PIF solution & requirements
Milo / 29.3.2021
a PIF can be either self-managed or, if externally managed, the external manager must be regulated either in Malta or in a jurisdiction with which the MFSA has a MoU. The MFSA will vet any external manager before licensing the PIF. Kindly also see attached PwC paper on the subject.
I am sure there has been a misunderstanding in what the client has understood about the proposed manager or (it would not be the first time I hear of such arrangements) they found a licensed external manager that has accepted to take on such role and then, at its peril and against regulations, allow Black Flower Capital, the advisor, to execute MiFID instruments trades directly. If the regulator found out such arrangement out the external manager will have a good time trying to explain it... advisors cannot execute trades in the first place (they can only give advise), plus they cannot even give advice on MiFID instruments if they are not regulated.