MCI Global Investment Advisors Limited

Limits on the record

• This firm may handle your money in passing but must not hold it, so payments should go to the product provider, never to a personal account.
• Notification requirements.

  Notification requirements 3. The Firm must notify in writing all NBF and Bespoke investors of the imposition and effect of the Requirements, with the content of the notification(s) to be agreed in advance with the FCA. The Firm must: a) provide its draft notification(s) to the FCA within two business days of the Effective Date; and b) communicate the notification(s) to NBF and Bespoke investors within one business day of the FCA providing its written approval of the notification(s). 4. The Firm must notify NDA Media Limited and Galmarley Limited trading as Bullion Vault that it does not have FCA permission to approve financial promotions for unauthorised persons under section 21(2)(b) of the Act so cannot provide those services to them, with the content of the notifications to be agreed in advance with the FCA. The Firm must: a) provide its draft notifications to the FCA within two business days of the Effective Date; and b) communicate the notifications to NDA Media Limited and Galmarley Limited trading as Bullion Vault within one business day of the FCA providing its written approval of the notifications. 5. The Firm must publish in a prominent place on all websites and social media accounts in its name (or that it operates) notices setting out the terms and effects of these Requirements, with the content of the notices to be agreed in advance with the FCA. The Firm must: a) provide its draft notices to the FCA within two business days of the Effective Date; and b) publish the notices within one business day of the FCA providing its written approval of the notices. 6. The Firm must use its best endeavours to ensure that NBF and Bespoke publish in a prominent place on all websites and social media accounts in their names (or that they operate) notices setting out the terms and effects of these Requirements, with the content of the notices to be agreed in advance with the FCA. The Firm must: a) provide its draft notices to the FCA within two business days of the Effective Date; and b) use its best endeavours to ensure that NBF and Bespoke publish the notices within one business day of the FCA providing its written approval of the notices. 7. The Firm’s senior manager (“SMF”) must provide written confirmation to the FCA that the Firm is in compliance with Requirements 1 and 2 within four business days of the Effective Date. 8. The Firm’s SMF must provide to the FCA evidence of the notifications and notices in paragraphs 3 to 6 within one business day of having communicated the relevant notifications and notices.

• Record retention

  Record retention 9. The Firm must secure and preserve all records and/or information (physical or electronic) relating to the Firm’s business (both regulated and unregulated), NBF and Bespoke from its systems in their original form, or in a copy proved to be identical to the source material. These must be retained in a form and at a location within the United Kingdom, to be notified to the FCA in writing by two business days from the Effective Date, such that they can be provided to the FCA, or to a person named by the FCA, promptly on its request. Effective date 10. The Requirements are to take effect immediately on their acceptance by the FCA and notification of such to the Firm by email (the “Effective Date”). 11. The Requirements will stay in effect unless and until varied or cancelled by the FCA (either on the application of the Firm or of the FCA’s own volition). Publication 12. The Requirements in this application will be published on the Firm’s entry on the Financial Services Register. Definitions 13. In this application: i. “Investor” means any individual or entity who is an Investor in NBF or Bespoke. ii. “Asset Requirements” means the asset requirements contained in paragraphs 2 to 5 of the requirements imposed on the Firm’s Part 4A permission pursuant to the Voluntary Application for Imposition of Requirements dated 8 August 2024.

• No regulated business, assets and records requirement

  Requirements not to carry on new business 1. The Firm must not, except with the Authority's prior written consent: a. onboard new Investors or take additional subscriptions from existing Investors. b. manage any Funds (other than Funds which it is already managing as AIFM or otherwise on the Effective Date) or onboard any Funds. c. onboard any Appointed Representatives. Asset requirements 2. The Firm must not, other than in the ordinary course of business or with the prior written consent of the Authority: a. in any way dispose of, withdraw, transfer, deal with or diminish the value of any of its own assets or any money or assets it holds or controls for, or to the order of, or for the benefit of, its Clients (whether in the United Kingdom or elsewhere). b. instruct or facilitate any disposal, withdrawal, transfer, dealing with or diminution in value of any money or assets held or controlled by third parties for, or to the order of, or for the benefit of, the Firm’s Clients (whether in the United Kingdom or elsewhere). 3. The Firm must use its best endeavours to ensure that other parties involved in the management or operation of any Funds including fund advisers, custodians and brokers, do not, other than in the ordinary course of business, dispose of, withdraw, transfer, deal with or diminish the value of any money or assets held for, or to the order of, or for the benefit of, the Firm’s Clients. 4. For the purposes of paragraphs 2 and 3, the Authority considers that the following would be in the ordinary course of business: a. transactions made in the best interests of Investors (other than Investors that are also the Firm’s controllers, members, Directors or officers) which may include meeting broker margin calls; b. payments to the Firm’s suppliers or other third parties in satisfaction of the Firm’s contractual and/or legal obligations that arose prior to the Effective Date (including but not limited to payments of or on account of professional fees or expenses, including but not limited to legal, compliance and/or other professional fees or expenses of any professionals or consultants appointed by the Firm to advise in connection with its wind down or otherwise); c. usual and proper salary payments made by the Firm. 5. For the purposes of paragraphs 2 and 3, the Authority considers that the following payments would not be regarded as payments made in the ordinary course of business (for the avoidance of doubt the Authority’s prior written consent will be required for these): a. payments (whether as a single transaction or a combination of related transactions) in excess of £5,000; b. payments of unusual or significant amounts to the Firm’s controllers, Directors, officers, employees or any connected persons (which shall include any management or performance fees); c. the making of any capital distribution; and d. the making of any gift or loan by the Firm to any party.