SIBA Investment Business FAQ · 3/3

The materials currently verified do not establish RGYS’s specific project experience, success cases or ability to reduce rounds of inquiries, and such claims should not be made on that basis. Support that may be provided includes organizing questions, assigning responsibility for materials, checking that responses are consistent with supporting evidence, and coordinating professional review. The applicant and appropriate professionals should confirm the content of responses and authority to submit them.

Risk warning:A response that is inconsistent with the original application materials may prompt further regulatory questions.

The service value that can be described lies in organizing group entities, businesses, clients, jurisdictions and fund flows into a combined proposal that professionals can review—not in claiming a higher approval rate or special regulatory channels. Licences in different jurisdictions are not automatically recognized by one another. Any specific advantage should be assessed against actual deliverables and written scope; no promises should be made about cross-border operations or tax outcomes.

Risk warning:A combined arrangement that omits the actual service provider may create a gap in regulatory accountability.

Long-term one-to-one support may, under a written agreement, include periodic reviews of matters, document tracking, compliance-calendar maintenance and professional coordination; it is not equivalent to serving in a statutory compliance role or providing individual legal advice. Significant business, personnel, ownership and disclosure matters should be reviewed promptly by an appropriate professional. It should not be promised that a single adviser can resolve every issue.

Risk warning:Over-reliance on a single coordinator may delay significant matters requiring professional judgement.

You may first submit information on the business model, target markets, client types, flow of funds, ownership chain, and proposed personnel, followed by an initial assessment of possible routes and professional review. After confirming the written service scope, fees, and responsibilities, prepare the application, respond to inquiries, and meet launch conditions in stages. Incorporation, filing materials, or preliminary review by an adviser does not authorize the business.

Risk warning:Investing in an application before clarifying the regulatory route may result in rework and incorrect arrangements for commencing business.

Whether a SIBA licence is required depends on the actual activity, not the company name or mere ownership of securities. Regulated investment business has seven categories: dealing, arranging deals, managing, advising, custody, administration and operating an exchange. A licence authorises only the stated category or subcategory. Capital requirements are determined case by case according to business risk; eligible fund management/advisory activities may be assessed separately for the Approved Manager route.

Risk warning:Carrying out functions beyond the licence authorization after obtaining only some business categories may exceed the scope of the licence.

An investment account may be sought from a securities broker or fund service provider that accepts BVI corporate clients; the specific channel depends on the provider’s eligibility and due diligence policies. Distinguish investment of the company’s own funds from managing investments or providing advice for others, which may involve an investment-business licence. Economic substance should also be assessed independently based on the actual activities.

Risk warning:Treating the management of assets for others as proprietary investment may result in unlicensed business activity.