The personal file that accompanies a Cyprus AIFM application is not a CV assembly for each person examined. It is a fit and proper file per person, and the file is what CySEC assesses against a specific framework: prior education and experience, current commitments, financial standing, regulatory history, criminal record, and the professional certification the role requires. Each individual completes and signs their own personal questionnaire, and each questionnaire lands in the file the AIFM submits.
Who submits, and what the file captures
The personal file has as many personal questionnaires as the applicant has persons to be examined. Persons examined include the executive directors, the non-executive directors, the senior management running the AIFM's key functions (compliance, internal audit, risk management and portfolio management), the shareholders holding a qualifying holding, and the beneficial owners behind any corporate shareholder. Each of these individuals completes and signs their own questionnaire.
The questionnaire captures personal identification and residency; educational qualifications; the full professional history relevant to the role; the current directorships and positions held elsewhere; the financial-standing disclosures the framework requires; the regulatory-history disclosures; the criminal-record declaration; the CySEC certification held for the role; the time commitment declared for the AIFM; and, for non-executive directors identified as independent, the independence declaration. The questionnaire is signed as accurate by the individual and includes an undertaking to notify CySEC of changes during the licence life.
CySEC certifications
CySEC operates a two-tier professional certification framework that runs alongside the fit-and-proper assessment. The Advanced Certificate is required of individuals whose roles carry investment decisions, risk management authority or senior compliance authority in the AIFM. The Basic Certificate is required of individuals whose roles carry lower authority but are still customer-facing or transaction-processing. Which certification each individual holds is captured in the personal questionnaire; the file will show, for each person examined, the certification held and the date it was obtained.
The certification is not a proxy for the fit-and-proper assessment. It is a professional qualification the framework requires for specific roles. A person can hold the Advanced Certificate and still fall short on the fit-and-proper assessment; conversely, a person can hold neither certification and pass the fit-and-proper assessment for a role that does not require one. The two operate on different axes.
Time commitment and cross-directorships
The time commitment declaration is a substantive item, not a formality. Each executive director declares that the role will be their full-time and exclusive occupation; each non-executive director declares the specific time they will devote to the AIFM and the specific time they devote to each of their other positions. The file has to show, at the level of each individual, that the time declared is consistent with the individual's other commitments.
Cross-directorships are declared and examined. The declaration is not a bare list. For each cross-directorship the file describes the nature of the entity, the role held, and the time commitment. Where the individual holds significant additional positions the file has to show that the AIFM role is not being taken on top of a load the individual cannot honour. This is not a per-name veto; it is a per-file question about whether the persons the AIFM is putting forward have the actual capacity to run it.
Financial standing, regulatory history and criminal record
The financial-standing disclosure covers bankruptcies, insolvency proceedings, court judgments, unpaid financial obligations and any similar circumstance bearing on the individual's financial reliability. The disclosure is not narrowed to Cyprus; it is worldwide. The individual is expected to know their own standing and to disclose it accurately.
The regulatory-history disclosure covers prior approvals, prior refusals, prior withdrawals and prior sanctions or disciplinary actions by any regulator, in any jurisdiction, that has ever reviewed the individual. The disclosure includes ongoing investigations. Nothing on the list is automatically disqualifying and some items on the list are automatically explanatory-only. What matters is that the file discloses fully so that CySEC can assess.
The criminal-record disclosure covers convictions in any jurisdiction. Certain categories are treated more strictly than others; the file discloses all of them. The individual attaches the corresponding official document from each jurisdiction where they have lived or worked at the material level.
Independence for non-executive directors
Where a non-executive director is identified as independent, the individual signs an independence declaration. The declaration is signed at the level of the specific characteristics that independence requires under the framework, not as a general statement. The independence status is examined against the individual's own history and current relationships, not accepted on the basis of the signed declaration alone.
The file does not close at authorisation
The personal file is not a snapshot at authorisation. Each individual undertakes to notify CySEC of material changes to any of the disclosures during the licence life. New cross-directorships, changes in time commitment, financial-standing events, criminal or regulatory matters and role changes at the AIFM itself are all reportable. The undertaking to notify is signed as part of the questionnaire, and it survives the granting of the licence.
The persons approved are the persons the licence stands on
The persons approved at authorisation are the persons the licence stands on. A change in any of them during the licence life is a matter for CySEC. The personal file is not paperwork that closes with the licence letter; it is a running representation about who is running the AIFM, and the framework rests on the accuracy of that representation.
This piece stands alongside the file itself, the timeline the file runs through, the scope of the licence granted and the Internal Operations Manual that describes how the AIFM will operate. A further piece in this cluster will walk the post-licence year-by-year timeline.