Jersey Finance
Elliot Refson
Feb 2026
Elliot Refson, head of funds at Jersey Finance, explains how Jersey serves as a gateway for cross-border private placements, as high net worth and family office investors drive demand for bespoke investment vehicles amid a fundamental shift in fund structures
Image: Jersey Finance
Given the growing importance of private capital, how do you see Jersey’s role as a non-EU jurisdiction complementing key onshore centres like Luxembourg in a multi-jurisdictional fund structure?
Jersey is seen as the jurisdiction of choice for specialist funds, offering a compelling alternative to larger domiciles such as Luxembourg.
While Luxembourg has long been recognised as a hub for pan-European access, Jersey differentiates itself by providing a framework designed for agility, clarity and highly bespoke solutions.
In a multi-jurisdictional world Jersey solutions are ideally placed to support fund managers with bespoke and often more complex fund structures.
What sets Jersey apart is that it is never about a one-size-fits-all approach. Our focus is on solutions that are as nuanced and tailored as the strategies they underpin. This makes Jersey a natural complement to onshore centres like Luxembourg, offering fund managers and investors the confidence that even their most complex requirements can be met.
Jersey has recently updated its Private Funds regime. How do these changes, such as the removal of the 50-investor cap and the 24-hour authorisation process, enhance its appeal for fund managers focused on cross-border private placements?
Yes, the recent enhancements to the Jersey Private Funds (JPF) regime mark a significant step forward in strengthening its position as the go-to framework for cross-border private placements.
The changes are about accelerating launches to ensure fund managers can bring strategies to market with remarkable speed. In an industry where timing and precision are critical, this level of responsiveness is a real differentiator.
The JPF regime lowers barriers to entry and operational costs for cross-border placements. This not only attracts managers seeking alternatives to more bureaucratic domiciles but also supports Jersey’s role in channeling diverse global capital flows. In essence these changes have moved the JPF to a ‘plug-and-play’ framework that balances speed, flexibility, and credibility.
Can you provide a practical example of how a Jersey-based fund would work in tandem with a US-based fund or a UK limited partnership to raise capital from global investors?
Let us say a US-based private equity manager launches a US$1 billion technology fund with a parallel structure: a Delaware limited partner (LP) for US investors (US$400 million) and a JPF for non-US investors (US$600 million). The Jersey fund leverages tax neutrality and the National Private Placement Regime (NPPR) to attract European investors and also attract Asian investors (outside the scope of NPPR), while the US fund aligns with domestic regulations. Both funds, managed by a single general partner (GP), co-invest proportionally (e.g. a 40:60 split for a €100 million deal) under shared governance. This setup optimises tax and regulatory compliance, streamlines global fundraising, and addresses investor preferences.
NPPRs are a key component of Jersey’s strategy. What are the operational and cost efficiencies for asset managers that make them a more attractive route for a certain class of funds compared to the full AIFMD passporting regime?
The first point to consider is whether you need to market into Europe under the cost and onus of the full Alternative Investment Fund Managers Directive (AIFMD) passport regime. By the EU’s own statistics only 3 per cent of managers market into more than three European countries. Which means that 97 per cent do not.
For those managers then the NPPR regime is a more cost effective, faster, and more streamlined solution which is outside of the full scope of the AIFMD. And of course marketing outside of Europe from Jersey is out of scope of the AIFMD.
In the context of private placements, how is Jersey’s well-established legal and regulatory framework for alternative asset classes, such as real estate and private equity, being leveraged to attract managers in other jurisdictions?
In Jersey, 90 per cent of all funds are alternative-investment-focused. As a subset of this and as at June 2025, there were 246 alternative investment fund managers using NPPR to market 454 alternative investment funds into Europe.
How do the recent trends you have observed, such as the shift from institutional investors to family offices and high-net-worth individuals, influence the design of fund structures for cross-border private placements?
Over the past years, Jersey and other fund centres have experienced a notable shift in investment structures. While traditional collective investment funds have seen a decline of around 50 per cent, overall assets under management (AUM) have continued to grow. This trend reflects a move away from institutional investment in alternatives.
High-net-worth and family office investors are investing selectively in specific opportunities. As a result, we have seen a marked increase in bespoke investment vehicles.
Beyond the US, UK, and Luxembourg, which emerging or key fund jurisdictions are you seeing increased interest from, and how is Jersey positioning itself to facilitate capital raising from these regions?
We are seeing increased interest from the Middle East, South Africa, and Asia. Many of Jersey Finance’s member firms have a presence in these markets and many more have adopted a fly in operation. At Jersey Finance we support these activities with a regional hub in Dubai and a presence in South Africa, Singapore, and Hong Kong through which we promote the jurisdiction to intermediaries, managers and the investment communities.
With the rise of digital assets and tokenisation, how are you preparing Jersey’s private placement framework to accommodate these new technologies, and what role can they play in streamlining cross-border capital flows?
We are highly supportive of innovation in Jersey, including digital assets and tokenisation. When tokenisation is structured as securitisation, these vehicles are not classified as a fund and fall outside of the AIFMD.
Jersey continues to champion financial innovation and has strong expertise in digital assets, tokenisation, and other emerging technologies.
From an asset servicing perspective, what are the key challenges or considerations for fund administrators when dealing with complex, multi-jurisdictional private placement structures involving a Jersey fund vehicle?
Fund administrators managing Jersey-based funds marketed into Europe via National Private Placement Regime (NPPR) bring a strong track record in navigating regulatory, operational, and investor related requirements. They handle AIFMD and upcoming AIFMD II obligations including Annex IV reporting, sustainability disclosures, and country-specific NPPR rules. With well-designed systems and experienced teams, our administrators support efficient and compliant fund operations across jurisdictions, helping fund managers achieve their objectives with clarity and reliability.
Looking ahead to the next five years, what do you see as the single most significant factor — be it regulatory, technological, or market-driven — that will shape the future of cross-border private placements and Jersey’s role in it?
The single most significant factor shaping cross-border private placement will be the ongoing evolution of the marketplace.
Over the next five years, we anticipate considerable change as the industry shifts away from traditional collective investment funds towards investor-driven funds. If you factor in new technology such as tokenisation there will inevitably be a seismic shift in the regulatory framework affecting cross border asset raising.
One area where Jersey has excelled time and time again is in balancing innovation with robust compliance and this will continue to be the case.
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