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 have answered in error, write to patrimony@bayswatertransflow.com stating so, and the answer will be corrected. Corrections are made in writing rather than by re-selection, so that the operation of this gate remains demonstrable.
Already written to us and received a code in reply?
The code stands. Your earlier answer is set aside on the written record you already made with us.
Your answer constitutes a representation as to your status, made by you and relied upon by Bayswater Transflow in determining whether this material may lawfully be made available to you. It does not transfer or diminish any obligation of the firm under section 21 of the Financial Services and Markets Act 2000, which remains the firm's alone. A representation made falsely is a misrepresentation on which the firm is entitled to rely, including by declining or rescinding any subsequent dealing. Your answer is stored locally in your browser only; it is not transmitted to, or recorded by, the firm.
Patrimony · The funds
The fund tree, read from the top.
Somebody sends you a document with the word Fund on the cover, and by the second page it has become a defined term. That defined term is doing all the work. In the Dubai International Financial Centre a fund is never simply a fund: it stands on one of three tiers, it carries a domicile, and both facts were settled long before the paper reached your hand. What follows is the tree, so that when the term appears you already know which branch you are on. Stated as at August 2026, and read again on any day it matters.
01 · The three tiers
Terrain
Three tiers, and the tier decides everything after it.
The Centre does not run one fund regime. It runs three, arranged as a ladder, and almost every obligation on the page in front of you follows from which rung the vehicle stands on. The Collective Investment Law and the DFSA's Collective Investment Rules build that ladder. The tier is chosen when the fund is formed, not when you are shown it.
- The public tier
A Public Fund may be offered to the public, which is to say its units may reach a Retail Client, and the regime is built to that fact. The fund is registered with the regulator before units are offered, a prospectus is issued and must carry prescribed content, independent oversight and an eligible custodian sit between the manager and the assets, and reporting runs for the life of the vehicle. Heaviest regime, widest audience: not two features, one feature stated twice.
- The exempt tier
An Exempt Fund is not offered to the public at all. Units travel by private placement to Professional Clients only, the number of holders is capped by rule, and the fund is notified to the regulator rather than registered by it. What reaches a family is an information memorandum carrying prescribed disclosure, not a prospectus standing behind a registration an authority granted. The protection has not vanished. It has moved, onto your classification and your own advisers.
- The qualified investor tier
The narrowest of the three. Private placement to Professional Clients, a tighter cap on holders, and a stated minimum subscription per investor fixed by rule. That minimum is the gate, and the exclusion is the design rather than an accident of it. The regime is the lightest of the three, and it is lightest because of who it has already shut out.
- Who each tier admits
Only the public tier can reach a Retail Client. The other two are shut to one, so the regime's first question is not about the fund at all. It is about you. A natural person is assessed as a Professional Client on a net asset test set at USD 1,000,000, taken with a test of relevant knowledge and experience, and undertakings qualify on separate balance-sheet tests. Classification comes before the document, and decides which documents may lawfully reach you.
Each rung down trades mandated protection for speed, and assumes you arrived carrying your own. The tier is stated once, in a defined term nobody reads aloud. Read it as the whole of the regime, because that is what it is.
02 · Where the vehicle lives
The second axis
A fund has a home, and its home is not always where its manager sits.
Tier is the first axis. Domicile is the second, and the two are independent. The Centre sorts funds by where they were constituted and by who manages them, and the sorting is not cosmetic: it settles which law made the thing you are being offered.
Constituted in the Centre, under the Centre's own law, and entered on the DFSA's register. The rulebook governing it is the one set out above, and the court that would construe its constitutional documents is the Centre's own. One legal place, one body of law: ask separately who manages it and under whose licence, because those two answers are not always in the same country.
Constituted outside the Centre, managed by a firm the DFSA licenses. Two bodies of law now meet inside one arrangement: the vehicle answers to the law of its own home, the manager answers to the DFSA for how it runs it. Nothing about that is improper. What matters is knowing which of the two your protection comes from, because a family that assumes both is protected by neither in the gap between them.
