If the controls carried out by the distributor do not sufficiently address the concerns, it may be appropriate to ensure transparency on the underlying customers in order to be able to carry out independent audits. In this case, the legal agreement with the distributor should allow the Fund full access to KYC registrations or require the fund to execute fixed-term contracts for the underlying client through its registrar and transfer agent. A legal agreement setting out the conditions of the distribution activity should be signed with the distributor. The agreement should set out the rules under which the trading partner will offer units in the fund and the type of clients it is targeting. It should be formulated appropriately to specify that the distributor must meet all applicable regulatory requirements, including AML/KYC. The agreement should give the Fund Manager the right to conduct audits of the distribution partner`s AML program and should allow the administrator to conduct kyc registration checks if he or she so wishes. Rothschild & Co Asset Management Europe has signed a distribution agreement with Alma Capital Investment Management. If the result indicates that equivalence can be considered, it may be a good basis for the application of SDDs to all covered distributors. The assessment should be updated regularly and should not prevent the Fund from ensuring that it understands the distributors` distribution model. I think it`s a good practice to check this model from time to time with the distributor and get continuous reports, for example.B. metrics that provide a breakdown of customer homes and types of customers.
Lemanik helps its asset management clients develop and implement a successful distribution strategy, as it is the one that drives the success of each investment fund structure. This value-added service is based on our experience in most of the main European markets and uses the distribution agreements and contacts we have established over the years. The service is suitable for those who either need to design a new product, develop or re-evaluate their distribution strategy and those who wish to open up new markets, customer segments or distribution channels. Our distribution services offering focuses on three important service elements: Pierre Baudard, Managing Partner at Rothschild & Co Asset Management: “This agreement is an important step in our plan to orient our strategy towards our core competencies. Of course, other investments remain in our portfolios and we will continue to be invested in absolute return strategies through our multi-management and private banking activities. I think the following points should be taken into account: if equivalence cannot be fully accepted, a review of the distributor`s AML programme should be carried out.