Investment Fund FAQs

Is the Annual Compliance Return included as part of the annual filing that Otonomos handles for the fund?
The AML responsibilities, including the preparation of the Annual AML/CFT Compliance Return, fall under the remit of the appointed Money Laundering Reporting Officer (MLRO). While Otonomos can assist with the submission of the return to the regulator, the preparation of the return must be completed by the appointed MLRO. Please note that the filing deadline for the Annual AML Return is 31 March each year.

Who is responsible for preparing the AML documentation for the Board of Directors, and what does the report entail?
The Money Laundering Reporting Officer (MLRO) is responsible for preparing the AML documentation and reports for the Board of Directors.There is no prescribed or fixed format for this. The report typically takes the form of an Annual AML Compliance Report, which outlines:

The fund's compliance with applicable BVI AML laws and regulations
A summary of internal AML procedures and controls
Any Suspicious Activity Reports (SARs) filed, if applicable
Outcomes of internal or independent AML audits
AML training conducted
Any compliance breaches or recommendations for improvement

This report supports the Board in fulfilling its oversight responsibilities and is usually submitted alongside the Annual AML Return to the FSC.

What are Launch Resolutions, and what agreements with service providers do they cover

Launch Resolutions are formal board resolutions that establish the fund's operational and regulatory setup at the time of launch. They typically cover:

Appointment of service providers (Authorised Representative, Legal Counsel, and Registered Agent)
AML obligations and appointment of the MLRO
Approval to sign and submit regulatory filings
Delegation of FATCA/CRS compliance responsibilities

These resolutions ensure the fund is properly structured and aligned with BVI regulations from the outset.