Investor Guide
The Investor
Guide.
A complete institutional reference to Qlumina — our regulation, investment structures, AI-driven process, risk framework, and onboarding. Explore chapter by chapter, or open any module for deeper detail.
For informational purposes only; not an offer or solicitation. All investments involve risk, including loss of principal. Past performance is not indicative of future results. Intended solely for eligible, professional, or accredited investors. Qlumina is registered in the BVI as an Approved Manager under SIBA, 2010.
Chapter 01
Understanding Qlumina
Qlumina is an AI-native asset management firm that designs, evaluates, and manages investment programs across multiple structures — Separately Managed Accounts (SMAs), Actively Managed Certificates (AMCs), and hedge funds. We combine systematic, technology-driven research with rigorous human oversight to source, validate, and allocate to investment strategies across global markets.
Our philosophy is built on the conviction that artificial intelligence and systematic data analysis can meaningfully improve the sourcing, evaluation, and risk management of investment strategies — while final investment decisions and fiduciary oversight require experienced human judgment. We identify high-quality portfolio managers and strategies through technology-enhanced due diligence and offer access through the structure best suited to investor needs.
BVI Company
No. 2201896
British Virgin Islands Business Company
Approved Manager
IBR/AIM/26/2644
BVI FSC, Approved Managers Regs. 2012
Legal Entity Identifier
9845000BG592F5189B91
GLEIF LEI
Registered Office
Rodus Building, P.O. Box 3093, Road Town, Tortola VG1110, BVI
What BVI Approved Manager status means
An Approved Manager is a category of investment manager authorised by the BVI Financial Services Commission to manage investment funds and accounts, subject to regulatory conditions including limits on the number of investors and/or assets under management, ongoing compliance obligations, and adherence to anti-money laundering (AML) and counter-terrorist financing (CTF) requirements. The regime is designed for professional and institutional investor-facing managers and provides a proportionate regulatory framework while maintaining internationally recognised standards of conduct and investor protection. Qlumina operates under the Securities and Investment Business Act, 2010 (SIBA), as administered by the BVI FSC.
Three investment structures
SMA
Individually owned, segregated accounts managed on behalf of a single investor with full transparency and daily liquidity.
AMC
Actively Managed Certificates — securitised notes issued by a third party that track a Qlumina-managed strategy.
Hedge Fund
Pooled investment vehicles structured as limited partnerships or corporate funds, offering access to complex or capacity-constrained strategies.
Chapter 02
Investment Structures
Each structure has distinct characteristics with respect to ownership, liquidity, fees, transparency, and minimum investment. Select a structure to explore its architecture, or compare all three side by side.
Separately Managed Account
An individually owned investment portfolio managed on behalf of a single investor. Assets are held in a segregated brokerage account in the investor's own name. Qlumina does not hold, control, or withdraw investor funds — it is granted a Limited Power of Attorney permitting only the sending of trading signals. The investor retains full legal and beneficial ownership at all times.
- Ownership: Direct — investor owns all assets in their own brokerage account.
- Liquidity: Daily; positions may be liquidated or the mandate terminated on any business day.
- Transparency: Full real-time account access 24/7 plus daily broker statements.
- Customisation: High — investor-specific mandates, restrictions, and risk limits.
- Minimum: Varies by asset class (typically $100K–$5M).
- Performance fee cycle: Monthly high-water mark.
Fee mechanics across structures
| Mechanic | SMA | AMC | Hedge Fund |
|---|---|---|---|
| Management fee | Annual % of AUM, billed monthly pro rata (1/12) | Annual %, billed monthly pro rata | Annual % of net assets, billed monthly pro rata |
| Performance fee | On net new profits above HWM | On net new profits above quarterly HWM | On net new profits above quarterly HWM; possible hurdle rate |
| HWM cycle | Monthly | Quarterly | Quarterly (end of each calendar quarter) |
| Hurdle rate | Not typical | Not typical | Optional — minimum return before perf. fee |
| Payment terms | Mgmt invoiced monthly on start-of-period AUM; perf. monthly | Per term sheet | Per offering memorandum |
| Fee basis / oversight | Direct account; investor sees all activity | NAV by issuer/calculation agent | NAV by independent administrator; annual audit |
The high-water mark ensures a manager only earns performance fees on net new profits — recovering any prior losses before earning further fees — aligning manager incentives with investor outcomes.
Chapter 03
SMA Architecture
The LPOA relationship
Your capital stays yours.
