Provision of regulatory and compliance advice and guidance to you on either a periodic basis or an ad hoc basis when required by you.

To undertake risk assessments and compliance reviews on either a periodic or an ad-hoc basis on site at your offices, including but not limited to:

• Internal Capital Adequacy Assessment Process (ICAAP)
• Risk Matrices
• Liquidity Risk Management
• Pillar 3 Disclosures
• Remuneration Code
• Stewardship Code
• Environmental Social and Governance Code
• Corporate Governance

An assessment of the type and scope of FCA Pt 4A Permissions required to undertake the investment services that you propose to conduct in the United Kingdom and to ensure that you meet your UK regulatory requirements for Authorisation.

Preparation of an appropriate Pt 4A Authorisation application with supporting documentation to accurately reflect your business model, including but not limited to:

• Collation and submission of the FCA Authorisation application
• Assistance with the regulatory and compliance aspects of the compilation of the Regulatory Business Plan
• Identification and advice on the required regulated activities, investment types, customer types, limitations and requirements of the Part 4A Permission Application
• Production of the Compliance Manual, Compliance Monitoring Programme, and Risk Analysis and Risk Management Programme
• Assistance with the apportionment of senior management responsibilities and preparation of the applications for Approved Persons
• Lead the relevant Authorisation correspondence with the FCA
• Development of appropriate Training and Competence arrangements
• Development of adequate and complete record-keeping arrangements
• Development of an appropriate process for regulatory reporting and notification requirements
• Development of appropriate Conduct of Business arrangements
• Development of arrangements for redress (complaints and compensation)
• Development of appropriate security and business continuity arrangements
• Development of a robust structure for compliance and corporate governance
• Development of appropriate Regulatory and Compliance Undertakings
• Development of the firm’s arrangements to satisfy and continue to satisfy the Threshold Conditions, including ongoing suitability and appropriateness of resources

The scope of the Alternative Investment Fund Managers Directive (AIFMD) is broad and, with a few exceptions, covers the management, administration and marketing of alternative investment funds (AIFs). Its focus is on regulating the Alternative Investment Fund Manager (AIFM) rather than the AIF.

An AIF is a ‘collective investment undertaking’ that is not subject to the Undertakings for the Collective Investment of Transferable Securities (UCITS) regime, and includes hedge funds, private equity funds, retail investment funds, investment companies and real estate funds, among others. The AIFMD establishes a European Union (EU) wide harmonised framework for monitoring and supervising risks posed by AIFMs and the AIFs they manage, and for strengthening the internal market in alternative funds.

The AIFMD also includes new requirements for firms acting as a depositary for an AIF.

LWF will undertake an assessment of the type and scope of firm subject to the AIFMD; prepare an appropriate AIFM Authorisation application with supporting documentation to accurately reflect your business model, including but not limited to:

• Collation and submission of the AIFM authorisation application
• Collation and submission of the Variation of Permission (VoP) notification for a full-scope UK AIFM; or for a small authorised UK AIFM; or for a small registered UK AIFM
• Collation and submission of the schedule of AIFs for a full-scope UK AIFM; or for a small authorised UK AIFM; or for a small registered UK AIFM
• Collation and submission of the Wholesale Investment Firm (WIF) application
• Assistance with the identification of the Senior Persons effectively conducting the business of the AFM
• Collation and submission of the Senior Persons registration
• Identification of the relevant AIFMD Marketing Permission and the collation and submission of the AIFMD Outward Passporting notification

The European Union Venture Capital Funds (EuVECA) Regulations are voluntary and facilitate cross-border marketing and fund-raising whilst sparing smaller funds the disproportionate costs and burden of authorisation under the Alternative Investment Fund Managers Directive (AIFMD).

EuVECA is only available to managers of Collective Investment Undertakings (CIUs) established in the European Union (EU) and falling below the AIFMD threshold of €500 Assets Under Management (AUM) (applicable to managers managing unleveraged, closed-ended Alternative Investment Funds (AIFs)) and subject to registration with the Regulatory Authority in their Member State.

