We are a boutique Management Company for demanding professionals. In Apis Asset Management, our clients find the expert partner which enables them to stay focused on their own business and help them succeed. It free our mind from pre-existing process and frameworks so we can design bespoke solutions for each and every of them to help them reach their goals efficiently.

Key features

Solution for you to focus on your core activity and delegate the management of your fund

Core services

Performed internally/ Managed in house
(except Central Administration and Distribution)

Investment Management and oversight

  • The Investment Management can be performed internally
  • We offer the ability to onboard asset manager, implement investment strategy in line with the prospectus and the requirements from the promoters
  • The Investment Management can leverage advisor’s expertise
  • We offer the capacity to challenge the target model portfolio and the advisors’trade, plus we implement the validated strategy
  • The Investment Management can be delegated and supervised through IM Oversight Management
  • This “IM oversight” falls into the “global oversight” function
  • With the same approach than for the IM and delegation process, APIS AM supervises third-party activities & providers: Transfer Agent, Fund Administration, Distribution, Portfolio Management (depending of the mandate)

Risk Management

  • Our Risk Management is performed internally
  • Its objective is to protect the Company’s, client’s and investor’s interest against different risks
  • The Risk Management framework is dictated by several regulations, whether local or European, and subject to frequent changes with reduced deadlines and increasing complexity
  • The CSSF, through its on-site and off-site inspections, tends to impose market practices to align the risk management framework of the management companies in Luxembourg (Risk Management Procedure, Risk profiles, Liquidity stress tests, AML on asset side, …)
  • APIS developed a complete and comprehensive Risk Management framework to cover all those keystones, which can be adapted to all Fund Admin and Custodians
  • APIS uses several internal or external tools to reach this goal, and leverages on major actors on the market : Opus, PwC ALLERT, Datacentral, Statpro …

Distribution and oversight

Many asset managers who come to Luxembourg have successfully established products in their country or region of origin and would like to replicate existing strategies in other markets.
They use Luxembourg as the gateway to global distribution. Indeed, Luxembourg, in its role as the largest investment funds domicile in Europe.
APIS has decided to delegate distribution to third-party distributors which are therefore closely supervised.


  • The Compliance Risk can be defined as the risk of legal or regulatory sanctions, financial loss, or loss to reputation you may suffer as a result of its failure to comply with all applicable laws, regulations, codes of conduct
  • European and local regulators have issued an ever growing number of regulatory requirements. As a result, numerous topics need to be treated on a daily basis (AML, Regulatory reporting, tax topics (FATCA, CRS), Governance…). We can provide you assistance to anticipate, identify and assess your compliance risk
  • APIS has developed an AML matrix to help you define your inherent and residual risk
  • All the Fund’s delegates are identified and supervised through an initial and ongoing due diligence, service reviews and KPI’s
  • The Compliance Officer may act as RC of the Fund (Responsible du Contrôle du Respect de Obligations) and provide the Fund with the annual compliance risk report
  • The Compliance function is managed in house

Central Administration

The Central Administration is a function that APIS delegates systematically, in the course of the collective management of a fund.
APIS has decided to delegate the Central Administration function to privileged partners. This function includes:
  • Transfer Agent and Registrar
  • Fund Administration.

Transfer Agent and Registrar

The Registrar handles the opening of accounts for investors in the Funds. It ensures that investors sent the required AML documents and carries out the due diligence including name screening. Risk factors such as activity, country of domicile, source of funds, screening hits will determine whether a given account is subject to simplified, standard of enhanced customer due diligence.
The Transfer Agent handles subscription, redemption, transfer of ownership and switch orders. It records trades, keeps shareholder records and issues and sends reports and other documents to clients and fund managers (e.g. pre-notification of expected cash-flow and execution confirmations).
In addition, the Transfer Agent has measures in place to prevent late trading and market timing.

Fund Administration

The Fund Administration function includes computing net asset values (NAVs) as well as ensuring the application of anti-dilutive measures such as swing or spread methods, when applicable, and producing fiscal indicators in relation with the countries where the funds are distributed.

Additional services

Distribution and Reporting services

Supporting the distribution services, and complimentary to them, APIS deploys value-added offerings including:
  • KIID – Key Investor Information Document,
  • Passporting to regulatory authorities,
  • Fund registration services,
  • Fund reporting.

Directors sourcing

The question of Director independence has long been at the heart of corporate governance policies as the presence of independent non-executive directors is widely considered as a means of protecting the interests of shareholders and other stakeholders. By ensuring there are Directors on each Board who are free from material conflicts of interest, it is intended that it be easier to ensure appropriate scrutiny and challenge of management recommendations and proposals and, when appropriate, for these Directors to make objective decisions which may raise conflicts of interest.
APIS provides Independent Directors having a long-standing experience in the financial industry.

Responsible du Contrôle (RC) and Responsible du Respect (RR) of AML obligations

All UCITS, AIF and RAIF are subject to AML/CFT requirements and must appoint
  • a person responsible for AML/CFT compliance (RR), who can be one of the Director of the fund, or the board of the fund collectively and 
  • a person responsible for the control of AML/CFT compliance (MLRO or RC) who is subject to specific requirements (such as presence, access to information, training). 
When being the Management Company of the AIFM of a fund, Apis AM can deliver RC services.