In 2025, the pressure on GPs to navigate stricter global regulations is tighter than ever. With the total managed private market assets approximating $13.1 trillion and an over 20% annual growth since 2018, regulators are responding with sharper scrutiny.
They are cracking down on ESG disclosures, cross-border fund compliance, investor protection, and AML/CFT standards. These regulatory updates for GPs in 2025 signal a call to action. Therefore, GPs must view compliance as a key strategic pillar for fund governance.
In this comprehensive jurisdictional guide, we unpack the major 2025 fund regulation changes across six markets to help you act, adapt, and stay competitive.
Cayman Islands
The Cayman fund regulation recently updated the Proceeds of Crime Act, which requires entities to report suspicious activities. Some critical updates require regulated entities to secure prior consent from the Financial Reporting Authority (FRA) to have a defence against money laundering (DAML).
This shift intensifies the legal demands for transaction reporting and local governance. Failure to secure the DAML consent could expose entities to key money laundering issues even if they file a suspicious activity report.
Concurrently, on June 1, 2025, the Cayman Islands Monetary Authority (CIMA) also issued a supervisory data notice on anti-money laundering surveys and scrutiny of SIBA-registered entities. This was a commitment to strengthening its expectation for dynamic internal CTF/AML/CPF structures, board governance, risk appraisal, and comprehensive audit-ready documentation.
Implications for GPs:
・Refine SAR protocols to mirror DAML consent requirements
・Properly document internal governance, including board governance and compliance obligations.
・Complete AML survey and preparedness for on-site assessment with extensive compliance logs
Hong Kong
Hong Kong’s 2025 regulatory framework for private fund managers has become stricter. It focuses on ESG structures and governance operations overseen by the Securities and Futures Commission (SFC). For example, the SFC ESG requirements 2025 executed the jurisdiction’s Sustainability Disclosure Standards (SDS), effective August 1.
This standard mandates fund managers to correspond with the ISSB/IFRS-focused disclosure benchmark. It is typically applicable where ESG factors materially impact investment decisions or reporting.
In October 2024, the SFC systematically assessed fund administration and distribution processes, highlighting inadequacies and substandard conduct. Since then, the regulator has heightened guidance on private fund distribution, especially around fit, proper criteria, and conduct expectations.
Still, the SFC published a circular on the listing of closed-ended alternative funds, stipulating new listing mechanisms and stern demands for product administration and investor communication.
Implications for GPs:
・Objective coordination of ESG reporting with ISSB and SDS frameworks is demanded for private and public funds that make ESG claims
・Governance control must align with strengthened licensing expectations
・Distribution structures now include a stringent evaluation of marketing practices, governance frameworks, and suitability
Singapore
The Monetary Authority of Singapore published two demanding 2025 fund regulation changes that GPS handling VCCs or LFMC frameworks must address.
Here are the major highlights from the Circular No. IID 04/2025 issued by MAS on June 26, 2025, for VCC managers:
・The managers must have significant fund management activity. This means any framework holding illiquid assets or handling one investor without managerial supervision may be considered non-compliant
・Custom demands now pertain to liquid assets unless all investors are accredited or institutional
・Directors conducting regulated functions must be licensed agents of the VCC manager
・VCC managers reserve the overall responsibilities for CFT/AML roles, even if services are outsourced to eligible FIs
MAS emphasized stricter private fund compliance standards in two key areas under the April-June 2025 advertising and AML/CFT private equity regulation updates:
・In a May consultation paper, the MAS compliance update 2025 proposed excluding existing exemptions for accredited or institutional investor advertisements. This means all fund-focused advertising must be transparent and meet approval and fair-dealing precision, irrespective of the target audience.
・MAS updated AML/CFT notices and regulations effective July 1, 2025, requiring solid standards on suspicious transaction reporting, client due diligence, and sanctions screening. This also encompasses proliferation financing under FATF requirements.
