Compliance guides for small EU fund managers
Plain-English answers on EU sanctions screening and MAR market-abuse compliance — written for small AIFMs and ManCos that have the same obligations as a big bank but not the same headcount.
Sanctions screening
EU sanctions screening for fund managers
What it covers, how often you need to run it, which lists to include, and how a small fund does it without a compliance desk.
Sanctions screening for crypto funds under MiCA
Why the obligation comes from EU restrictive-measures law, not MiCA itself — and what's genuinely harder when you hold crypto-assets.
The EU sanctions 50% ownership rule
Why an un-named entity can still be frozen — the 50% ownership test and the separate control test, and what they mean for screening.
How often is the EU sanctions list updated?
There's no fixed schedule — and why a weekly or monthly refresh leaves you exposed.
What to do when you find a sanctioned holding
Freeze, confirm, report, don't tip off, record — the steps to take, in order.
OFAC vs EU vs UK: which lists to screen
When an EU fund must also screen the US and UK lists — and why the three don't line up.
Market abuse (MAR)
What is a STOR?
Suspicious Transaction and Order Reports under MAR, explained simply — who files, what triggers one, and what happens if you don't.
Do small AIFMs need to file STORs?
Yes — there's no fund-size exemption. What actually changes with size is resourcing, not the obligation.
MAR compliance for small funds
A minimal-but-real surveillance setup: daily detection, a review step, and an audit trail — runnable by one person.