Constituted outside the Centre and managed from outside it. It can still be offered to a family in the Centre, but it arrives through the rules governing that offer rather than by belonging to the tree, and it does not become a Domestic Fund by being sold to somebody standing inside the zone.
Domicile settles which law constitutes the vehicle, which court construes its documents, and where your remedies sit if a term is tested. Where the family itself lives is a separate question again, under a separate body of law, set out at where you live.
Two axes, two questions, both answered before substance. Everything after them hangs from an answer you already hold.
03 · The onshore passport
Across the boundary
Outside the Centre is a different regulator's country.
Step across the boundary and you are in the United Arab Emirates proper, where the Securities and Commodities Authority governs the promotion of investment products to persons onshore. The word passported gets used at tables, warmly and quickly. It describes something real and precise, and the precision is whose permission it is.
- 01 The line at the boundary Onshore UAE and the two financial free zones are separate regulatory territories. To the SCA, a fund domiciled outside onshore UAE is a foreign fund, and a DIFC fund is domiciled outside onshore UAE. The Centre's registration of a vehicle says nothing about what may be promoted in the country around it.
- 02 To onshore retail, closed Promotion of a foreign fund to retail investors onshore is prohibited. Not conditioned, not documented into permissibility, not cured by the standing of whoever does the promoting. Prohibited.
- 03 To onshore professionals, licensed and registered Promotion to professional investors onshore is permitted on a private placement basis, and only by a person the SCA licenses to carry on promotion, or through an offering registered with it. The gate is a licence and a registration. Both are held by somebody in particular, and both can be named.
- 04 The passport, and what it covers Funds domiciled in the DIFC or in ADGM have a dedicated route: a streamlined registration with the SCA for onshore marketing, lighter than the general foreign fund path. Read what it attaches to. The passport belongs to the fund and to its manager. It is not a travelling permission passing to whoever carries the document, and it does not license a separate, unlicensed party to promote that fund to an onshore resident on its own account.
Told that a vehicle is passported onshore, you have been told something true about the fund. You have been told nothing at all about the person telling you.
04 · The questions
At your own table
Three questions, and the order is the whole method.
Order matters, because each answer narrows what the next is allowed to mean. Asked in sequence, before anybody opens a page of substance, they cost a minute.
Public, Exempt or Qualified Investor. Ask before reading a word of substance: the answer tells you what a regulator has examined, what it has merely received, and what has quietly been left with you. Then ask where the tier is stated in the document, and read that line with your own eyes.
Domestic, External or Foreign. Which law constitutes the vehicle, which regulator supervises the manager, and whether those are the same legal place. Where they differ, ask which of the two your custody arrangements, redemption terms and remedies sit under. A competent counterparty answers in a moment. Hesitation is itself information.
Every document in front of you stands on a registration an authority granted, on a notification it merely received, or on neither. Ask which authority sees this page, at what moment, and which of the three it is. The DFSA, the SCA and a foreign home regulator are different answers, and only one is true for any given document.
None of these is an accusation, and no serious house hears them as one. They are the questions the drafter answered before the document was printed.
05 · The honest line
Stated plainly, once
Nothing on this page recommends any vehicle.
No fund is named here and none ever will be. No tier is better than another: a Qualified Investor Fund is not a superior product, it is a lighter regime behind a higher door, and whether any of it suits a particular family is a question for the institution licensed to answer it and for your own solicitor. This firm does not speak to merits, and least of all on a page about structure.
Bayswater keeps no office, no staff and no presence in the Centre. It holds no licence from the Dubai Financial Services Authority and needs none, and nothing here suggests that the DFSA authorises, licenses or endorses this firm, because it does not. The work is carried on from the United Kingdom, the position settled with United Kingdom counsel before any engagement begins, and every advantage this firm stands to receive is disclosed to you in writing before work starts. The manager across the table forms its own advice, in its own name, under the conduct rules it is examined against. The same tree, drawn in the other centre's terms, sits at the ADGM funds.
We describe the tree, in daylight, to anyone entitled to read it. Someone licensed to do so chooses the branch, and it is never us.