- What is the minimum number of a CIF's management members that must be directors?
- Two — the 'four-eyes principle', preventing single-person control over critical decisions.
- For a significant CIF, what is the maximum directorship combination involving one executive role?
- One executive directorship plus two non-executive directorships (the 1+2 rule).
- How do directorships in non-commercial organisations count toward a CIF director's limit?
- They do not count at all. Charities, foundations and public institutions are excluded from the directorship count.
- How do multiple directorships held within the same group count toward the limit?
- As a single directorship, because the director is effectively serving one enterprise.
- On what ground can CySEC reject a CIF's authorisation application relating to its directors?
- If it considers the directors are not of sufficiently good repute or experience — the fit-and-proper test is a primary gatekeeping tool.
- Can the chairman of a CIF's board also be its CEO?
- No — not unless justified. Separating the roles preserves independent board oversight of executive management.
- Who may sit on a CIF's nomination committee?
- Members of the board of directors who do not perform any executive function in the CIF (non-executive directors only).
- What must the nomination committee of a significant CIF assess at least annually?
- The structure, size, composition and performance of the board of directors.
- What is the board of directors responsible for supervising?
- Senior management. The board provides strategic oversight and holds senior managers accountable, while management executes.
- How often must senior management receive written reports on compliance, risk management and internal audit?
- At least annually (the minimum floor).
- What must those periodic reports to senior management specifically confirm?
- Whether appropriate remedial measures have been taken where any deficiencies were identified — closing the loop between findings and action.
- What standard must a CIF's periodic internal review ensure its authorisation arrangements remain?
- Appropriate, effective, comprehensive and proportionate to the nature, scale and complexity of its business.
- What must a CIF do if its conflict-of-interest arrangements cannot adequately prevent damage to a client?
- Disclose the general nature and/or sources of the conflicts to the client before undertaking business on their behalf.