This article, authored by Dechert associate Craig Borthwick, appeared in Issue 338 of HFMWeek, May 2014.
Full scope depositary requirements do not apply to EEA AIFMs managing non-EEA 'offshore' funds. Instead, if the offshore fund is being marketed in the EEA under the private placement regime, AIFMD article 36 requires that a 'depositary-lite' regime will apply (at a minimum).
