On Reg

Country Edition: Exploring the UAE’s Key Economic Indicators and Opportunities

• Dechert LLP • Episode 14

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In the latest Country Edition of Dechert On Reg, host Angelo Lercara is joined by partners Amanjit Fagura and Colin Sharpsmith from Dechert’s Dubai office to discuss critical insights for asset managers looking to raise capital in the United Arab Emirates (UAE). Fagura and Sharpsmith provide a comprehensive overview of the UAE's regulatory landscape, investment patterns and fund structures, offering valuable guidance on navigating the complexities of raising capital in the Emirates. The episode also explores key investor groups, tax considerations, current market trends and recent regulatory changes that asset managers need to be aware of.

Show Notes

Dechert World Compass

Music.

Angelo Lercara:

Hello everyone, and welcome to Dechert On Reg, the podcast, where we explore the ever changing landscape of financial regulations and the key issues that are shaping the future of asset management. I'm Angelo Lercara, partner at Dechert and co-head of our regulatory product line, and in each episode, we'll be joined by expert colleagues and guests to explore the most pressing issues in financial regulation. In today's episode, we are continuing our series where we dive deep into specific jurisdictions. As you know, from time to time, we'll focus on a different country exploring its unique regulatory landscape and what asset managers need to know when raising capital there. Today, we're talking about the United Arab Emirates. So, whether you're an industry insider or simply interested in the world of financial regulation, you don't want to miss this episode of Dechert On Reg. I'm excited to have two esteemed experts joining us to help us explore the UAE regulatory landscape. Amanjit Fagura and Colin Sharpsmith are here today to discuss what asset managers need to know when raising capital in the Emirates. Let's dive in. Hi Ama, hi Colin, it's great to have you on the

Colin Sharpsmith:

Hi Angelo. A pleasure. show.

Amanjit Fagura:

Hi, Angelo. Great to be part of the show and excited to have this conversation with you.

Angelo Lercara:

Look, to set the stage for our discussion, the United Arab Emirates has a population of approximately 10 million people, and is a federation of seven Emirates, with, I think it's fair to say, Abu Dhabi and Dubai standing out as the region's powerhouses of finance. The Emirates are one of the Middle East's most dynamic economies, known for their diverse sectors, including finance, real estate and tourism. Can you give us a brief overview of the Emirates, including its key economic indicators?

Amanjit Fagura:

Yeah, one thing I would say actually, Angelo, before we get into it, I think the population probably is close to 11 million. And we'll go into, I think part of the podcast will touch upon the reasons for that, especially in the asset management space and other pulling factors that I've seen the population maybe grow over the last couple of years moreso than it has done in the past. But yes, there's seven Emirates, Dubai and Abu Dhabi, as you said, are probably the ones at the forefront when it comes to developing their financial models, trying to attract more foreign growth and bringing in investment from foreign funds or foreign vehicles, but also there is still an element of outbound investment, which will be really important to some of our listeners when we're thinking about what people in the region are doing. Economic indicators, there's been good growth in the region. GDP is up, I region focuses on. Inflation rates, I think, per the IMF, are around 1.62% and employment figures, I mean, this is probably not accurate as of today, but around the 80% mark for employment. And I think the region started off with petroleum, as everyone understands, being the major kind of area where the GDP was grown from. But I think Dubai is one of the Emirates that stands out as kind of moving away from that. And services are maybe its most prominent way of growing its GDP, and there's forecast for that to continuously grow between now and 2029 at the rate of another 26 odd percent. So I think there's a lot of potential here. And I think again, this tally is weird. What we're seeing on the ground in terms of growth, population moving in. And the last thing I would just add is the population, as most people know, is mostly made up of expats. So the majority of the workforce here is coming from regions such as South Asia, Egypt, Philippines, UK, and, generally, the population falls within 15 to 64, so working-class category, which means that unemployment rates are generally quite low. So I think all of that stands itself in good stead for growing an economy and kind of keeping the growth going.

Angelo Lercara:

Thank you. Perfect and very impressive. How do investors from the region typically invest? So what's the balance between domestic and international funds?

Amanjit Fagura:

On a general basis, I say the investment is similar to other jurisdictions. I don't think it differs from where you are based, Angelo, in our U.S. markets, in our European markets, when you say domestic and international funds, I think what we're seeing is even the domestic funds that are set up are branches of or offshoots of feeders, or whatever it may be, of international fund managers setting up in the region. So, and Colin can talk to this a lot more because he's on the regulatory space, he does a lot of work in this area, but what we're seeing is there is a big growth of more domestic funds being set up. But a lot of the times, those funds, where it relates to clients that we work with a lot of the time, often are international fund managers. There is definitely a more local market for domestic funds, whereby they invest more locally, in local products. They're a lot smaller. They exist, and they have done for many years. But I think what we are seeing now is the growth from international managers coming to the region looking to set up, whether it's for personal, tax, family reasons, or just maybe the place where they are, in terms of the opportunity they see in the UAE, but also in the wider GCC region, where there is currently a lot of activity and growth happening and the potential to raise a lot of capital. And I think this goes hand in hand with one of the big factors that drive a lot of managers to the region is that pull of the capital. So if you are going for a sovereign or going for one of the large institutional investors, they want to see you have some investment in the region and some boots on the ground to show that you're serious about investing and helping the economy grow, if you want their capital.