Qlumina holds no withdrawal authority. A Limited Power of Attorney grants trading rights only — never the ability to withdraw, transfer, or move funds.
Investor
Owns the brokerage account & all assets
Prime Broker / Custodian
Holds assets in investor's name; enforces LPOA scope
LPOA
Trading signals only — API executed within seconds
Qlumina
Manages trades; cannot withdraw or transfer funds
How an SMA differs from a fund
In a fund, investors pool capital into a single vehicle that owns the underlying positions. In an SMA, assets remain segregated with no commingling. This delivers direct transparency into every position, daily liquidity, the ability to impose personalised restrictions, and, in many jurisdictions, potential tax advantages such as individual loss harvesting. The investor verifies all activity through their own brokerage statements — visibility and control not available in most pooled structures, which may be offshore, offer only monthly or quarterly liquidity, and require weeks or months before NAV reports or redemptions.
How the LPOA works in practice
A Limited Power of Attorney is a legal document granting Qlumina (or the appointed portfolio manager) permission to execute trades within the investor's brokerage account. It is limited to trading authority only — it does not grant the ability to withdraw funds, transfer assets out of the account, or change account ownership or banking details. Only the investor (or their authorised signatories) can withdraw or transfer funds.
When Qlumina's portfolio manager places a trade — for example, buying shares of Apple — a trading signal is sent via API to the investor's brokerage account and executed, typically within the same second. The investor's portfolio mirrors the manager's intended positions in near-real-time while the investor retains full ownership and control. The broker is informed of the LPOA relationship and maintains its own records of Qlumina's authority and its limitations.
Customisation
An SMA mandate can be tailored to the investor's objectives — restrictions on instruments, sectors, geographies, leverage, or risk limits (for example, capping value-at-risk below 4% of invested capital via blended complementary strategies). Any modification alters both downside and upside; Qlumina ensures the trade-offs are clearly understood before implementation. Customisation requests are discussed during onboarding and documented in the investment management agreement.
Broker-level risk controls
Some prime brokers offer automated risk controls configured at the account level, independent of the manager. For example, an investor with $100,000 and a desired maximum drawdown of 10% can instruct the broker to automatically liquidate all open positions if the account value falls to $90,000. On trigger, the broker closes all positions, deactivates Qlumina's trading access, and alerts the investor; no further trades are permitted until the investor explicitly re-authorises. In fast-moving markets price gaps — particularly at market open (overnight or over weekends) — may cause execution slightly beyond the intended stop, so broker controls are a valuable safeguard, not a guarantee of a specific maximum loss.
Transparency
The investor has real-time access to their brokerage account 24/7 via the broker's online platform — visibility into all open positions, executed trades, cash balances, and margin usage — and most prime brokers also email daily account statements. This stands in stark contrast to most pooled funds, where investors receive only periodic (monthly or quarterly) reports, do not see individual positions, and have limited visibility between reporting periods. For investors who value seeing exactly what is happening with their capital at all times, the SMA provides an unmatched degree of transparency and control.
Tax considerations
Tax treatment varies by jurisdiction and individual circumstance. In many cases SMAs provide greater tax flexibility because gains and losses are realised within the investor's own account, allowing strategies such as individual tax-loss harvesting. In a pooled fund, the timing of gains and losses is determined at the fund level and may not align with an individual investor's tax position. Investors should consult their own tax advisors for guidance specific to their situation.
Custody
SMA assets are held at third-party prime brokers or custodians selected by or in consultation with the investor. Qlumina never takes custody. The account is opened and maintained in the investor's name; custodian choice depends on asset class, strategy, and technical compatibility with Qlumina's systems.
Minimum investment by asset class
FX & CFD
Typically $100,000–$250,000.
Equities
Typically $100,000–$250,000.
Futures
Generally $500,000–$5,000,000 notional, reflecting higher prime-broker margin. Investors with existing SMA structures at compatible brokers may cross-collateralise margin to lower the effective requirement.
Opening an SMA
Open a brokerage account
At a prime broker of the investor's choice, in the investor's name. The broker must support API connectivity, required liquidity and market data, and LPOA arrangements.
Execute agreement & grant LPOA
Sign the investment management agreement with Qlumina, grant the LPOA, and complete KYC/AML documentation as required under applicable regulations.
Notify broker & go live
The broker is notified of the LPOA scope. Once funded and documented, Qlumina begins managing the account; the investor retains full real-time access 24/7.
