Raison AM (Leagal Entity - Threesixty Elements S.A.) has zero tolerance to any regulatory risks. We are a licensed investment manager and investment adviser, acting with all the requirements of international regulatory bodies of Europe and the United States.

BVI Financial Services Commission

Approved Investment Managers

The main controller of the company is the BVI Financial Services Commission - the Territory's single financial services Regulator. It's the agency responsible for authorising and licensing companies or persons to conduct financial services business and for monitoring the perimeter of regulated financial services activity to safeguard the public against any illegal and or unauthorised financial services business operating in or from within the BVI.

In 2015 we obtained an Approved investment manager license (Certificate No. IBR/AIM/15/011), the presence of which permits to act as an investment manager or investment adviser to different types of funds organized in BVI and other Recognised Jurisdictions and a person that is incorporated, formed or organized outside the BVI in a non-recognised jurisdiction and to such other person as the FSC may approve on a case by case basis in other Recognised Jurisdictions.

U.S. Securities and Exchange Commission

Division of Investment Management

The US SEC Division of Investment Management works to protect investors, promote informed investment decisions and facilitate appropriate innovation in investment products and services through regulating the asset management industry. The Division is responsible for the Commission's regulation of investment companies, variable insurance products, and federally registered investment advisers.

In the beginning of 2016 Raison AM was registered with the U.S. Securities and Exchange Commission as an Investment Adviser. This license grants us the right to provide analysis or advice on securities either by making direct or indirect recommendations to our clients or by providing research or opinions on securities or securities markets.

You can always view an updated information on SEC-registered investment advisers with the most recent Form ADV online by visiting the Investment Adviser Public Disclosure (IAPD) website. Our SEC Number is 801-107170.

Financial Industry Regulatory Authority

Financial Industry Regulatory Authority (FINRA) is dedicated to investor protection and market integrity through effective and efficient regulation of the securities industry. FINRA is an independent, not-for-profit organization authorized by Congress to protect America’s investors by making sure the securities industry operates fairly and honestly.

FINRA operates Central Registration Depository, the central licensing and registration system for the U.S. securities industry and its regulators. You can check updates at Finra BrockerCheck website. Our company's CRD number is 282147. 

Internal Revenue Service

Foreign Account Tax Compliance Act

FATCA is a piece of US legislation that was designed to improve tax compliance by US persons, both individuals and entities, as they are required to report their worldwide income to the US Internal Revenue Service (IRS) on an annual basis, regardless of whether or not they currently reside in the US. FATCA requires global financial institutions to identify all reportable US persons within their client base and provide information on such accounts to the appropriate tax authorities. Threesixty Elements annually reports information to the tax authorities concerning the accounts of US persons and certain US owned entities.

Raison AM GIIN

Raison AM has registered with the IRS for FATCA purposes and our GIIN for the management company is W1LQF2.00000.LE.092. If you need a GIIN for a fund or another entity of our group, please contact us to obtain the GIIN for that entity.

For your information, the IRS list of all registered Foreign Financial Institutions is publicly available on this link.

European Securities and Markets Authority

European Markets and Infrastructure Regulations

EMIR is a European Union regulation designed to increase the stability of the over-the-counter (OTC) derivative markets and to make the derivatives markets more transparent by requiring counterparties to derivatives transactions to report trades, positions, collateral and valuations to the European Securities and Markets Authority (ESMA), the European regulatory body. It is designated Regulation (EU) 648/2012 entered into force in 2012. All counterparties with reporting obligations under EMIR must have a Legal Entity Identifier (LEI) in order to report.

Legal Entity Identifier

LEI initiative is designed to create a global reference data system that uniquely identifies every legal entity or structure, in any jurisdiction, that is party to a financial transaction. The use of the LEI has been mandated by the ESMA for the reporting of derivative transactions to Trade Repositories under EMIR. Our LEI number is 5493008ZTCV22U0F8503.