Angelo Lercara:

Right, right.

Colin Sharpsmith:

Yeah, if I could just add to that, I think it's often been described as a sort of two-speed jurisdiction in terms of the funds. As Ama mentioned, there's a large number of smaller funds typically focused on real estate that are locally managed. Real estate has been the most sort of popular asset class, both in the UAE and regionally, and those have typically been structured as offshore, you know, Cayman and other popular fund destinations as the domicile of the fund, even if they're managed locally. But we've seen an enormous growth, both in the registration of large internationally managed fund vehicles and also new products being set up as feeders, as Ama mentioned, in particularly the two financial free zones in Abu Dhabi and Dubai in order to access the wider UAE market.

Angelo Lercara:

Right, thank you. And speaking of registrations, what are the key regulatory bodies that would oversee asset management in the Emirates, and what should asset managers be aware of?

Colin Sharpsmith:

Yeah, so it's an interesting hodgepodge of regimes. So as has already been mentioned, it's a federation, the UAE, of seven different Emirates. They work under a codified rule book for most of the UAE in respect to funds and asset management, with a couple of exceptions, which I'll come on to later, which are the two financial free zones that I've already alluded to, so everywhere outside that space for the purposes of financial services, asset management is regulated by the Central Bank of the UAE on one side, in relation to custody arrangements and banking and other provision of those services, and the Securities and Commodities Authority, or SCA, as It's known, the UAE regulator, which controls the regulatory regime for registration and marketing of investment funds. But then you have these two jurisdictions within the UAE that sit outside the scope of those regulators, and they have their own regulators and their own legal regime. So onshore in the UAE, you have a civil law code with courts in each of the different seven Emirates, which is Arabic language first, and the way that the SCA and the Central Bank work, and it follows civil law code. In the DIFC, the Dubai International Financial Center, which was formed by federal decree in 2004 and in the Abu Dhabi Global Markets, or the ADGM, which was formed in 2013, you have English common law jurisdictions with their own courts and their own regulators, the Dubai Financial Services Authority in the DIFC and the Financial Services Regulatory Authority, or FSRA, in the ADGM. And they follow a completely different regulatory model, which is based on that of the on that of the UK Financial Conduct Authority rules and rule books and when they are providing services to clients or investors outside of those two geographic zones - and I should point out that even within the Emirates of Abu Dhabi and Dubai, the ADGM is a small geographic area built currently across two islands and with a third being developed currently within the city of Abu Dhabi, and the DIFC itself being a land-locked, if you like, island within the city of Dubai. And outside of those two small geographic zones, you are within the jurisdiction of the Central Bank of the UAE and SCA,

Angelo Lercara:

Right. Let's take a look at the investor - potential investors and investor groups. So who are the most important ones, and are there any unique characteristics or preferences among these groups? So I assume there is, but maybe, Ama, you could describe it a little bit more?

Amanjit Fagura:

The typical ones in the region that probably most of our listeners would have been accustomed with are the sovereigns in the region - family offices, institutional investors, investment arms of banks. So those are the main ones in the region. And then obviously you have the domestic market as well. But similar to other jurisdictions, those are a lot more prescriptive as to how you can raise capital from the domestic market. One theme that runs across all of these is most of these investors will invest typically how you would expect them to invest, or how they do in other jurisdictions. They will do reviews of the documentation. They will, if they have enough of a ticket, they will negotiate side letters and terms and preferential rights if possible, etc. But the other aspect, which is quite prevalent given the jurisdiction we're in and the region, is the requirement for Sharia-compliant overlay, or some kind of insight into how the underlying manager is investing, and a lot of the time for managers coming to the region, they are aware of Sharia-compliant or Sharia-sensitive investors, but don't have that much of an idea about what that looks like, especially given the asset classes or the products they are trying to sell in the region. So that's always something we, when we're talking to any manager coming to the region, is asking,"Who are they talking to, what their sensitivities or not are to Sharia." And I think this also differs just taking outside of the UAE itself is within the GCC, the countries that make up part of the GCC is sometimes differs as to their sensitivities on Sharia matters as well. So, I think it's just something that people should be aware of when they're looking at the region, depending on who they're looking at. Yeah. Thanks.

Angelo Lercara:

Yeah, thanks. And I assume that would have an impact on what type of fund you could place in the region, or what type of structure you would have to think about if you want to place or raise capital in the region. And so, what would the most common fund structures be that are being used in the in the Emirates? And maybe, if at all, how do they compare to other jurisdictions?

