Regulatory Disclosures
Last Updated: March 2026
Persistent Asset Partners Limited is committed to maintaining the highest standards of regulatory compliance and transparency. This page provides important regulatory information for our clients and prospective investors.
Regulatory Status
Hong Kong Securities and Futures Commission (SFC)
Persistent Asset Partners Limited is a corporation licensed by the Securities and Futures Commission of Hong Kong to conduct the following regulated activities:
• Type 9: Asset Management
• CE Number: BXX123 (Example)
• License Date: March 15, 2002
Our Type 9 license authorizes us to provide discretionary portfolio management services to professional investors. We are subject to the Securities and Futures Ordinance (Cap. 571) and the Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission.
China Securities Regulatory Commission (CSRC)
As of January 2025, Persistent Asset Partners Limited has been granted Qualified Foreign Institutional Investor (QFII) status by the China Securities Regulatory Commission, authorizing us to invest in China's domestic securities markets on behalf of qualified clients.
• QFII License Number: QFII-XXX-2025
• Approved Investment Quota: RMB 5 billion
• Custodian Bank: [Major Chinese Bank]
Investor Protection
Professional Investor Requirement
Our services are exclusively available to Professional Investors as defined under the Securities and Futures Ordinance of Hong Kong. This includes:
• Institutional investors (banks, insurance companies, pension funds, etc.)
• High-net-worth individuals meeting the prescribed financial thresholds
• Corporate professional investors meeting specific criteria
• Family offices with sophisticated investment capabilities
Investor Compensation Fund
Investments managed by Persistent Asset Partners Limited are not covered by the Investor Compensation Fund administered by the Securities and Futures Commission. The Investor Compensation Fund provides compensation to eligible investors who suffer pecuniary loss as a result of a default of a licensed intermediary or authorized financial institution in relation to products traded on a recognized exchange in Hong Kong.
Client Asset Protection
Client assets are held separately from our proprietary assets and are maintained with independent custodians and prime brokers. We implement strict internal controls to ensure the segregation and protection of client assets.
Conflicts of Interest
Persistent Asset Partners Limited has established comprehensive policies and procedures to identify, manage, and disclose conflicts of interest. Key measures include:
Identification and Disclosure
• Regular assessment of potential conflicts across all business activities
• Disclosure of material conflicts to clients before entering into any engagement
• Maintenance of a conflicts register reviewed by senior management
Management Measures
• Physical and informational barriers between different business units
• Personal trading policies for all staff members
• Independent compliance monitoring and surveillance
• Restrictions on outside business activities
Principal vs. Client Interests
• Principals of the firm invest alongside clients in our funds
• Fee structures aligned with long-term client interests
• No proprietary trading that conflicts with client mandates
Related Party Transactions
All transactions with related parties are conducted at arm's length and are subject to enhanced due diligence and approval procedures.
Cross-Border Activities
Jurisdictional Limitations
This website and our services are not directed at residents of jurisdictions where distribution or provision of such services would be contrary to local law or regulation. Specifically:
• United States: We do not offer services to U.S. persons as defined under U.S. securities laws
• European Union: Services may only be offered to professional investors under applicable MiFID II exemptions
• Mainland China: Cross-border services are subject to QFII regulations and applicable quotas
• Other Jurisdictions: Availability subject to local regulatory requirements
Anti-Money Laundering (AML)
We are subject to and comply with:
• Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) of Hong Kong
• Guidelines issued by the SFC on AML/CFT
• FATF recommendations on combating money laundering
All clients undergo thorough Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures before account opening.
Tax Compliance
We comply with applicable tax reporting requirements including:
• Common Reporting Standard (CRS) / Automatic Exchange of Information (AEOI)
• Foreign Account Tax Compliance Act (FATCA) where applicable
• Hong Kong tax obligations
Disclosure Documents
Fund Documentation
Investors in our funds receive comprehensive disclosure documentation including:
• Private Placement Memorandum (PPM): Detailed information about investment strategy, risks, fees, and terms
• Subscription Agreement: Legal agreement setting out investor representations and commitments
• Partnership/Operating Agreement: Governing documents for fund operations
• Side Letter: Any specific terms negotiated with individual investors
Periodic Reporting
Investors receive regular reports including:
• Monthly: Net Asset Value statements, performance summaries
• Quarterly: Detailed investment reports, risk analytics, market commentary
• Annually: Audited financial statements, tax documentation (K-1 or equivalent)
Additional Disclosures
• Form ADV (for U.S. reporting purposes where applicable)
• Annual compliance attestations
• Material change notifications
Risk Warnings
Investment Risks
Investing in hedge funds and alternative investments involves significant risks, including but not limited to:
• Loss of Capital: Investors may lose some or all of their investment
• Illiquidity: Investments may be difficult to sell or redeem, with lock-up periods and redemption gates
• Leverage: Use of borrowed funds can magnify gains and losses
• Market Risk: Exposure to market fluctuations and volatility
• Currency Risk: Investments in foreign securities are subject to exchange rate fluctuations
• Concentration Risk: Portfolios may have concentrated positions
• Counterparty Risk: Risk of default by trading counterparties, brokers, or custodians
• Operational Risk: Risk of loss due to operational failures or fraud
China-Specific Risks (QFII Investments)
Investments in China's domestic markets carry additional risks:
• Regulatory and political uncertainty
• Capital controls and repatriation restrictions
• Limited investor protections compared to developed markets
• Currency controls on the RMB
• Market access limitations and quota constraints
No Guarantee of Returns
Past performance is not indicative of future results. There can be no assurance that our investment strategies will achieve their objectives or that investors will receive a return on their capital.
Independent Advice
Prospective investors should consult with their own legal, tax, and financial advisors before making any investment decision.
Compliance Contact
For regulatory inquiries or to report compliance concerns:
Chief Compliance Officer
Persistent Asset Partners Limited
Suite 1208, 12/F, One Pacific Place
88 Queensway, Hong Kong
Email: hengshengzichan@gmail.com
We maintain a confidential reporting mechanism for concerns about potential violations of securities laws or company policies.