Implications for GPs:
・VCC managers must ensure strict oversight, active investment decision-making, and precise licensing for regulated responsibilities
・Board liability, custody programs, and fund governance frameworks must mirror MAS expectations
・Market scrutiny, including a formal survey and approval under MAS’s stricter advertisement standards
・AML/CFT upgrades to echo FATF demands on proliferation financingplete AML survey and preparedness for on-site assessment with extensive compliance logs
China
In 2025, China issued major updates to its data administration, emphasizing the urgency around financial data sovereignty and cross-border data movement. These shifts are critical for any GP operating within the Chinese jurisdiction.
Here are the key regulatory developments:
・On April 17, 2025, China issued new regulations focused on effectively managing the cross-border movement of financial data, including defining permissible data types for transfer under a negative list framework.
・Still, on April 9, 2025, the China Cyberspace Administration (CAC) also published an official Q&A on international data exchange. It outlines how entities should adhere to China’s jurisdictional data exchange rules, especially in recognizing and approving core data.
Implications for GPs:
・GPs must map data movements and precisely classify data. For any data deemed as “core”, they must seek formal approval through a CAC security evaluation or certified contractual clauses.
・Technology and legal structures must echo CAC demands, including impact appraisal, data encryption, and privacy-by-design structure.
Luxembourg
Luxembourg is a key center for EU-domiciled funds. Its regulatory structure adapts to align with the broader EU initiatives on ESG disclosure requirements and investor protection.
Here are the key regulatory developments:
・The Commission de Surveillance du Secteur Financier (CSSF) continuously streamlines its fund governance of alternative investment funds and management companies, especially with data administration, outsourcing, and AML/CFT risk mitigation.
・CSSF issued Circular 25/883 in April 2025, emphasizing its position on outsourcing governance. The regulation update requires pre-authorization for key IT functions and improved reporting on data residency.
・In addition, CSSF maintained its support of the ESMA Guidelines on Fund Marketing Communications, emphasizing comparability, transparency, and accurate presentation of historical performance and sustainability claims.
Implications for GPs:
・GPs must implement strict governance over outsourcing and IT, with periodic risk appraisal and documentation that can withstand audit oversight
・AML/CFT structures must be proactive, tech-integrated, and customized to every fund’s risk profile
・Marketing and sustainability declarations must reflect taxonomy, SFDR, and MiFID II demands
British Virgin Islands (BVI)
BVI 2025 updates emphasized beneficial ownership transparency, economic substance, and AML/CPF/CFT adherence. For example, on February 21, the BVI FSC announced an updated 2025-2027 AML-CFT-CPF policy. The approach mirrors the commission’s dedication to mitigating money laundering, proliferation, and terrorist financing.
In December 2024, the commission released Industry Circular 46, which contains updated regulations on beneficial ownership commitments. The update requires GPs and entities to gather, preserve, and continuously update beneficial ownership data across frameworks.
In its Q1 2025 newsletter, FSC announced more than 45 scheduled compliance checks of licensed FIs through Q1 2026. This will focus on training, implementation procedures, and AML/CFT/CPF policies.
Implications for GPs:
・Institute and maintain extensive beneficial ownership registers, aligning with new regulatory standards and deadlines
・Have solid, active, and current AML/CFT/CPF policies
・Proactively prepare for legal scrutiny, including training logs, internal audits, and proof of remediations
・Track 2025 fund regulation changes in transparency structures, especially those impacting access to ownership data under the jurisdiction’s cross-territorial directives
Key Takeaway
In 2025, fund administration is not business as usual. From ESG disclosure scrutiny in Hong Kong to China data localization rules and stricter BVI economic substance changes, regulators are elevating standards universally.
For GPs, the cost of non-compliance transcends fines to include damaged credibility, delayed rollouts, and loss of investor trust. Remaining competitive means staying updated and embedding regulatory awareness into the fund lifecycle.
Linnovate helps you identify and bridge regulatory gaps with practical structures customized to your jurisdictional footprint to meet the regulatory updates for GPs in 2025. Contact our team today to future-proof your 2025 strategy and beyond.
