If title to units in a private investment fund is transferred to a professional investor,...

The CISI UAE Financial Rules and Regulations imposes restrictions on transfers of title to units in private investment funds. Such units may be transferred to existing unit holders, to specified family members in the case of a family fund, or to a professional investor or counterparty subject to an important minimum-value condition. Where the transferee is a professional investor or counterparty, the nominal value of the transferred units must be at least AED 180,000, or the equivalent amount in another currency. This restriction reflects the private nature of the fund and ensures that transfers to new professional participants continue to satisfy the regulatory parameters applicable to private-fund investment. It also differentiates private funds from publicly promoted investment products, which are subject to different offering and distribution requirements. AED 120,000, AED 220,000 and AED 280,000 are not the thresholds specified by the CISI syllabus. Therefore, where ownership is transferred to a professional investor under the relevant private-fund rules, AED 180,000 is the minimum nominal value and option B is correct.

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