Sep 21, 2026 · 21 min · 8 segments
ADGM’s specialised Fund Manager frameworks provide tailored regulatory pathways for managers based on their **fund size, investment strategy and investor profile**. In this episode of The Riffle…
Yeah.
We have to start with the source texts annex one, which refers to this baseline as the full scope fund manager.
Full scope.
Right.
If you walk up to the regulator and basically declare, hey, I want to manage all types of funds for all types of clients, retail, institutional, open-ended, whatever, you get put in this full scope category.
And the requirements there are just incredibly heavy.
So let's unpack that burden so we have a good comparison.
What are we actually talking about here?
Well, operationally, you face a massive authorization process.
For starters, you're mandated to establish an independent internal audit function.
Okay, that sounds expensive.
It is.
Then you have to appoint a dedicated finance officer.
Okay.
And a compliance officer.
And a money laundering reporting officer.
Wait, so you're basically hiring an entire C-suite before you've even made your first investment.
You are.
And then comes the insurance.
Right, okay.
But the real anchor, the thing that really weighs you down, is the capital requirement.
A full scope manager has to hold a base capital requirement, which is often up to $150,000 if they manage a public fund.
Wow.
And on top of that, they face what's called an expenditure-based capital minimum, or EBCM.
Yeah.
We have to start with the source texts annex one, which refers to this baseline as the full scope fund manager.
Full scope.
Right.
If you walk up to the regulator and basically declare, hey, I want to manage all types of funds for all types of clients, retail, institutional, open-ended, whatever, you get put in this full scope category.
And the requirements there are just incredibly heavy.
So let's unpack that burden so we have a good comparison.
What are we actually talking about here?
Well, operationally, you face a massive authorization process.
For starters, you're mandated to establish an independent internal audit function.
Okay, that sounds expensive.
It is.
Then you have to appoint a dedicated finance officer.
Okay.
And a compliance officer.
And a money laundering reporting officer.
Wait, so you're basically hiring an entire C-suite before you've even made your first investment.
You are.
And then comes the insurance.
Right, okay.
But the real anchor, the thing that really weighs you down, is the capital requirement.
A full scope manager has to hold a base capital requirement, which is often up to $150,000 if they manage a public fund.
Wow.
And on top of that, they face what's called an expenditure-based capital minimum, or EBCM.
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