Privacy Policy

Last updated October 2026.

New Morning Fund Administration Limited is a mutual fund administrator licensed and regulated by the Financial Services Authority of St. Vincent and the Grenadines. Most of the personal information we hold is held because the law requires us to hold it, and this policy explains what that information is, why we have it, who we share it with, and how long it stays with us.

Who we are

New Morning Fund Administration Limited (Company No. 23999 BC 2017) is responsible for the personal information described in this policy. Our office is at First Floor, Minor's Compound, Vigie Highway, Fountain, Arnos Vale, and our registered office is at First Floor, St. Vincent Teachers Cooperative Credit Union Uptown Building, corner of James and Middle Street, Kingstown, VC0100, St. Vincent and the Grenadines. Until 2026, the company was named Fund Administrators of SVG Corp.

Questions about this policy, and any request concerning the information we hold about you, should be sent to privacy@newmorningfa.com or to the office address above.

Who this policy covers

This policy applies to visitors who contact us through this website, to the funds we administer and the directors, investment managers, and beneficial owners connected to them, and to investors in those funds. What we hold differs considerably between these groups, and the sections below are set out accordingly.

What we collect

Visitors to this website

If you complete the enquiry form, we receive your name, your company or fund name, your email address, your telephone number where you choose to give it, the nature of your enquiry, and the content of your message. Please do not send identity documents or personal financial information through the form; if we need them, we will tell you how to send them securely.

Funds, directors, managers, and beneficial owners

Before we accept an appointment, we carry out due diligence on the fund, its directors, its investment manager, and its beneficial owners. For the individuals involved, this means identification documents, proof of address, details of role and ownership, regulatory status where relevant, and the results of the screening described below.

Investors in the funds we administer

This is the largest body of information we hold. It includes identification and verification documents, address and contact details, tax residence and taxpayer identification details, information establishing source of funds and, where the risk of the relationship requires it, source of wealth, the results of screening against the United Nations, OFAC, United Kingdom, and European Union sanctions lists together with politically exposed person and adverse media checks, the risk rating applied to the relationship, and the record of subscriptions, redemptions, transfers, holdings, and correspondence held in the shareholder register.

We hold this information in order to meet obligations that fall on us as a licensed administrator, and we cannot process a subscription until investor due diligence has been completed and approved.

Where the information comes from

Much of it comes from you directly, but not all of it. We also receive information from the fund and its investment manager, from the previous administrator where a fund transfers to us, and from the commercial screening databases and publicly available sources we use for sanctions, politically exposed person, and adverse media checks. We may ask for further documents where what we hold is incomplete or where the risk of the relationship requires it.

Why we hold it

We hold the great majority of this information because legislation requires it, in particular the Proceeds of Crime Act and the anti-money laundering and countering the financing of terrorism regulations and guidance applying to regulated entities in St. Vincent and the Grenadines, the Mutual Funds Act, Chapter 154, and the FATCA and CRS reporting requirements. Beyond that, we hold information in order to perform the administration agreement with each fund, which covers maintaining the shareholder register, calculating net asset value, and preparing reports and filings. Enquiry form information is held only so that we can respond to the enquiry you have made.

We do not sell personal information, and we do not use it for marketing.

Who we share it with

We disclose personal information where the law requires it and where it is necessary to administer the fund. That includes the Financial Services Authority, the Financial Intelligence Unit, and the Inland Revenue Department of St. Vincent and the Grenadines, and through the Inland Revenue Department the tax authorities of other jurisdictions under the Common Reporting Standard and the United States Internal Revenue Service under FATCA. It also includes the fund itself and its board, the fund's auditors and legal counsel, and its bank, custodian, and brokers, together with the screening providers and technology suppliers that support our own systems.

Our suppliers act on our instructions and are bound to keep the information confidential and to use it only for the purpose for which it was provided.

Where a report is made to the Financial Intelligence Unit concerning suspected money laundering or terrorist financing, the law prevents us from telling the person concerned that the report has been made, or from disclosing information relating to it.

How long we keep it

Investor due diligence files, and the records of transactions carried out for a fund, are retained for at least seven years after the relationship ends, as required of us as a regulated administrator. We keep records for longer where a regulator, a court, or an ongoing investigation requires it, or where they may be needed in connection with a legal claim. Enquiry form information is kept only for as long as is needed to deal with the enquiry and to keep a record of it, after which it is deleted.

How we protect it

Client and investor information is held on access-controlled systems and is available only to the staff who need it for their work. Our administration team prepares investor files, and our compliance function reviews them before any onboarding is approved, so that no single member of staff both prepares and approves a file. Our staff are subject to confidentiality obligations that continue after their employment ends.

Information held outside St Vincent and the Grenadines

Some of the systems we use to hold records, screen investors, and send correspondence are operated by suppliers based outside St. Vincent and the Grenadines, which means that information may be stored or processed in those countries. Where that is the case we satisfy ourselves that the supplier is bound to protect the information to a standard consistent with this policy.

Your rights, and where they end

You may ask us what information we hold about you and ask us to correct it where it is wrong or out of date. Write to privacy@newmorningfa.com, and because much of what we hold is sensitive, we will need to satisfy ourselves of your identity before we respond.

There are limits we should be straightforward about. We cannot delete records we are required by law to retain, which covers most investor due diligence and transaction records for the full retention period. We cannot disclose information relating to a report made to the Financial Intelligence Unit. We may also withhold information where disclosing it would reveal personal information about another person, or would prejudice an investigation or a legal claim. Where we refuse a request, we will tell you that we have done so and, so far as we are permitted,

Cookies

This website uses cookies that are necessary for it to function, and these cannot be switched off. Cookies that are not necessary are declined by default, and you may accept them through the notice shown when you first visit. Your choice is remembered and can be changed at any time.

Changes to this policy

We review this policy from time to time and will post any revised version on this page with the date on which it was last updated. Where a change materially affects clients or investors, we will tell them directly.

Contacting us

Write to privacy@newmorningfa.com or to New Morning Fund Administration Limited, First Floor, Minor's Compound, Vigie Highway, Fountain, Arnos Vale, St. Vincent and the Grenadines. You may also telephone us on +1 (784) 570-9013.

If you are not satisfied with how we have handled a request, say so in writing, and we will review it. We will not notify changes to payment instructions by email alone, and if you receive such a request purporting to come from us, please telephone us before acting on it.

To confirm with counsel

Whether there is a supervisory authority or ombudsman in St. Vincent and the Grenadines to which a complaint about the handling of personal information may be directed, and if so, naming it here.

Formerly Fund Administrators of SVG Corp.