LWF will undertake an assessment of the type and scope of firm subject to the EuVECA; prepare an appropriate registration application with supporting documentation to accurately reflect your business model, including but not limited to:

• Collation and submission of the European Venture Capital Fund (EuVECA) Managers Registration
• Assistance with the regulatory and compliance aspects of the compilation of the Regulatory Business Plan
• Assistance with the identification of the type of registered Alternative Investment Fund Manager (AIFM)
• Assistance with the identification of the Senior Persons effectively conducting the business of the AFM
• Collation and submission of the Senior Persons registration
• Assistance with the identification of the Alternative Investment Funds (AIFs)
• Completion of the schedule of registered AIFs
• Assistance with the calculation of funds under management to determine compliance with Regulation 9 (1) 9a) Thresholds
• Assistance with the collation of the investment strategy and objectives of the Funds
• Assistance with the determination of the Funds complies with the relevant investment conditions for qualifying as a European Venture Capital Fund (EuVECA)
• Assistance with the determination of capital invested in assets complies with Article 3 (e) qualifying investment criteria.
• Assistance with the Marketing Plan within the European Economic Area (EEA)

Ongoing provision of regulatory and compliance consultancy services, including independent compliance monitoring reviews, regulatory advice and guidance to you, including but not limited to:

• Periodic independent compliance monitoring, covering all relevant areas of regulatory responsibility
• Periodic compliance meetings, detailing monitoring findings and recommendations
• Regulatory and compliance guidance and advice
• Review and revision of internal regulatory registers and internal reporting forms
• Ongoing reviews and updates of the Firm's compliance and corporate governance arrangements, covering all regulatory and compliance documentation and structures
• Assistance with the completion of regulatory non-financial returns, forms and formal reports
• Execution and review of the compliance monitoring programme of delegated functions to outsourced entities if appropriate
• Support on individual specific issues – for example in dealing with a complaint; a suspicious transaction; or a financial promotion
• Review of marketing and promotional material

Initial analysis to identify higher risk areas of the business and weakness in your procedures.

An analysis of your business and providing regulatory compliance advice and guidance on your business model, specific issues and business development.

Provision of regulatory and compliance reports and management information to your Board of Directors or Management Committee, including but not limited to:

• Senior management
• Systems and controls
• Anti-money laundering, anti-bribery and corruption and financial crime
• Threshold conditions
• Approved persons and significant influence
• Appointed representatives, tied agents, introducers and other agents
• Operational risk reports
• Training and Competence

Assistance with the establishment and implementation of regulatory and compliance training and competence arrangements, including but not limited to:

• Policies and procedures
• Continuous Processional Development arrangements
• Competency assessments and appraisals
• Training opportunities or product risk guidance

Arranging appropriate training in regulations and compliance, including but not limited to:

• Anti-money laundering
• Anti-bribery and corruption

Assistance with the completion and submission of all regulatory financial returns, forms and formal reports to the FCA.

Undertake special projects at your request, including but not limited to the provision of regulatory and compliance guidance and advice on specialist fields ranging from:

• Variations to Part 4A Permissions
• Change in Controllers
• Operational readiness for an FCA supervisory visit
• Collation and response to an FCA thematic review
• Annual 'health checks'
• Updates and reviews
• Thematic monitoring
• Project management
• Regulatory due diligence
• Investigations
• Enforcement work
• File audits – checks to ensure that procedures are being followed and the identification of good practices and weaknesses

To ensure that your business meets its UK regulatory requirements, the provision and implementation and ongoing monitoring of the regulatory infrastructure, including but not limited to arrangements covering:

• Corporate Governance
• Compliance and Conduct of Business
• Approved Persons
• Training and Competence
• FCA Financials
• FCA Correspondence
• Risk Management Framework

Help with establishing policies and procedures – for example procedural manuals for recruitment, training and competence, complaints handling and anti-money laundering; which may also include templates for specific disclosure documents, fact-finds and registers.