Fee architecture
SMA fees typically consist of a management fee (an annual percentage of assets under management, billed monthly on a pro rata basis) and a performance fee charged on net new profits above a high-water mark. Management fees are invoiced monthly at one-twelfth of the annual rate, applied to account value at the start of the billing period. Performance fees are calculated and payable monthly, subject to the high-water mark.
The high-water mark ensures performance fees are paid only on net new profits — the highest account value on which a fee has previously been paid (or the initial investment). The manager must recover any prior losses before earning further performance fees. For SMAs it is assessed monthly.
Example: An investor opens with $1,000,000. End of Month 1 the account is $1,050,000; a 20% fee is charged on the $50,000 profit ($10,000), setting a new high-water mark of $1,050,000. In Month 2 the account declines to $1,020,000 — no performance fee. In Month 3 it rises to $1,080,000; the fee is charged only on the $30,000 above the prior $1,050,000 mark ($6,000), and the new high-water mark becomes $1,080,000.
Liquidity & termination
SMAs offer daily liquidity. Because the investor owns the account and all positions directly, they may instruct liquidation or terminate the mandate on any business day, subject to market conditions and instrument liquidity — a significant advantage over pooled funds' monthly or quarterly redemption cycles.
To terminate, the investor gives written notice to Qlumina and the prime broker. Qlumina seeks to wind down open positions favourably, typically within 24–48 hours on the next available trading days. Once positions are closed and the LPOA revoked, the investor retains full ownership and control — the account remains the investor's property and does not close when the management relationship ends.
Chapter 04
AMC Architecture
How an AMC differs from an ETF or mutual fund
Unlike ETFs and mutual funds, AMCs are debt instruments issued by a specific issuer, exposing the investor to the issuer's credit risk in addition to market risk. They are typically not registered as collective investment schemes and do not hold segregated assets — the investor holds a claim against the issuer. In exchange, AMCs can be structured more flexibly, launched more quickly, and may provide access to strategies (concentrated or leveraged portfolios) that would be difficult in a regulated fund format.
Benefits
- Held in a standard brokerage or custody account like any other security.
- Transferable and potentially exchange-listed for secondary-market liquidity.
- Access to actively managed strategies without opening a separate managed account.
- Operationally simpler — a single security rather than a full portfolio mandate.
Key risk — Issuer credit risk
Because an AMC is a debt obligation of the issuer, issuer insolvency may result in loss of some or all of the investment regardless of the underlying strategy's performance. Assess the issuer's creditworthiness before investing. Additional risks include market risk, liquidity risk (secondary market may be limited), and operational risk.
Pricing & trading
AMCs are priced on the net asset value of the underlying strategy, calculated by the issuer or an independent calculation agent. Depending on structure, they may trade on an exchange or be redeemed directly with the issuer at NAV-based prices, subject to any applicable spread or redemption terms.
Fees & quarterly high-water mark
AMC fees include a management fee (annual percentage, billed monthly pro rata) and a performance fee on net new profits above a quarterly high-water mark — assessed only when end-of-quarter NAV exceeds the highest NAV on which a fee was previously paid.
An AMC launches at NAV $100. End of Q1 the NAV is $108; a 20% fee is charged on the $8 gain ($1.60/unit), setting the high-water mark at $108. During Q2 the NAV drops to $103 — no fee. End of Q3 the NAV rises to $112; the fee is charged only on the $4 above the prior $108 mark ($0.80/unit), and the new high-water mark becomes $112.
Minimum investment
Varies by issuance and is specified in each certificate's term sheet. Generally lower than hedge funds or futures-based SMAs.
Liquidity
Generally weekly subscription/redemption, subject to the term sheet and notice requirements. Secondary-market liquidity may apply if exchange-listed with a market maker.
Chapter 05
Hedge Fund Architecture
Structure & strategies
Qlumina's hedge funds are typically structured as limited partnerships or corporate vehicles domiciled in the BVI or another jurisdiction appropriate to the strategy and investor base. Each fund has constitutional documents (limited partnership agreement or memorandum and articles), an offering memorandum, and subscription documents. Qlumina manages or allocates to strategies across a range of styles and asset classes; availability changes with capacity and market conditions.
Minimum & eligibility
Hedge fund minimum investments are specified in each fund's offering memorandum and vary by strategy. Eligibility is generally limited to professional, accredited, qualified, or institutional investors as defined under applicable law. Retail investors are typically not eligible to invest in Qlumina's hedge funds.
