Regulated scope
Most managers publish the first list. Publishing both is faster for everyone: a professional investor knows in one page whether we are the right counterparty, and nobody spends three calls discovering a boundary.
BLK Finance d.o.o. is entered in the register of alternative investment fund managers maintained by the ATVP under ZUAIS, the Slovenian transposition of AIFMD, and operates as a registered — sub-threshold — manager.
Acting as manager of someone else’s fund strategy is what the market calls a third-party AIFM, outsourced AIFM services or fund hosting. That is the arrangement described below, with the perimeter around it stated in full.
46 detailed questions answeredWhere a client needs something on the right-hand list, we say so and, where relevant, introduce a licensed BLK Group entity or an independent provider. Those services are contracted directly with that provider under its own permissions and terms — they are not services of BLK Finance and do not form part of the management of any fund.
In detail
01
The core regulated function. A dedicated fund for one professional investor or a small defined group, with portfolio management and risk management performed by us inside an investment policy agreed with the investor and documented before capital is called.
02
Choosing the vehicle and jurisdiction of the fund, drafting rules and investor documentation with counsel, appointing administration, audit, valuation and banking, and completing the ATVP notification for the fund.
03
Ring-fencing strategies, projects and investor groups so exposures cannot contaminate each other — including project SPVs for real estate and programme vehicles for trade finance corridors.
04
A risk management function functionally separate from portfolio management, documented limits monitored at transaction level, a valuation policy set at launch, and independent valuation input where the asset class requires it.
05
Professional-investor classification, AML and KYC including source of funds and beneficial ownership, subscription documentation, capital call mechanics and maintenance of the investor register.
06
Periodic investor reporting on an agreed cycle, annual audited financial statements, regulatory reporting to the ATVP, and ongoing oversight of every delegated service provider.
The registered regime
AIFMD, and therefore ZUAIS, provides a proportionate regime for managers below defined thresholds. It is a deliberate design choice for focused, single-strategy funds sold to professional investors — not a loophole, and not a substitute for full authorisation.
We would rather an allocator understands this before a first meeting than discovers it in diligence.
The registration regime applies where assets under management stay below EUR 100 million including assets acquired through leverage, or below EUR 500 million where the funds are unleveraged and grant no redemption rights for five years from initial investment. Crossing a threshold requires the manager to seek full authorisation.
A registered manager cannot passport marketing across the EEA. Funds are made available to professional investors under the national rules that apply in each case, and never by public offering. In practice, mandates are typically investor-initiated or arise from an existing relationship.
Registration with the ATVP, ongoing reporting on the funds managed, notification of material changes, AML obligations, and governance appropriate to the activity. Where a fund’s own documents commit us to a higher standard, that standard applies.
The full AIFMD depositary requirement applies to authorised managers. For funds we manage, safekeeping, administration and audit arrangements are set out in the fund documents and disclosed to investors before subscription, so nobody has to assume what exists.
Beyond our perimeter
A fund conversation often uncovers a need that is not fund management: a corridor that needs paying, a settlement problem, a corporate structure that should exist before capital arrives, or a technology gap. BLK Group holds those capabilities in separate licensed entities. We introduce; they contract; you always know which entity you are dealing with and under which permission.
VIP360
Dedicated IBANs, e-money wallets, card programmes, SEPA and SWIFT remittance and multi-currency FX through FCA- and FINTRAC-regulated entities.
XCHANGE360
Crypto and stablecoin acceptance, OTC execution, custody and payout. Swiss operations AML-supervised through ARIF — not a prudential licence.
BLK Advisory
Payments strategy, EU corporate setup routes, cross-border structuring, VAT and VIES oversight, receivables processes and M&A support.
BLK Tech · VIPTECH
White-label wallets, payment gateways, fraud prevention, digital-asset custody and compliance SaaS for regulated institutions.