CySEC circular – Reminder to Alternative Investment Fund Managers on minimum investment requirement.

09 Jul 2019 By Panayiotis Z. Toulouras LLC

The Cyprus Securities and Exchange Commission (' the CySEC') recently released circular ‘C321’, dated 7th of June 2019, reminding all Alternative Investment Fund Managers (AIFMs) to raise capital from investors within 12 months from the set date that funds under their control were authorised by CySEC.

Specifically, Law 124(I)/2018 or ‘AIF Law’ states that all authorized or regulated AIFMs are required by Article 14 to raise at least €500.000 worth of capital from investors within the 12 months mentioned.

The article further provides that capital commitments are not to be calculated as part of the minimum investment and in situations where AIF is internally managed, initial capital requirement is also excluded. Payments made by investors should be made in either cash or in assets related to AIF investment policy and free of liens. Regarding non-cash payments made by investors, these will need to be valued at date of payment by an independent valuer.

Lastly the circular also states that all types of AIFs authorized prior to the aforementioned legal requirements being in force, will need to comply to any new obligation as stated in Article 145 of the 'AIF Law'.

The team here at Panayiotis Z. Toulouras LLC are able to assist and guide you on the above and other issues to all AIFs in Cyprus. For any enquiries or assistance, feel free to contact us at [email protected] or call us directly at +357 24 623 800. For more information visit

Read the full circular here.