Update to the Central Bank’s Position on QIAIFs Holding Indirect Exposure to Digital Assets
On 4 April 2023, the Central Bank of Ireland published the 47th Edition of the AIFMD Q&A (the Q&A) clarifying investment limits for qualifying investor alternative investment funds (QIAIFs) holding indirect exposure to digital assets.
The investment limits for QIAIFs seeking indirect exposure to digital assets are as follows:
where a QIAIF is open-ended it can gain exposure to digital assets of up to 20% of net asset value (NAV); and
where a QIAIF is closed-ended or is open-ended with limited liquidity it can gain exposure to digital assets of up to 50% of NAV.
This is a welcome update and effectively removes the pre-submission requirement for QIAIFs seeking to gain indirect exposure to digital assets within the above limits. The pre-submission process (set out here) will still be required for QIAIFs proposing to invest indirectly in digital assets in excess of the above limits or any direct investment in digital assets.
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