On 15 October 2025, the Guernsey Financial Services Commission ("GFSC") announced a significant development in the administration of family private investment funds ("Family PIF"), introducing a new limited investment licence. This initiative is designed to enable fiduciary firms to act as the designated administrator of a Family PIF ("Designated Administrator") without requiring a full investment licence, thereby broadening access to regulated fund structures for family wealth management.
What is a Family PIF?
A Family PIF is a type of Guernsey regulated collective investment scheme, restricted to investors who share a family relationship or are eligible employees of the family or its office. These funds are private in nature and cannot be widely promoted to the public.
Under Guernsey’s regulatory framework, each Family PIF must appoint a Designated Administrator with an investment licence. However, many Family PIF sponsors are clients of fiduciary firms, which typically hold a fiduciary licence rather than an investment licence, preventing them from acting as the Designated Administrator of a Family PIF.
The limited investment licence: a targeted solution
To address this gap, the GFSC now offers a limited investment licence to fiduciary firms wishing to act as the Designated Administrator of a Family PIF. This licence is restricted solely to activities related to the administration of Family PIFs and prohibits other restricted investment activities.
Key features of the limited investment licence include:
- eligibility: available to firms already holding a fiduciary licence as primary licensee;
- regulatory oversight: applicants must demonstrate appropriate skills, expertise, and resources - the application process is subject to the same rigour as a full investment licence;
- licence conditions: the limited investment licence will include conditions limiting activities to those associated with Family PIF administration; and
- annual fee: although the application fee is the same as a full investment licence, a reduced annual fee of £1,000 applies, reflecting the limited scope of permitted activities.
Compliance requirements
Holders of a limited investment licence must still comply with the protection of investors law and the associated conduct of business rules. However, given the restricted nature of their activities, many rules may not be applicable. The GFSC may waive or modify certain requirements under other applicable rules, such as in respect of capital adequacy.
Importantly, the limited investment licensee will be responsible for applying customer due diligence measures to all investors in a Family PIF, in accordance with the Handbook on Countering Financial Crime (AML/CFT/CPF).
Conclusion
This policy shift marks a progressive step in Guernsey’s regulatory landscape, enhancing flexibility for fiduciary firms and reinforcing Guernsey's reputation as a leading centre for private wealth structuring. By opening up access to regulated fund structures, the GFSC is enabling innovation while maintaining robust regulatory standards.
If you would like any further information, please get in touch with your usual Bedell Cristin contact or one of the contacts listed.
