Practice Areas Funds & Investment Management

Regional Leader in Fund Formation & Establishment

GLA & Co advises the full spectrum of sponsors, managers and institutional investors on the structuring, formation, operation and distribution of investment funds across the GCC and broader MENA region, with particular depth under the regimes of the DIFC, ADGM, onshore UAE (SCA), Saudi Arabia (CMA), Qatar (QFC and onshore QFMA), and Kuwait (CMA). We combine market-leading technical capabilities with practical execution, drawing on our regional platform and bilingual teams to deliver commercial, regulator-ready solutions.

Our Offering

We advise on private equity, venture capital, private credit, real estate and REITs, infrastructure, hedge and hybrid funds, evergreen and semi-liquid structures, co-investments, managed accounts, continuation vehicles, secondaries and GP-led liquidity solutions, as well as day-to-day governance, compliance, and regulatory engagement across the lifecycle. Our practice integrates closely with corporate, M&A, tax and disputes to support manager formation, portfolio transactions, financing, carried interest and management incentive arrangements, and enforcement and restructuring scenarios.

We are deeply experienced in mapping strategy and target investor base to the optimal product category and legal form in each jurisdiction; building and diligencing the provider stack (custody, administration, audit, valuation, and Shari’a governance); preparing regulator-facing business plans, policies and documentation suites; obtaining manager and product permissions; and coordinating cross-border distribution and post-launch compliance.

Jurisdictional Expertise and Regulatory Pathways

DIFC (DFSA)

The DIFC offers Public Funds, Exempt Funds and Qualified Investor Funds (QIFs), with ascending degrees of regulatory intensity and streamlined processes for Exempt Funds and QIFs subject to investor thresholds and minimum subscriptions. We regularly help clients choose among investment company, investment partnership, and investment trust forms, including cell structures for umbrella products.

Managers may be authorized locally as a Domestic Fund Manager or rely on the External Fund Manager regime for recognized foreign managers, and we frequently employ hosted platforms to accelerate time-to-market. Our work spans full documentation suites (constitutional documents, offering memoranda, class supplements, valuation and conflicts policies, custody/administration arrangements) and DFSA filings through approval/notification.

We also advise on ongoing valuation and custody independence, liquidity management and stress testing for open-ended funds, AML/CTF and sanctions controls, recordkeeping and governance, and marketing rules within the DIFC and into onshore UAE (SCA overlay).

Common planning points include aligning fund category to investor thresholds and liquidity, documenting delegation/outsourcing lines, and coordinating UAE federal corporate tax and treaty access considerations for cross-border portfolios.

ADGM (FSRA)

In ADGM, we regularly structure Public Funds, Exempt Funds and QIFs, advising on company, limited partnership and investment trust forms as well as PCC/ICC umbrellas for multi-strategy platforms. We tailor pathways for ADGM-based fund managers, external manager models, and hosted arrangements, preparing FSRA application packages and product submissions calibrated to strategy and investor base.

Our documentation covers constitutional instruments, offering materials, class/cell supplements, investment management and service agreements, and policy suites for valuation, liquidity, equal treatment and conflicts. We guide launch readiness (AML/KYC, onboarding, FATCA/CRS) and steady-state operations (audits, investor reporting and regulatory returns).

We also advise on ADGM marketing rules, and the additional SCA steps required for any onshore UAE outreach, as well as governance expectations for local mind and management and corporate tax interactions with free zone status.

We routinely help clients avoid pitfalls around category misalignment, valuation and custody independence for private assets, onshore marketing without SCA compliance, and delayed tax planning for cross-border portfolios.

Onshore UAE (SCA)

Onshore funds are regulated by the SCA, with distinct regimes for public funds, private/professional funds and specialized products such as REITs, ETFs, money market and Islamic funds. We advise on selecting contractual versus corporate vehicles where permitted, and on embedding Shari’a governance in Islamic offerings.

Foreign managers typically participate as advisers or sub-managers to an SCA-licensed local manager; we structure these models, secure approvals and align documentation across fund and service contracts, valuation and liquidity frameworks, side letter and equal treatment policies, and conflicts governance.