When a hedge fund fits better than an SMA
Infrastructure-intensive strategies
HFT-style strategies need co-location, low-latency feeds, and optimised execution — infrastructure that can exceed $1M/year and is shared efficiently across a pool.
Economies of scale
Better execution pricing, lower per-unit costs, and more efficient margin/collateral use for high-frequency or large-notional strategies.
Market & counterparty access
Some brokers, exchanges, or OTC counterparties impose minimums or institutional requirements an individual SMA cannot meet; a fund can.
Netting & margining
Positions across strategies can be netted for margin, reducing capital required — harder across separate SMA accounts.
Operational simplicity
A single pooled portfolio enables rapid, coordinated changes with consistent execution for all investors.
Privacy & confidentiality
Investor identities and allocation sizes are not visible to other investors or market counterparties.
Investors should weigh these structural advantages against the transparency, ownership, and liquidity benefits of an SMA when selecting the most appropriate format.
Liquidity terms — lock-up, notice & gates
Hedge funds generally offer monthly liquidity, meaning investors may submit redemption requests once per month, subject to a notice period (typically 30 to 90 days as specified in the fund documents). Some funds may impose an initial lock-up period during which redemptions are not permitted. Funds may also have the right to impose redemption gates (limiting the total amount redeemed in a given period) or to suspend redemptions under extraordinary market conditions. These terms are designed to protect remaining investors by ensuring the manager can liquidate positions in an orderly manner. All liquidity terms are disclosed in each fund's offering memorandum.
Fee structure — management, performance, hurdle, HWM
Hedge fund fees typically include a management fee and a performance fee. The management fee is charged as an annual percentage of net assets, billed monthly on a pro rata basis (one-twelfth of the annual rate per month). The performance fee is charged on net new profits above a quarterly high-water mark. Some funds may also apply a hurdle rate — a minimum rate of return that must be exceeded before a performance fee is earned. All fee terms are set out in each fund's offering memorandum.
Quarterly HWM: the performance fee is assessed only on net gains above the highest NAV per share (or per interest) at which a fee was previously charged, calculated at the end of each calendar quarter. No performance fee is payable in any quarter where NAV has not surpassed the prior high-water mark — so the manager must recover any prior losses before earning additional performance fees.
Fund Administrator
An independent service provider responsible for day-to-day operational accounting — calculating NAV, processing subscriptions/redemptions, maintaining the investor register, reconciling positions and cash with the prime broker and custodian, and preparing periodic statements. The administrator provides an independent check on reported performance; NAV is typically produced monthly (or at the fund's dealing frequency) and is the basis for all fee calculations and investor reporting.
Auditor
An independent accounting firm examining the fund's financial statements, typically annually, for fair presentation under the applicable framework (e.g. IFRS or US GAAP) — covering NAV accuracy, asset existence and valuation, completeness of liabilities, and propriety of fee deductions. A clean audit opinion provides additional assurance beyond the administrator's calculations. Both owe professional duties to the fund (and indirectly to investors); the auditor maintains independence from the fund and manager.
Net Asset Value (NAV)
NAV is a fund's total assets minus liabilities, usually expressed per share/unit — the price at which investors subscribe or redeem. It is calculated by the fund administrator (hedge funds) or issuer/calculation agent (AMCs) at regular intervals: monthly for hedge funds, weekly for AMCs. Accurate, independently verified NAV is critical — it determines each holding's value, the fees payable to the manager, and the price at which subscriptions and redemptions occur; discrepancies can directly affect investor returns.
Chapter 06
AI & Technology
Qlumina integrates AI across its investment operations — as a tool that enhances human decision-making, never replacing human judgment or fiduciary oversight. All AI-derived insights are reviewed and validated by the investment team before being acted upon.
01 · Research
Strategy Development
ML models analyse large datasets, identify patterns, backtest hypotheses, and generate quantitative signals. No strategy deploys solely on AI output.
02 · Selection
Manager Evaluation
Proprietary tools analyse performance, risk metrics, and behavioural patterns to source managers with demonstrable skill — supplementing, not replacing, qualitative due diligence.
03 · Monitoring
Risk Management
Near-real-time monitoring detects anomalies, assesses factor exposures, stress-tests scenarios, and flags style drift, concentration, or unusual drawdowns.
04 · Decision
Human-in-the-loop
Experienced professionals make every final allocation, onboarding, and portfolio decision — exercising judgment and fiduciary responsibility.
