Guernsey Expands Private Investment Funds Regime

The Guernsey Financial Services Commission (“GFSC”) has updated its Private Investment Fund (“PIF”) regime to expand the available PIF product options.

The Private Investment Fund Rules, 2021 (the “PIF Rules 2021”) were issued on 20 April 2021 together with guidance, and replace with immediate effect the prior Private Investment Fund Rules, 2016.

Three alternate PIF routes
Under the new PIF Rules 2021, there are now three alternate routes available for PIFs in Guernsey:

  • Route 1 – the POI Licensed Manager PIF: This is the existing Guernsey PIF which requires the PIF to have a Guernsey manager that is licensed by the GFSC. All PIFs registered prior to 20 April 2021 will continue to be registered under this route.

  • Route 2 – the Qualifying Private Investor PIF: This is a new route that does not require a GFSC-licensed manager. To use this route all investors will have to meet qualifying investor criteria which are designed to ensure investors are restricted to suitably sophisticated investors.

  • Route 3 – the Family Relationship PIF: This is also a new route that does not require a GFSC-licensed manager. This route enables a bespoke private wealth structure to be created as a PIF, requiring a family relationship between investors.

Although Route 2 and Route 3 do not require the appointment of a GFSC-licensed manager, one can be appointed if desired. Where a PIF takes the form of a limited partnership the general partner will generally need a licence even if the PIF is a Route 2 or Route 3 PIF (although note below regarding certain GFSC rules not applying to that licensed general partner). Where the manager or general partner needs to obtain a licence, application is made at the same time as the PIF registration application and is fast-tracked on the same one-business day turnaround.


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Matt SandersManaging PartnerT +44 (0) 1481 748
Kate StoreyPartnerT +44 (0) 1481 748
Chris Hutley-HurstSenior CounselT +44 (0) 1481 758