Operating models

Fund manager

A fund-manager proposal needs to distinguish the fund, manager, investors and service providers.

Reference entryPublished 25 September 2026By Ape Law
Answer in brief

A fund-manager proposal needs to distinguish the fund, manager, investors and service providers. Their obligations and permission questions are related but not identical.[1]

01

Understanding the question

Map investment discretion, asset custody, valuation, administration and distribution. Describe the instruments the strategy will hold and the investors it intends to serve. Corporate formation alone does not answer the regulatory questions about managing or offering the product.[1]

02

Build the working record

ConsiderationWhat to establish
MandateWho makes investment decisions and under what limits?
Fund structureHow do investors hold their interests?
ProvidersWho handles custody, administration and valuation?
03

Put it into practice

A strategy adding token exposure should revisit its mandate, disclosures and operational dependencies rather than assuming an existing description covers the change.

Useful outputA manager-and-fund operating model connected to the applicable FSRA analysis.
04

Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[2][3]

Ape Law’s ADGM licensing practice
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REF

References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

  1. ADGM: Financial Services Regulatory Authority ADGM · Official regulatory source

    Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.

  2. Ape Law: ADGM VASP licensing Ape Law · Service description

    Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.

  3. Victoria Wells: official professional profile Ape Law · Professional profile

    Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. Read the citation method.