Directive - Aliquot Commodity Fund Inc. (2011-08-15)

Summary

This is an enforcement directive issued by the BVI Financial Services Commission under section 40(1)(b) of the Financial Services Commission Act, 2001, directed at a group of investment funds managed by Castlestone Management Incorporated, including Aliquot Commodity Fund Inc. and numerous related fund entities. The directive imposes specific ongoing reporting and spending restrictions on these funds while the Commission's concerns are addressed.

• Weekly reporting: The named funds must provide the Commission, on a weekly basis, full details of their activities.
• Internal controls proposal: The funds must provide the Commission with a proposal to implement more robust internal controls.
• Restriction on payments: The funds must refrain from making any payment of fees and expenses without the Commission's prior written consent, except for fees relating to fund administration, brokerage, custody, audit and legal services.

The directive applies specifically to the listed Castlestone Management Incorporated funds identified by name (including Aliquot Commodity Fund Inc., Aliquot Agriculture Fund Inc., and others). The matter is tracked under Matter ID INV0811/092.

Key obligations

• Provide the Commission with full details of the fund's activities on a weekly basis
• Submit to the Commission a proposal to implement more robust internal controls
• Refrain from paying any fees and expenses without the Commission's prior written consent, other than fees for fund administration, brokerage, custody, audit and legal services

Applies to

investment funds, funds under management of Castlestone Management Incorporated

Deadlines

• weekly: Funds must report full details of their activities to the Commission on a weekly basis