Limitations & risks of AI
AI systems carry important limitations: they depend on input data quality (“garbage in, garbage out”); models may reflect historical biases or fail to anticipate unprecedented tail events; over-reliance without human oversight can cause systematic errors; outputs can be opaque (“black box” risk); and regulatory frameworks for AI in financial services are still evolving. Qlumina mitigates these through rigorous model validation, human-in-the-loop decision-making, ongoing performance monitoring, and regular AI governance review.
Model validation & audit
A multi-layered approach: out-of-sample testing, cross-validation, sensitivity analysis, and periodic independent review. Performance is tracked against benchmarks; models are retired or recalibrated if they fail predefined criteria. Full development and validation documentation is maintained.
Data sources & governance
Qlumina draws on market data (prices, volumes, fundamentals), alternative datasets (sentiment, satellite imagery, supply-chain data), and proprietary datasets from Qlumina's own operations and research — all sourced in compliance with applicable data-privacy and intellectual-property laws.
Chapter 07
Investment Strategies
Qlumina offers a range of strategies spanning different asset classes, geographies, and investment styles. Each strategy has its own risk-return profile, liquidity characteristics, and minimum investment requirements. Strategy availability may change over time depending on capacity and market conditions.
Investable universe
Solutions are constructed exclusively using highly liquid asset classes — primarily US Equities, FX “Majors” (USD, EUR, JPY, GBP, CHF), and highly liquid commodities — to ensure efficient execution, robust risk management, and scalable capital deployment.
Range of styles
Strategies span multiple asset classes, geographies, and investment styles — each with its own risk-return profile, liquidity characteristics, and minimums. Availability changes with capacity and market conditions.
Benchmarking & reporting
Each strategy is benchmarked against an appropriate index or peer group. Performance is reported net of all fees, with periodic reports (monthly or quarterly) showing performance, holdings where applicable, and risk metrics.
Multi-strategy allocation
Investors may allocate across multiple strategies, and Qlumina can structure a diversified allocation across SMAs, AMCs, and/or hedge funds based on objectives, risk tolerance, and capital.
Current strategies are described on the investment pages of our website. Investors are encouraged to discuss strategy selection with Qlumina's team to determine suitability.
Chapter 08
Performance Verification
No single source is sufficient. Qlumina triangulates across multiple independent data points to form an evidence-based view of a manager's true performance and risk characteristics.
Internally managed strategies
- NAV by independent fund administrators (hedge funds & AMCs)
- Annual audits by independent auditors (where applicable)
- Reconciliation against prime broker and custodian records
External manager verification
- Administrator NAV statements
- Audited financial statements (where available)
- Direct broker / prime broker statements
- Investor & broker references
- AI analysis of timestamped trade data
- Live pilot allocations within Qlumina's ecosystem
External manager verification procedures
- Administrator NAV statements: where a manager operates a fund with an independent administrator, Qlumina reviews the administrator's NAV reports as a primary source of verified performance data.
- Audited financial statements: where available and where the structure mandates an annual audit, Qlumina reviews audited financials. Not all structures require an audit — e.g. certain Alternative Investment Funds (AIFs) may be exempt depending on jurisdiction, size, or investor composition. In the EU, sub-threshold AIFs managed by managers below the AIFMD's AUM thresholds may not require a full external audit; certain BVI funds may qualify for lighter-touch reporting. The absence of an audit does not automatically disqualify a manager but requires additional verification through other means.
- Broker statements: Qlumina may request and review brokerage or prime broker account statements directly — an independent confirmation of trading activity, positions, and profit/loss.
- Investor and broker references: Qlumina contacts existing investors and the manager's prime or executing broker to gather qualitative and quantitative references on track record, operational integrity, and conduct.
- AI analysis of timestamped trade data: where the manager can provide timestamped trade data — from proprietary trading, SMA client accounts, or hedge fund accounts — Qlumina applies proprietary AI tools to analyse trading patterns, consistency, risk-adjusted returns, and potential anomalies. This is among the most powerful verification tools available, allowing granular, trade-level scrutiny that is difficult to fabricate.
- Pilot allocations within Qlumina's ecosystem: for promising strategies, Qlumina may conduct a live pilot allocation using capital from sophisticated early-stage investors with first right of refusal for high-Sharpe-ratio strategies — typically multi-strategy hedge funds, proprietary trading firms, experienced family offices, and first-loss capital providers who understand early-stage risks and accept higher risk for access to capacity-constrained opportunities. Pilots verify live performance, assess operational execution, and build confidence before broader allocation.
No single source of verification is sufficient on its own. Qlumina triangulates across multiple independent data points to form a comprehensive, evidence-based view of a manager's true performance and risk characteristics.
