Holding Restrictions – Investment Funds – Gibraltar


Restrictions on customers

Pursuant to the Sanctions Act 2019, individuals domiciled in countries which are subject to international sanctions recognised by Gibraltar, will not be accepted as investors of any Gibraltar-based funds.

U.S. investors can only be accepted in accordance with U.S. law. Thus, the Gibraltar fund will generally accept U.S. investors as long as the fund is compliant with U.S. law.

Restrictions on settlement

There is no general restriction on settlement of Gibraltar investment funds through CBL. However, certain funds may impose specific settlement/transfer restrictions. Customers must refer to and abide by the restrictions (if any) contained in the fund prospectus before entering into transactions.


The information contained in the Holding Restrictions is based on the legal opinion obtained by CBL that was issued on 3 March 2022. CBL believes the information to be correct as of that date but disclaims any responsibility as to the accuracy and completeness of the information after that date. In the case of discrepancy between the information provided by CBL and the local laws and regulations, the latter shall prevail. The Holding Restrictions do not constitute legal advice and customers should seek advice from independent professional counsel.

Customers are responsible for ensuring compliance with the disclosure requirements and agree to indemnify and hold harmless CBL, for any loss, expense, liability, damage or claims, whether direct or indirect, against or incurred by CBL arising out of or resulting from such non-compliance.