Governance for BVI Approved Managers
The BVI Approved Manager regime gives emerging and mid-sized managers a proportionate route to authorisation, with lighter ongoing obligations than a full investment business licence. That proportionality is a commercial advantage — but it also means the quality of a manager’s own governance carries more weight, both with the BVI Financial Services Commission and with allocators conducting operational due diligence.
What we bring to an Approved Manager board is the operating experience behind it. Our Managing Directors have overseen risk, valuation and operations across hundreds of emerging managers, sat on the regulator’s side of the table, and run regulated entities in the BVI. Mount Sage Directors Ltd holds a Restricted Class III Licence under the Bank and Trust Companies Act, 1990 — the BVI’s regulated framework for professional directorship services, which not every director provider in the jurisdiction holds.
Where an Independent Director Adds Value
Genuine review of board materials, challenge to management where appropriate, and properly documented decision-making that withstands later scrutiny.
BVI-resident directors supporting direction and management in the jurisdiction, combined with our Sub-Advisor CIGA solution and BVI office premises.
Institutional allocators examine board composition closely. A senior, genuinely independent director materially strengthens an ODD file.
Directors who engage directly with the BVI FSC and sit on its advisory committees, and who understand the Commission’s expectations in practice.
Experienced engagement with administrators, auditors, prime brokers and counsel — including valuation and NAV oversight.
Outsourced CIO, COO and CFO capability for managers building infrastructure, covering prime brokerage, ISDA, banking and custody set-up.
Our Relevant Experience
Christian Thompson spent a decade at Man Group overseeing performance, risk and operations across more than 100 emerging hedge fund managers, and managed the outsourced fund servicing team covering valuation, administration and custody for over 1,000 funds, chairing the firm’s Valuation Committee. He sits on the BVI FSC Securities, Investment Business and Mutual Funds Advisory Committee (SIBAC) and is Principal and Co-CIO of Brook Bay Capital.
Sjoerd Koster spent 13 years as General Manager of a SIX-listed, BVI FSC-regulated bank, and serves on the BVI Financial Services Complaints Tribunal. He is a former President of the BVI Bank Association and has held board appointments across regulated bank and approved manager entities.
Between them they have reviewed the governance of a large number of emerging managers from the allocator and regulator side — which is a materially different vantage point from having only sat on boards.
Frequently Asked Questions
Mount Sage Advisors provides independent directors to BVI Approved Managers. Both Managing Directors are permanent BVI residents with direct investment management and fund operations experience, and Mount Sage Directors Ltd holds a Restricted Class III Licence under the Bank and Trust Companies Act, 1990 — the BVI’s regulated framework for professional directorship services.
The regime, introduced by the Investment Business (Approved Managers) Regulations, 2012, offers a lighter-touch authorisation for managers of BVI and certain other funds, subject to assets under management thresholds. It allows a manager to begin operating on approval from the BVI Financial Services Commission, with reduced ongoing obligations compared with a full investment business licence. Current thresholds and eligibility should be confirmed with your BVI counsel.
There is no general rule requiring a BVI-resident director purely to hold Approved Manager status. However, fund management business is a relevant activity under the BVI economic substance regime, so an Approved Manager that is a relevant entity will need to consider whether it is directed and managed in the BVI. A resident director with genuine investment management expertise is a common practical response. Confirm the position with your BVI legal advisers.
Yes. Alongside board appointments we provide outsourced CIO, COO and CFO capability, vendor selection, prime brokerage, ISDA, banking and custody set-up, and coordination with BVI law firm partners on offering materials and regulatory infrastructure across BVI, Cayman, Jersey and Ireland structures.
Sjoerd Koster — Managing Director
sjoerd.koster@mountsageadvisors.com
+1 (284) 346 7769
Christian Thompson — Managing Director
christian@mountsageadvisors.com
+1 (284) 342 5300
200 Waterfront Drive, Unit 7A, Road Town, Tortola VG1110, British Virgin Islands
This page is provided for general information only and does not constitute legal, tax, regulatory or investment advice. Mount Sage Directors Ltd holds a Restricted Class III Licence issued by the BVI Financial Services Commission.