Patrimony · Restricted access
Before this door opens, the law asks who you are.
The families and institutions this practice serves are not named here, and never will be.
Nothing on this website is an offer, a recommendation, or a view on the merits of any investment. To the extent that any part of it is an invitation or inducement to engage in investment activity within the meaning of section 21 of the Financial Services and Markets Act 2000, it is directed only at the persons described below, and it must not be acted on by anyone else. The four paragraphs that follow are short, they are the law, and they are the reason this door is shut.
Under section 21 of the Financial Services and Markets Act 2000, a firm that is not authorised by the Financial Conduct Authority must not communicate an invitation or inducement to engage in investment activity unless an exemption applies. Contravention is a criminal offence under section 25, and under section 30 an agreement that results from an unlawful communication may be unenforceable against the person who received it. Those consequences fall on the communicator. That is why this firm, and not you, polices this door.
This room relies on the exemptions in the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005. Article 19 admits investment professionals: authorised and exempt persons, and persons whose ordinary activities involve carrying on activity of the kind this room describes, for the purposes of a business. Article 49 admits high net worth companies, unincorporated associations and trusts that meet the thresholds the Order sets. A family office ordinarily enters through the vehicle it operates: where that company or trust meets the Article 49 thresholds, it may pass; a private individual does not pass by standing behind it. The conditions of both Articles require proper systems and procedures to keep this material from being acted on by anyone else, and this gate, together with the declarations it takes and the correction protocol beneath, is how those systems are kept.
Then this room is not directed at you. The protections the law builds for retail investors exist precisely so that material of this kind does not reach them. A declaration made in words you know to be untrue is a misrepresentation: English law allows the party who relied on it to set aside what followed from it, and this firm will use that right, including to refuse any dealing that began at this door. You would stand outside every protection the regime built for you, by your own hand. We ask you instead, plainly and with respect, to go no further.
The categories above are creatures of United Kingdom law. No foreign equivalence exists and none is claimed: your own country's law decides what may lawfully be put in front of you and what you may act upon, and a number of jurisdictions restrict their residents from acting on foreign material of this kind. By proceeding, you confirm that you may lawfully do so under the law of your place of residence. That confirmation, and that responsibility, are yours alone.
Now tell us who you are. We will hold you to it exactly as far as the law does.
Then we must ask you to stop here, and we ask it with respect.
The rules that close this room to private individuals exist for their protection, and we keep them to the letter. Nothing you have seen on this page is an invitation to engage in investment activity. If your family maintains an office or retains professional advisers, they are welcome to read this room and to write on your behalf. If you answered in error, write to the firm at its registered address, marked Patrimony, and say so: the correction is made in writing, not by a second click, because the record of who passed this gate is part of how the gate is kept.
By answering, you make a formal representation of your own legal status, on which this firm relies as its grounds for opening this room. The duty under section 21 is ours and it stays ours: your declaration does not move it, and was never asked in order to move it. What a false declaration does is different: it is a misrepresentation, yours to answer for, on which this firm will rely. The answer is held in your browser and transmitted nowhere: this site collects nothing.
Patrimony · ADGM
The younger centre, read closely.
Somebody in your family has already said the words Abu Dhabi, and somebody else has already asked what law would actually govern the arrangement. The Abu Dhabi Global Market is a common-law jurisdiction with its own courts and its own regulator, seated inside a civil-law country. If your capital is going to meet a regulated manager in the emirate, this is the ground it will meet on. What follows is that ground, described the way a family should have it described: the statute, the lines it draws, and where this firm stands in relation to them.
01 · The ground itself
Terrain
A common-law jurisdiction, inside a civil-law country.
The ADGM is not a district of Abu Dhabi with a helpful tax posture. It is a financial free zone with its own legal system, standing beside the onshore law of the United Arab Emirates rather than inside it. Four facts about it do the work, and a family should hold all four before anything else is discussed.
- The zone
An English-language jurisdiction with its own body of law, its own registrar and its own regulator, sitting inside the emirate. A manager licensed there is licensed there, and not elsewhere in the country: the free zone and the onshore United Arab Emirates are two different legal places, and confusing them is the first mistake an unprepared file makes.
- The courts
English common law applies in the ADGM directly, and the ADGM Courts sit in English to apply it. For a family that has ever had a document construed in London, that is not an atmosphere. It is a known set of rules about how a contract will be read, what a fiduciary owes, and what a court will do when a term is tested.
- The regulator
The Financial Services Regulatory Authority regulates financial services in the zone under the Financial Services and Markets Regulations 2015. It licenses the manager across the table, writes the conduct rules that manager works under, and examines it against them. A longer read of that regulator sits at the FSRA, read for families.
- What that gives you
Contracts in English, a common-law court in which to test them, a regulated counterparty under published conduct rules, and a rulebook your own solicitor can read in an evening and then hold everybody to. Including us.
02 · The text
Why the drafting matters
Written close to English statute, and close on purpose.
Both Gulf centres are conceptually familiar to an English lawyer. The ADGM goes further than familiar. Its regulations were drafted with close and literal parallels to the United Kingdom's, which means the two systems read each other natively: a provision here has a counterpart there, in the same place, doing the same job, and the reader is not translating between two traditions while somebody's capital waits.
