Governance
A control framework, not an organisation chart
Investment decisions are subject to Responsible Officer supervision, Investment Committee review, documented risk limits, fund operations, compliance monitoring and control governance.
Risk controls
Documented exposure limits, position and liquidity monitoring, and independent risk review prior to and following investment approval.
Fund operations
Position, cash and NAV reconciliation, subscription and redemption coordination, fee calculation and investor reporting.
AML / CFT
Investor onboarding, sanctions and source-of-funds screening, and ongoing monitoring consistent with Hong Kong requirements.
Compliance monitoring
Licensed-activity supervision, personal-account dealing controls, record keeping, and periodic compliance testing and reporting.
Control governance
Segregation of duties between strategy generation and operational control, with escalation to Responsible Officers.
Oversight of models
Validation, documentation and change control for quantitative models and algorithms used in the investment process.
Separation of Duties
Operations and compliance sit apart from strategy generation.
The fund operations, compliance and governance function supports operational control, reconciliation, compliance monitoring and governance. It remains separate from investment strategy generation.
Subject to final appointment and disclosure approval, an external fund services provider may support fund administration, AML/CFT, investor onboarding, compliance monitoring, risk assessment and operational controls.