Chapter 09
Risk, Legal & Compliance
Capital is not guaranteed
No. Qlumina does not guarantee any return of capital or any rate of return. All investments are at risk, including the possibility of losing the full amount invested. There is no deposit protection scheme, government guarantee, or investor compensation fund applicable to Qlumina's products.
Principal risks
All investments carry risk, including the potential for total loss of capital. The principal risks include, but are not limited to:
Market risk
Value may decline due to changes in market prices, interest rates, exchange rates, or economic conditions.
Strategy risk
Any investment strategy may underperform or incur losses, regardless of historical results.
Leverage risk
Certain strategies employ leverage, which amplifies both gains and losses.
Liquidity risk
It may not always be possible to liquidate positions quickly or at favourable prices, particularly in stressed conditions.
Counterparty risk
Failure of a broker, custodian, issuer, or other counterparty could result in loss of assets or inability to execute.
Issuer credit risk (AMCs)
AMC investors bear the credit risk of the certificate issuer.
Operational risk
Errors, systems failures, fraud, or inadequate controls at any level of the investment process.
AI & model risk
AI-driven tools may produce erroneous outputs, fail to anticipate certain conditions, or introduce systematic biases.
Regulatory risk
Changes in laws or regulations in the BVI, the investor's home jurisdiction, or any investment jurisdiction could adversely affect returns or operations.
Concentration risk
Certain strategies may hold concentrated positions, increasing the impact of adverse events in a single security, sector, or market.
Currency risk
Investments denominated in a currency other than the investor's base are subject to exchange rate fluctuations.
This list is not exhaustive. Prospective investors should carefully review the offering documents and risk disclosures specific to each product before investing.
Conflicts of interest
Qlumina maintains a conflicts policy that identifies, manages, and where necessary discloses potential conflicts — arising from managing multiple products, allocating opportunities across products, or receiving fees from multiple sources. Where conflicts cannot be eliminated, they are disclosed in the relevant offering or account documentation.
Regulatory protections
The BVI FSC requires Approved Managers to comply with SIBA, the AML/CTF framework, and FSC codes of conduct. The BVI regime is designed for professional investors and may differ from onshore regimes (UK FCA, US SEC, EU AIFMD); protections may be more limited than in an investor's home jurisdiction. Seek independent legal advice.
If Qlumina ceases operations
- SMA investors retain direct ownership in their own brokerage accounts; the mandate terminates and the investor (or a successor manager) assumes control.
- AMC investors hold certificates issued by the third-party issuer; the term sheet governs what occurs on termination — the issuer may appoint a successor, wind down, or redeem.
- Hedge fund investors are subject to the fund's wind-down provisions; typically a liquidator realises assets and distributes proceeds pro-rata.
Chapter 10
Onboarding & Operations
Who is eligible
Qlumina accepts investments only from professional, accredited, qualified, or institutional investors as defined under BVI law and, where applicable, the investor's home jurisdiction. Retail investors are not eligible. Investor classification is verified during onboarding, and supporting documentation may be requested.
BVI professional-investor criteria
Individual investors generally qualify by meeting one or more of:
- Net worth (individually or jointly with a spouse) of at least US$1,000,000, excluding the primary residence.
- Annual income of at least US$200,000 (individually) or US$300,000 (jointly) in each of the two most recent years, with a reasonable expectation of the same level this year.
- Sufficient professional experience, knowledge, and expertise to understand the risks and make informed investment decisions.
These thresholds are based on the BVI framework and may be supplemented by the investor's home jurisdiction. Qlumina may apply stricter internal criteria and decline any investor who does not meet its suitability standards.
KYC / AML onboarding
All prospective investors must complete Qlumina's onboarding process, including identification documents, proof of address, source of funds and wealth declarations, and such other information as required to comply with BVI AML/CTF regulations and Qlumina's internal compliance policies. Qlumina is committed to the highest standards of AML compliance and may decline any prospective investor who does not satisfy its requirements.
Identification
Government ID and entity documents.
Proof of address
Residential / registered-address verification.
Source of funds & wealth
Declarations per BVI AML/CTF regulations.
Eligibility verification
Investor classification confirmed; Qlumina may decline.
Contact & complaints
Investors and prospective investors may contact Qlumina through the details provided at qlumina.com. Qlumina maintains a complaints-handling procedure; complaints are acknowledged and addressed in accordance with internal policies and applicable regulatory requirements.
Chapter 11