Section 19 of the Financial Services and Markets Regulations 2015 prohibits carrying on a Regulated Activity in or from the ADGM without authorisation. The shape will be familiar: the United Kingdom's own general prohibition sits at section 19 of the Financial Services and Markets Act 2000. The parallel runs deeper than the section number, and it is the reason the rest of this page can be stated so plainly.
Schedule 1 to the Regulations specifies the regulated activities, among them dealing in investments as principal or agent, arranging deals in investments, advising on investments or credit, and managing assets. Arranging and advising are separate perimeters, independently regulated, exactly as they are in the United Kingdom. A party may work on process, structure and terms and never offer a view on the merits, and the discipline of never crossing that line is the whole architecture of this practice.
Within Chapter 2 of Schedule 1, among the exclusions to arranging, sits a provision headed Arranging deals with or through Authorised Persons, at paragraph 21. It contemplates arrangements made by a person who is not an authorised person, for or with a view to a transaction to be entered into by a client with or through an authorised person, where the transaction is entered into on advice given to the client by an authorised person, or where it is clear the client has not sought that arranger's view on the merits. It carries carve-outs, including one that switches the provision off where a reward received from anyone other than the client has not been accounted for to the client.
Schedule 1 carries a second and separate exclusion, at Chapter 18, for Non-ADGM Persons: arrangements made by a party with no ADGM presence, confined to transactions entered into by Authorised Persons or Exempt Persons, and advice given as a result of what the Schedule terms a legitimate approach. It stands alongside the first exclusion rather than instead of it, and it reinforces the territorial line that section 19 already draws.
The legislators there wrote a door for a party who stands beside a transaction without being inside it. We did not invent our shape. We read it in their statute.
03 · What a family finds inside
The room
The institution across the table opens its own file on you.
Terrain is not only statute. It is what actually happens to a family that walks into a regulated house in the zone, and it happens in a fixed order whether or not anyone has warned you first. We warn you first.
The Conduct of Business Rulebook sorts clients into Retail, Professional and Market Counterparty, and the sorting decides what the manager owes you. A natural person is generally assessed as a Professional Client at USD 1,000,000 in assets together with relevant experience or professional certification; institutions and large undertakings qualify on separate balance-sheet tests. Families of the scale this practice serves sit in the professional tiers, comfortably.
Lighter mandated protections and lighter mandated warnings, in exchange for more of the weight sitting on your own file and your own advisers. The regime assumes you arrived already protected. Our work is making that assumption true before it is tested, not after.
The institution runs its own diligence and forms its own advice to you under its regulator's conduct rules, and it is examined against those rules. Your decision rests on that advice and on your own solicitor, never on anything this firm has said about merits, because this firm does not speak to merits at all.
The zone holds its licensed houses to strict provenance regimes aligned with international standards, and serious ones ask hard, patient questions about where capital came from, across decades if the answer runs that far back. Expect the questions. Expect our file to have answered them before they were asked.
Nothing we prepare replaces the institution's own examination. The file is built expecting exactly that examination.
04 · The order of the room
What to expect
Five things happen, and they happen in this order.
This is the ADGM side of the sequence, seen from your chair rather than ours. The full spine of the work, from the first question to completion, is set out in the mandate.
- 01 You are classified Before substance, status. The manager categorises you under its conduct rules and records why. Ask to see the reasoning, and read it: it sets the duties you are owed for the whole of the relationship.
- 02 Its diligence begins, independently The institution examines your position for itself, on its own criteria, with its own committee. It is not reviewing our conclusions. It is forming its own, and a house that did neither would be the wrong house.
- 03 Provenance is put to you directly Where the capital came from, through which hands, under which regime, evidenced. The questions can seem intrusive to a family that has never been asked them. They are the regulated house behaving exactly as it should.
- 04 The institution advises you, in its own name Its recommendation is formed under its regulator's conduct rules, given by a licensed party answerable for it. This movement is never compressed and never skipped. It is the protection that survives everything else in the room.
- 05 Terms are written, with our interest on the page Every interest this firm holds in the outcome is already on your engagement terms, disclosed to you in writing before any of the work began, not in a footnote produced afterwards. You should never have to ask a firm what it stands to gain. You should already be holding the paper that says so.
A family that knows the order of the room is never surprised inside it.
05 · Where we stand
Design, stated
No office in the zone, no licence, and no need of one.
Bayswater keeps no office, no staff and no presence in the ADGM, and that absence is deliberate. This firm holds no licence from the Financial Services Regulatory Authority, and nothing on this page should be read as suggesting that the FSRA authorises, licenses or endorses it, because it does not. The work is carried on from the United Kingdom, under the exclusions and exemptions United Kingdom law provides for it, while the manager across the table answers to its own regulator in full.
That is why the ADGM's textual closeness to English statute matters to a family and not only to lawyers. Each side of the table stands under exactly one body of law, both sides know which, and the two bodies of law were written close enough together to be read side by side without a translator. When something is tested, nobody is discovering the architecture for the first time.
Outside the zone, beside the table. Read the statute, and you will find our shape already drawn in it.