Who regulates the fund and who must be licensed: regulators, managers and custodians by domicile

Fund regulation works on two layers in every domicile: the vehicle is registered or authorised by a registry or regulator in the place where it is formed, and the manager is licensed or authorised by the regulator where it carries on business. The two layers can sit in different countries. A Singapore VCC must have a manager regulated by MAS, while a Cayman fund is often run by a manager licensed in Singapore, Hong Kong or London. This page sets out, domicile by domicile, who registers the fund, what the manager must hold, whether a custodian is mandatory and who carries anti-money-laundering (AML) duties at fund level.

This page compares legal and regulatory features; it does not rank domiciles.

Two layers: vehicle registration and manager licensing

The first layer is vehicle status. A registry gives the fund legal existence (ACRA in Singapore, the General Registry in the Cayman Islands, the Luxembourg trade and companies register, the Central Bank of Ireland acting as registrar, the Hong Kong Companies Registry). A financial regulator may then register or authorise the fund as an investment product, depending on who it is offered to: CIMA for Cayman mutual and private funds, the CSSF for most Luxembourg regulated funds, the Central Bank of Ireland for UCITS and AIFs, the SFC for every OFC.

The second layer is manager status. The firm that takes investment decisions needs a licence where it operates: a capital markets services licence for fund management (or an exemption) in Singapore, Type 9 asset management in Hong Kong, authorisation as an alternative investment fund manager (AIFM) or UCITS management company in the EU.

Three consequences follow:

1. A fund registered in one place can be managed from another, so two regulators may be involved.
2. Some vehicles must use a locally regulated manager (VCC, OFC); others accept a manager anywhere, subject to that manager's home rules (Cayman funds in general).
3. Distribution adds a third set of rules where investors live, covered on Investor perception and distribution reach.

Domicile by domicile: who registers and who supervises

Sources are listed in the page references. "Confirm with counsel" marks points this site has not verified against a primary text.

The fund-level regulator and manager rows differ most. In Singapore, ACRA creates the VCC but supervision runs mainly through the MAS-regulated manager and the AML notice. Luxembourg splits internally: the CSSF supervises a SICAV as a product, while a RAIF relies on its authorised AIFM. Hong Kong also splits: the SFC registers every OFC, whereas an LPF has no product regulator. Ireland is the only domicile where one body acts as both registrar and authoriser. Read the custody row with care: a mandatory custodian (Hong Kong OFC) and a custodian-or-title-verification rule (Cayman private funds) are different obligations.

Manager licensing: what the decision-maker must hold

Singapore. ACRA's Step 2 page on directors and key officers (last updated 29 January 2026) says every VCC must appoint one permissible fund manager, in one of three categories: a licensed fund management company holding a capital markets services licence for fund management under the Securities and Futures Act; a fund management company registered under paragraph 5(1)(i) of the Second Schedule; or a financial institution exempted under sections 99(1)(a) to (d) of the SFA, such as a licensed bank. At least one director must be ordinarily resident in Singapore, and at least one director must be a qualified representative or a director of the fund manager; ACRA notes that the same person may satisfy both (ACRA Step 2 page, 29 January 2026). Detail on manager categories sits on vccfund.com.sg.

Hong Kong. An OFC's investment manager must be licensed or registered for Type 9 regulated activity, and the OFC needs at least two directors who are natural persons, one of them independent (SFC, OFC structure). An LPF's investment manager must be a Hong Kong resident aged at least 18, a company or a registered non-Hong Kong company; if it carries on a regulated activity in Hong Kong, it needs an SFC licence or registration (Companies Registry FAQ Q43–Q44).

Luxembourg. According to CMS guidance (July 2024), a RAIF must appoint an authorised AIFM and cannot be internally managed. The CSSF reported 281 authorised investment fund managers as at 31 August 2026.

Ireland and Cayman. Irish UCITS and AIF ICAVs are managed under EU management-company and AIFM rules. For Cayman funds, the manager's licence is set where the manager operates.

Custody and safekeeping

Custody rules differ more than most comparisons suggest.

• Hong Kong OFC: "all the scheme property of an OFC must be entrusted to a custodian" (SFC, OFC structure). This applies to private OFCs as well as public ones.
• Cayman private funds: section 17 of the Private Funds Act (2025 Revision) requires a custodian to hold custodial assets in segregated accounts and verify title to other assets. A fund can instead notify CIMA that a custodian is neither practical nor proportionate; it must then appoint an administrator, another independent third party or, with safeguards, the manager to verify title. Section 18 adds cash monitoring, section 16 requires valuations at least annually, and section 13 requires an annual audit by a CIMA-approved auditor.
• Luxembourg RAIF: a depositary with a registered office or branch in Luxembourg (CMS).
• Ireland: EU depositary rules apply to UCITS and to AIFs with an authorised AIFM; confirm the specific arrangement with Irish counsel.
• Singapore VCC: the custody position depends on whether the VCC is an authorised, restricted or other scheme. vccsg.com covers custodian and administrator roles in detail.

Custody often drives cost for small or illiquid funds, so check it before shortlisting.

AML and CFT duties at fund level

AML obligations attach to the fund itself in some domiciles, not only to the manager and the bank.

In practice the AML provider must be in place before the fund takes subscriptions.

Rule changes from 2020 to 2026 worth tracking

• Cayman, 2020. The Private Funds Act came into effect on 7 February 2020 and required new and existing private funds to register with CIMA by 7 August 2020 (CIMA Annual Report 2020). A registrable private fund may not accept capital contributions until it is registered.
• Singapore, 2020 and 2025. The VCC framework launched on 15 January 2020 (MAS and ACRA). Notice VCC-N01 was last revised on 30 June 2025.
• Hong Kong, 2020 and 2021. The LPF Ordinance (Cap. 637) commenced on 31 August 2020. The OFC re-domiciliation mechanism came into operation on 1 November 2021 (SFC).
• European Union, 2024 to 2026. Directive (EU) 2024/927, known as AIFMD II, amends both the AIFMD and the UCITS Directive. Member States had to transpose it by 16 April 2026 (EUR-Lex). Managers of EU funds should check how their home state transposed it.

What "registered" does not mean

Registration and authorisation are gatekeeping steps, not endorsements. When ACRA registers a VCC, it does not assess the fund's strategy. SFC registration of a private OFC is not the same as SFC authorisation of a public OFC. CIMA registration of a private fund does not make the investment safe. A RAIF is not supervised by the CSSF at all; its AIFM is. When you describe a fund, use precise terms such as "registered with ACRA and managed by a MAS-regulated manager" or "a private OFC registered by the SFC", and avoid wording that implies approval of the product.

Before choosing, list every regulator involved: where the fund is formed, where the manager operates and where investors sit. The process page and the domicile matrix show how this list feeds into a shortlist.

This page is general information, not legal or regulatory advice; requirements change and depend on the fund's facts. To discuss your situation, register your enquiry through the contact details on this site.