Regulation & Governance

Gordian Capital

Singapore Private Ltd
Registration Number: 200517499Z

Holder of a Capital Markets Services license (No. CMS100394-1) for fund management for accredited & institutional investors issued by the Monetary Authority of Singapore ("MAS")

Filed with the United States Securities and Exchange Commission (SEC) as an Exempt Foreign Advisor. (CRD# 281555 | SEC# 802-108139)

regulation

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The licensing and reporting requirements that asset managers and other financial industry participants must meet in order to be able to provide financial services have dramatically increased globally since the 2008 financial crisis. Singapore’s regulator, the Monetary Authority of Singapore (“MAS”) is now widely recognised as the regulator that sets the highest bar in Asia for fund management and other licensed or regulated activities: it is acknowledged as Asia’s “gold standard

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New regulations came into effect on 7 August 2012 as the fund management licensing framework under Singapore law was amended to require fund managers either to be registered as a Registered Fund Management Company (“RFMC”) or to be licensed as a Capital Markets Services (“CMS”) license holder for fund management. Asset management firms must register as a CMS license holder if they manage in excess of SG$250 million. Below that level, they can register as an RFMC.

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Gordian Capital takes the licensing regime under which we operate and our obligations very seriously and has developed a culture of compliance. Our Chief Risk Officer, who serves as our Compliance Officer is also an Executive Director serving on the Board of Directors. As such, he is empowered with the necessary authority required to conduct & maintain a focused & professional compliance program. The compliance function is closely aligned with the business & operational heads and is a core part of the business decision process.

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The Administrator of each fund performs a standard KYC/AML check on every potential investor. In addition, Gordian Capital performs its own in-house detailed KYC/AML review. On an annual basis our Compliance Officer leads an internal team that perform a full KYC/AML check and conducts a tax risk assessment on all investors. All our investment professionals, each of whom is individually registered with the MAS, undergo an annual Fit and Proper review as well as KYC/ AML training. All members of our client-facing Investment Operations team undergo the same training.

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The licensing and reporting requirements that asset managers and other financial industry participants must meet in order to be able to provide financial services have dramatically increased globally since the 2008 financial crisis. Singapore’s regulator, the Monetary Authority of Singapore (“MAS”) is now widely recognised as the regulator that sets the highest bar in Asia for fund management and other licensed or regulated activities: it is acknowledged as Asia’s “gold standard”.

Governance

Gordian Capital focuses on best corporate governance practices. We take an ethical approach to the way we conduct business and align our business goals with those of our clients be they Portfolio Managers, investors, corporate or families.

Our firm is suitably structured to effect good corporate governance and we have reporting systems structured to provide transparency and accountability for our clients and regulators.

Our objective is always to work in the best interests of our clients. We have internal controls, policies & procedures that include, but are not limited to:

  • Handling of conflicts of interest
  • Privacy
  • Confidentiality
  • Data Protection
  • Valuation
  • Compliance
  • Internal Audit
  • Insider Trading
  • Personal Trading
  • Disclosure

The result is a culture of compliance and best practices to serve & benefit all our stakeholders.

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Risk Management

Our risk management process starts with the integrity of our Portfolio Managers and professional counterparties. We only engage and work with reputable counterparties, leading institutional investors and experienced Portfolio Managers.

Once funds are established, Portfolio Managers of liquid strategies have access to derivation, a leading multi-strategy, multi-asset Portfolio & Risk Management system launched in 2001. In April 2016, derivation became part of the Linedata group, a listed financial services & technology company. 63,000 finance professionals in 50 countries currently use Linedata technologies to manage their businesses on a daily basis.

A team independent from the Portfolio Managers, performs daily risk checks to make sure the portfolio’s assets are in line with the mandate and to identify asset or style drift.

Regular reviews are performed on portfolios of illiquid assets by a team independent from the Portfolio Managers to confirm conformity with mandate.