A London-based multi-family office, regulated by the Financial Conduct Authority (“FCA”), sought to create a structure that would allow its clients to participate collectively in high-value investment opportunities. While the firm consistently sourced lucrative opportunities, many had minimum entry requirements, often in excess of £1 million per investor, making it impractical for many individual clients to participate directly.

AZJ Legal designed and implemented a bespoke nominee aggregator structure in Gibraltar, enabling the family office to pool investor capital for specific deals while preserving individual ownership and accountability for each investment. The structure operates on a deal-by-deal basis rather than as a collective investment fund, allowing each investor to choose which opportunities to join and to track their separate profit and loss positions.

The structure was finalised and launched in collaboration with a regulated Gibraltar trustee company. This innovative vehicle, believed to be the first of its kind in Gibraltar, combines the jurisdiction’s flexible corporate and trust framework with compliance standards that parallel those of the FCA in the UK, while remaining outside the scope of collective investment scheme regulation.

AZJ Legal drafted the nominee and participation agreements, prepared explanatory materials for the family office to present to their clients, and coordinated implementation with local fiduciaries. The end result was a fully operational, compliant, and scalable vehicle within a short timeframe.

The outcome was transformative: the family office gained the ability to offer larger, more diversified deals to its clients, without the regulatory and administrative burden of fund formation. Investors benefited from access to high-yield investment opportunities that were previously unavailable to them individually, and both the family office and investors achieved significant cost efficiencies.