Lawyer
Expert in corporate and international corporate law. Has extensive experience in supporting the acquisition of financial licenses in Ukraine, as well as business incorporation in the EU, the United Kingdom, Switzerland, the UAE, and key Asian jurisdictions.
Registration of AMC (asset management company)
Let’s start with the fact that the asset management market in Ukraine continues to gradually transform in accordance with European standards for regulating the financial sector. We would like to draw your attention to the fact that in 2026, the creation of an asset management company (AMC) will no longer be an exclusively technical procedure for obtaining a license – it is a complex process that combines corporate structuring, financial law, regulatory compliance, internal control and strategic planning of the future financial institution.
Our Law Firm “Prikhodko and Partners” supports clients in projects to create professional participants in the capital market, including AMCs, investment companies, financial institutions and other licensed structures. In practice, we see that the successful completion of the procedure depends not so much on the formal submission of documents, but on the correct understanding of the logic of the regulator and the early preparation of the entire business model.
What is an asset management company?
If we consider the definition, then an AMC (asset management company) is a legal entity that has a special permit for professional activity in managing the assets of collective investment institutions. Such a company manages:
- mutual investment funds;
- corporate investment funds;
- assets of non-state pension funds;
- separate investment portfolios in cases provided for by law.
The main regulator in this area remains the National Securities and Stock Market Commission, which in 2025–2026 significantly strengthened the approaches to assessing applicants.
Legislative framework in 2026
Today, the activities of AMCs are regulated by a number of regulatory acts, the key ones being:
- The Law of Ukraine “On Capital Markets and Organized Commodity Markets”;
- The Law of Ukraine “On Collective Investment Institutions”;
- The Law of Ukraine “On Financial Services and Financial Companies”;
- Legislation in the field of financial monitoring;
- Licensing conditions for conducting activities with asset management agreements.
However, in practice, the text of the legislation itself does not provide a complete picture. The regulator is increasingly applying a risk-based approach, which assesses not only the formal compliance of documents, but also the real ability of the company to carry out professional activities.
That is why legal support at the stage of creating an AMC today has not only tactical, but also strategic importance.
Requirements for the legal structure
An asset management company can be established in the form of:
- limited liability company;
- joint-stock company.
In most cases, clients choose LLC, since this form is more flexible in terms of corporate governance and subsequent business restructuring.
Special attention should be paid to:
- the structure of participants;
- ultimate beneficial owners;
- sources of capital formation;
- corporate ties with other companies.
Practice shows that it is the opaque ownership structure that often causes refusal of approval.
Authorized capital and sources of funds
One of the key elements of the audit is the origin of the founders’ funds. The regulator analyzes:
- financial capacity of the owners;
- sources of capital;
- tax history;
- the presence of risky transactions in the past.
In 2026, it is not enough to simply contribute authorized capital. It is necessary to document the legality of the origin of each amount invested in the future company.
In our practice, this stage often requires the most thorough preparation.
Requirements for managers
The management team of the AMC must meet the criteria for professional suitability.
The regulator checks:
- education;
- professional experience;
- business reputation;
- absence of criminal records;
- absence of conflict of interest.
The following are separately assessed:
- director;
- internal auditor;
- compliance officer;
- responsible for financial monitoring;
- risk manager.
The formal approach to appointing officials no longer works today. The regulator assesses whether the team is capable of actually managing the financial institution.
Internal policies and compliance
A modern AMC must have a full-fledged internal control system.
It is necessary to develop:
- AML/KYC policies;
- internal audit procedures;
- risk management system;
- conflict of interest prevention policy;
- information protection rules;
- corporate decision-making procedures.
We can tell you that template documents often do not pass inspection, since the regulator pays attention to the practical adaptation of policies to a specific business model.
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Practical difficulties in 2026
Most often, applicants face the following problems:
Opaque ownership structure
Any nominal owners or complex foreign chains cause additional checks.
Weak business plan
The regulator evaluates not only documents, but also the economic logic of the project.
Formal compliance
It is not enough to have documents – you need to prove the real functioning of the system.
Insufficient training of managers
Officials must understand their functions and confirm professional competence.
Why should you seek legal support?
Our specialists from the Law Firm “Prikhodko and Partners” provide comprehensive support for the creation of an AMC:
- analyzes the structure of the future business;
- assesses regulatory risks;
- prepares a package of documents;
- develops internal policies;
- supports communication with the regulator;
- helps to obtain approval from managers;
- minimizes the risks of refusal.
We don’t just draw up documents — we build a legally stable business model that meets the modern requirements of the Ukrainian financial market.
Taking into account all of the above, registering an asset management company in 2026 is a complex multi-level process that requires a combination of legal expertise, financial understanding, and knowledge of regulatory practice.
It is the right preparation at the start that determines whether AMC will become a working tool for business, or turn into a long-term process with the risk of failure. Our specialists from the law firm “Prikhodko and Partners” are ready to support the client at every stage – from creating a structure to obtaining a license and launching the activity.
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1 question
Are you planning to establish an asset management company as a new legal entity, instead of an existing company?
2 question
Can you confirm the legal origin of the funds that will be contributed to the company's authorized capital?
3 question
Are there any foreign citizens or foreign companies among the founders or ultimate beneficiaries?
You may also need:
Introduction of corporate rights to the authorized capital of the company
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