does not want a third-party AIFM — they want their own manager, and that is a legitimate answer we will point them towards.

### I have investors and a strategy but no AIFM. What are my options?

Three practical routes. Establish and register your own manager: full control and your own economics, at the cost of a registration or authorisation process, qualified staff, capital, policies and permanent supervisory overhead — which suits a large, repeatable programme. Use an existing manager as a third-party AIFM: the regulatory wrapper, governance and reporting already exist, and you contribute origination and strategy expertise under a defined, disclosed arrangement, with investment decisions resting with the manager — which suits a first or focused fund. Or keep the arrangement outside a fund structure altogether, as a club deal, joint venture or direct co-investment: simpler and cheaper for a single asset with two or three known investors, with correspondingly less governance and a hard limit on the investors you can accept.

### How long does it take to launch a customised AIF?

It depends on the strategy, the asset class, the counsel and service providers involved and the regulatory notifications required, and we do not quote a standard timetable because any single figure would be misleading. What we can say is which part you avoid. Because the manager, the governance framework and the reporting infrastructure already exist, a sponsor using a third-party AIFM skips the months of work involved in establishing and registering their own. An indicative timetable is agreed at the structuring stage, in writing, before documentation is drafted — and in our experience schedules slip on investor AML, and on decisions the sponsor has not yet made about economics, far more often than on drafting or on the regulator.

### What would make you decline a mandate?

A strategy outside our four areas, because we do not learn an asset class on your deal. An investor base that cannot be classified as professional, since retail distribution is outside our scope entirely. Economics too small to carry the cost of a fund — and we will show you that arithmetic rather than simply assert it. Counterparties that fail AML, sanctions or beneficial-ownership screening, which is not negotiable at any size. A structure whose purpose is to make an offer look regulated rather than to be governed properly. And investors who have been told a return is fixed or guaranteed: if that has been said, the mandate is not one we can take on at any price. A fast no is worth more to both of us than a slow maybe.

## Group & boundaries

### Does BLK Finance provide investment advice or manage individual portfolios?

No. As a registered AIFM it does not provide MiFID investment services. It does not give investment advice, does not manage individual client portfolios on a discretionary basis, does not receive or transmit orders, and does not act as a placement agent for third parties. Its activity is the management of the alternative investment funds it manages, and nothing on this website should be read as a personal recommendation. The distinction is worth stating precisely, because “managing money for an investor” describes both a discretionary mandate and a fund of one, and only the second is within our permissions. If what you want is a segregated managed account under a discretionary agreement, that is a MiFID service and you need a firm authorised to provide it.

### What is the relationship with VIP360, XCHANGE360 and BLK Advisory Services?

They are separate brands and legal entities within BLK Group. VIP360 covers payments and e-money through FCA- and FINTRAC-regulated entities; XCHANGE360 covers digital-asset settlement and custody, with Swiss operations AML-supervised through ARIF, a FINMA-recognised self-regulatory organisation rather than a prudential licence; BLK Advisory Services covers corporate and payments advisory. BLK Finance does not provide any of those services. Each is contracted with the entity concerned, under its own licence and terms, and the contracting entity and its regulatory status are disclosed before onboarding. The commercial value of the group is real — a portfolio company can be introduced to payment rails, a trade corridor can be paid through a licensed entity — but an introduction is an introduction, and it forms no part of managing any fund.

### How are conflicts of interest within the group managed?

Through the conflicts of interest policy of the relevant fund. Related-party transactions, including any dealing between a fund’s portfolio company and a group entity, are identified, assessed and disclosed to investors — or not entered into. Being part of a regulated operating group is treated as both an advantage and a conflict to be managed in the open, and pretending otherwise would be the fastest way to lose an allocator in diligence. The specific exposures are easy to name: a fund investing in payments technology sits alongside group businesses that buy payments technology, and a trade finance fund may pay a corridor through a licensed group entity. Where such a dealing happens it is on arm’s-length terms, assessed under the fund’s policy, and disclosed. Where it cannot be, it does not happen.

---

Generated from https://blkfinance.com/faq/. Terms of use and risk warnings: https://blkfinance.com/legal/