Financial Crime Risk – Investment Vehicles Return (Form 152) – Guidance for Completion

Summary

This is GFSC guidance explaining how to complete the Investment Vehicles Return (Form 152), which replaces the former Intermediary Annual Return. It is completed by fund administrators (Firms) licensed under the Protection of Investors Law who act as designated administrator for Guernsey registered or authorised collective investment schemes, and it sets out how to populate the 152a/152b forms and the accompanying Statistics Spreadsheet.

• Who must file: Firms that are the designated administrator for Guernsey registered/authorised Schemes (i.e. those that submit Form 141 Designated Manager Quarterly Return) must submit one or more 152b returns covering all Schemes with a 152a form.
• Scope of data: Data must be reported at Scheme level and, where applicable, at cell, sub fund, share class, and basket constituent element level, plus aggregate Firm-level data on single asset and/or single investor vehicles (excluding those where the single investor is a Guernsey Scheme).
• Reporting period: The Reporting Period runs 1 July to 30 June; the Return becomes available from 30 June each year.
• Statistics Spreadsheet: A linked Statistics Spreadsheet template must be completed for each selected Scheme (Start, Scheme Details, Direct Investor/Intermediary/Correspondent Location, and NAV tabs) and uploaded back into the Return without altering cell formatting or adding password protection.
• Classification of investors: Investors must be classified as Direct Investors, or as covered under Intermediary or Correspondent Relationships per the AML/CFT Handbook (Sections 9.8 and 8.6), with geographic NAV breakdowns by investor type.
• Penalties: The Return is within scope of penalties for late and inaccurate submissions.

The guidance is purely explanatory of the online submission process and data fields; it does not itself create new legal duties beyond directing Firms to the existing filing requirement and its deadline.

Key obligations

• Designated administrators must submit one or more 152b Investment Vehicles Returns covering all Schemes for which a 152a form exists.
• The Return must be submitted within four months of the Reporting Period end, i.e. by 31 October each year.
• Firms must report data at cell, sub fund, share class, and/or basket constituent element level where these exist, excluding the Core of PCCs/ICCs.
• Firms must complete and upload the Statistics Spreadsheet without altering its formatting or password-protecting the file.
• Firms must classify each Investor as a Direct Investor, or as covered under an Intermediary Relationship or Correspondent Relationship, and report NAV by investor type and jurisdiction.
• Firms should engage with the Commission as early as possible where there is uncertainty or issues completing the Return.

Applies to

fund administrators (Firms licensed under the Protection of Investors (Bailiwick of Guernsey) Law, 2020), designated administrators of Guernsey registered/authorised collective investment schemes

Deadlines

• by 31 October: The Return must be submitted within four months of the Reporting Period end (1 July to 30 June).
• 1 July to 30 June of the following year: Reporting Period covered by each Return.
• from 30 June each year: The Return becomes available for completion.