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Financial Institutions

Institutional-Grade Asset Safekeeping

Custodian services for non-CIS clients require FSC licensing and a robust operational and governance framework, Aurevya guides institutions through every stage of establishing a credible, compliant custody operation in Mauritius.

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Overview

What is a Custodian Service Provider (Non-CIS)?

A Custodian Service Provider (Non-CIS) is authorised by the FSC to provide safekeeping and administration of client assets, securities, cash, and other financial assets, outside the CIS framework. This licence is typically sought by entities providing custody services to institutional clients, family offices, and private wealth clients who are not holding assets through a collective investment scheme.

Custodians are subject to detailed FSC operational requirements, including segregation of client assets, robust IT systems, and regular reporting. Mauritius custodians can hold assets across multiple asset classes and geographic markets, providing a genuinely multi-asset, multi-market custody capability from a single regulated entity.

Aurevya advises on the complete custody licence application process, operational framework design, IT systems requirements, client onboarding procedures, and ongoing compliance, drawing on practical experience of what the FSC requires in assessing non-CIS custody applications.

FSC
Licensed
Full FSC regulatory authorisation, the credibility required to attract institutional clients and establish genuine custody relationships with prime brokers and sub-custodians.
Segregated
Client Assets
Mandatory client asset segregation, a fundamental protection for custody clients and a core requirement of the FSC's operational standards for custodian licence holders.
Multi-Asset
Custody Capability
Mauritius custodians may hold equities, fixed income, cash, and other financial assets across multiple markets, a genuinely broad custody capability from a single regulated platform.

Scope of Authority

Key Features

Securities Safekeeping
Authorised to hold securities, equities, bonds, and other financial instruments, on behalf of clients in segregated custody accounts, maintaining comprehensive records of all client holdings at all times.
Cash Management
Custody of client cash balances across currencies, maintaining segregated cash accounts and providing cash management services including interest calculation and FX settlement support for custody clients.
Corporate Actions Processing
Administration of corporate actions affecting client assets, dividends, interest payments, rights issues, mergers, and other events, notifying clients and processing elections in accordance with client instructions.
Asset Segregation
Strict separation of client assets from the custodian's own assets, a fundamental FSC requirement and a cornerstone of client protection in the custody framework, ensuring client assets are identifiable and recoverable at all times.
Institutional Clients
The non-CIS custodian licence is appropriate for a broad range of institutional clients, family offices, investment companies, non-fund institutional investors, and private wealth structures requiring segregated custody outside the CIS framework.
FSC Oversight
Full FSC regulatory oversight, including periodic inspections and reporting requirements, providing institutional clients with confidence in the regulatory standing and operational discipline of the Mauritius custodian.

Process

How It Works

01
Custody Business Assessment
We assess the proposed custody business model, target clients, asset classes, sub-custody arrangements, and technology infrastructure, confirming that the Non-CIS Custodian licence is the appropriate regulatory vehicle and scoping the application requirements.
02
FSC Licence Application
Preparation and submission of the complete FSC custodian licence application, including business plan, operational framework overview, technology description, key personnel fit-and-proper submissions, and AML/CFT programme.
03
Operational Framework Design
Design of the custody operational framework, client asset segregation procedures, asset reconciliation processes, corporate actions processing, client reporting framework, and business continuity arrangements, all required by FSC operational standards.
04
IT Systems Implementation
Implementation of the custody management systems required by the FSC, securities settlement, asset reconciliation, client reporting, and AML/CFT monitoring, with documentation acceptable for FSC review during the licence application process.
05
Client Onboarding Framework
Design of the client onboarding process, KYC procedures, custody agreements, service level terms, reporting formats, and asset transfer procedures, enabling the custodian to accept its first clients efficiently upon licence grant.
06
Launch
Coordination of the operational launch, first client onboardings, asset transfers, and commencement of the ongoing FSC reporting and compliance programme. Aurevya provides continued compliance support throughout the life of the custody operation.

Practical Considerations

Requirements & Timeline

Regulatory Requirements

  • Minimum capital as specified by FSC for the Non-CIS Custodian category
  • Qualified custody operations personnel with relevant institutional experience
  • Client asset segregation systems meeting FSC standards
  • Asset reconciliation processes, daily or as specified by FSC guidelines
  • Custody management IT systems reviewed and accepted by the FSC
  • AML/CFT programme covering custody-specific risks
  • Business continuity plan addressing custody service disruption scenarios
  • Regular FSC reporting including financial returns and compliance submissions

Indicative Timeline

  • Corporate Setup: 2–3 weeks from completion of KYC and structure documentation
  • Application Preparation: 4–8 weeks, the operational framework and IT systems documentation are typically the most time-intensive elements
  • FSC Review: 10–18 weeks from submission of a complete application
  • Operational Launch: 3–6 weeks post-licence grant for systems finalisation and first client onboardings

Common Questions

Frequently Asked Questions

CIS custody refers to the safekeeping of assets belonging to Collective Investment Schemes, regulated pooled investment vehicles. The custodian of a CIS has specific obligations under the Securities Act 2005 in relation to the scheme and its investors, and the appointment must be approved as part of the scheme authorisation process. Non-CIS custody covers safekeeping for all other clients, institutional investors, family offices, investment companies, and private wealth structures that are not CIS entities. The non-CIS custodian licence is the broader category and is the appropriate licence for entities providing custody services to the general institutional market.
A Mauritius Non-CIS Custodian may hold equities, bonds, cash balances across currencies, money market instruments, and other financial assets, subject to the FSC's operational requirements for each asset class. The custodian may also arrange for sub-custody of assets held in overseas markets through relationships with global sub-custodians, enabling a multi-market custody capability from the Mauritius platform. The specific asset classes that will be held should be documented in the business plan submitted to the FSC as part of the licence application.
The FSC specifies minimum capital requirements for Non-CIS Custodian Service Providers, reflecting the operational and fiduciary responsibilities of custody activities. The precise capital requirement is confirmed during the pre-application assessment phase and is assessed in the context of the proposed custody business model and the value of assets to be held. Aurevya's regulatory team confirms applicable capital requirements and advises on the optimal capitalisation approach as part of the initial engagement.
Client asset segregation is a fundamental requirement of the FSC's custody standards. Client assets must be held in accounts and records that are clearly separate from the custodian's own assets, both operationally (in systems) and legally (in account structures). Each client's assets are typically held in separately identified accounts. Daily reconciliation of client assets against sub-custodian records and internal books is required to detect and resolve discrepancies promptly. Aurevya designs the segregation framework as part of the operational setup process and assists in documenting it for FSC review.
The custody of virtual assets in Mauritius is governed by the Virtual Asset and Initial Token Offerings Act 2021 (VAITO Act) rather than the traditional custody framework. A separate virtual asset custody licence under the VAITO Act is required to provide custodial services for virtual assets. An entity wishing to provide custody for both traditional financial assets and virtual assets would need to hold both the Non-CIS Custodian licence and the appropriate VAITO Act authorisation. Aurevya advises on the regulatory structure for entities seeking custody capability across both traditional and digital asset classes.

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