We manage SCA processes for public approvals and streamlined professional offerings, guide operational readiness and ongoing obligations, and coordinate distribution strategies through SCA-licensed promoters for mainland marketing.

Our advice emphasizes local substance and oversight in line with SCA expectations, and navigates UAE federal corporate tax, qualifying investment fund exemptions, VAT and treaty access impacting fund flows.

Saudi Arabia (CMA)

Saudi funds operate under the CMA’s Investment Funds Regulations and product-specific rulebooks (real estate/REITs, private equity/VC, ETFs, money markets), with a licensed Authorized Person (AP) managing investments/funds and CMA product approvals calibrated to fund type. We structure public and private funds, conventional and Islamic, including specialized products with external valuation and real-asset requirements.

Foreign managers typically engage via sub-advisory or delegated portfolio management through a local AP. We prepare AP applications, delegation frameworks, and complete product suites (constitutional documents, offering materials, valuation and liquidity tools, Shari’a governance for Islamic funds) and handle CMA submissions.

We guide steady-state compliance including valuation independence for illiquid assets, custody, liquidity management for open-ended funds, AML/CTF, periodic reporting, outsourcing oversight and Shari’a audit.

We also advise on onshore marketing for foreign funds through CMA-licensed channels, with careful treatment of reverse solicitation and investor eligibility thresholds, and on the Saudi tax/Zakat interface for mixed GCC and non-GCC ownership.

Qatar Financial Centre (QFC) and onshore State of Qatar (QFMA)

In the QFC, we align strategy and investor base with retail/public, professional/qualified investor and specialized funds within the QFCRA’s Collective Investment Scheme regime, advising on investment company, partnership and trust formats including Islamic structures. We prepare manager authorization packages and product filings, and coordinate service providers, governance and Shari’a oversight.

We also cover incorporation/licensing, offering documentation, AML/KYC and launch readiness, and ongoing requirements around valuation, custody, liquidity, conflicts, reporting and outsourcing.

For distribution into the State of Qatar outside the QFC, we advise on the QFMA’s approval/registration requirements, the role of licensed local distributors, Arabic documentation and selling restrictions, and the limited scope of reverse solicitation.

Kuwait (CMA)

Kuwait’s CMA distinguishes public funds and private/professional funds and prescribes licensed roles for managers, custodians, administrators/registrars and distributors. We structure contractual fund vehicles (market standard), corporate forms where permitted, and Islamic funds with appropriate Shari’a governance.

We plan manager operating models (local license, hosted platform, foreign delegation), build service stacks, prepare policy suites and documentation, and steer public approvals or streamlined professional registrations.

We also guide distribution (onshore marketing of foreign funds via CMA processes and licensed promoters, Arabic documentation and selling restrictions), substance expectations and Kuwait tax/Zakat/NLST and treaty considerations for fund vehicles and sponsor structures.

Marketing, Offering and Sale of Foreign Fund Units into the Middle East

We provide a unified distribution playbook for foreign managers approaching GCC/MENA investors. Across the onshore UAE (SCA), Kuwait (CMA), Qatar (QFMA) and Saudi Arabia (CMA), regulators require pre-approvals or registrations even for professional placements, use of locally licensed promoters/distributors or APs, Arabic localization and jurisdiction-specific risk legends, with reverse solicitation interpreted narrowly.

We calibrate campaign design and materials to local conduct and advertising rules (including geofencing websites and webinars), align investor eligibility testing and minimum subscriptions, and coordinate dual-track strategies where free zone regimes (DIFC/ADGM/QFC) are used alongside onshore approvals. We also build compliance frameworks for ongoing reporting and change notifications post-registration.

Jurisdiction-specific highlights include SCA registration and use of SCA-licensed promoters in the mainland UAE; CMA approvals and licensed promoters in Kuwait; QFMA approvals for onshore State of Qatar marketing with licensed distributors; and Saudi placements through CMA-licensed APs under private placement regimes limited to sophisticated/professional investors.