Colin Sharpsmith:

So, I think what we're seeing a lot of, both for funds that are managed and also being registered for marketing in the region, has traditionally been foreign funds structures came in. It's been a very popular jurisdiction, but we've also seen Luxembourg and Irish domicile products being registered for sale. One thing that has changed, there has been a domestic funds regime for quite some time in relation to onshore products, typically focused around workplace and other local investors using sort of small corporate structures and so on. But increasingly, and actually, what's been driven mainly by a change or a clarification from SCA in relation to the marketing of foreign funds, there had been, up until the beginning of 2023, a market practice whereby many people looking to promote or offer funds in the UAE were of the view that if you were not targeting retail investors, that there would be no obligation to register that fund with ESCA for marketing. That was not Dechert's view, but it was a view that was widely taken in the market. SCA clarified that position, as I say, in early 2023m and there was a subsequent change to the rules last year where foreign funds that had previously been registered for sale to retail investors had to de-register, and as a result of those sort of two regulatory impacts, we've seen an enormous increase in the number of local Abu Dhabi and Dubai, so ATGM and DIFC, funds, and those two jurisdictions have adopted funds laws with a variety of structures. Corporates are still very, very popular, including cell companies, but also partnerships and investment trusts. There's also opportunities to use umbrella funds, which gives clients quite a lot of structuring options, and we've seen a rise in those being set up and be marketed into the rest of the UAE using the UAE's own internal marketing passport, which is a concept that's similar to the passporting concepts in Europe. Under UCITS it's an AIFMD, but that's an enormous amount of growth. Up until 2019 there were only 16 funds that had been registered for marketing under the passport. It's now in the hundreds in terms of the vehicles that just in the last few years, the number of new funds, structures that set up. And a lot of those, some of those are domestically managed strategies in virtual asset space and other novel investment strategies and others are feeding into international managed funds.

Angelo Lercara:

OK, thank you. So, based on your experience and your daily advice, what would you consider to be the main challenges and opportunities for asset managers when raising capital in the region, Ama?

Amanjit Fagura:

It's an interesting question. There's obviously a lot of challenges similar to other markets. But one thing I would say that sets itself apart in the region is, I think maybe like seven to 10 years ago, there was this perception that a lot of managers could raise capital from the region. And I think it was true that it was quite easy to do. There was less diversity of opportunity, less products being kind of touted out in the region in terms of availability, and maybe a lot more capital at that point because there was this growth with investors in the region, across the different sovereigns, institutional investors, family offices, etc, in terms of the products they had available to them locally. So that meant, at that point, there was less choice for them. So bigger tickets, maybe, and maybe quicker deployment. So, if you had a good opportunity, had a good name behind you, you could come to the region and theoretically raise money, because they were looking to make a lot of outbound investment. I think what we're finding now is, and I think this ties in quite hand in hand with what we said before about a lot of investors requiring boots on the ground and having people or managers invest in the region, is there are a lot more products, there's a lot more managers, and there's a lot more focus on the region. And so, what we have seen is that this is discussions with our manager clients and on the investor side, they are inundated with offers or opportunities to invest, which actually means, from a manager perspective, there's a lot more work to be done to get people over the line. So what we're hearing is sometimes the lead time to getting an actual, like, cash in hand is one to two years, if not even longer. There's a lot more work done in the background, including coming to the region more often if the managers or the main teams are outside of the region, kind of sitting with and talking to those key investor clients that they've identified. And it doesn't always transpire. So I think what the ask is, is that there's a lot more saturation in the market with product, and the investors actually have their pick and their choice as to what they want to invest in. It wasn't like before, they only had a few options, and so that was it, and they went for it. And what I'm also seeing on the investor side, we have an investor-side client base in the wider GCC, they're looking at very different areas as well. So not just your typical products. I know credit is very out there and still very popular in the region because of the types of returns you get and the consistency of returns. But even just underlying areas like space, tech, venture, there's AI, crypto, it's very diversified, and I think that comes from a growth in knowledge and trying to, like, make sure their portfolios, when you're looking at them holistically, they are spread across and not just in PE, real estate infra, which were the main asset classes that maybe investors, once upon a time, used to invest in, right?

Angelo Lercara:

Right. So it's very interesting.

Colin Sharpsmith:

I would just add that, I mean, I think among our client base and our listeners probably appreciate the massive opportunities for capital raising in the region. We're continuing to see more and more international asset managers put boots on the ground, as Am said, and look to set up a presence in Abu Dhabi or Dubai - or in some cases, both - in order to access that market. One other challenge that I should mention, I've already talked about the diversified regulatory regime in terms of onshore versus offshore with respect to foreign funds that they face is the requirements under the onshore marketing regime for a local distributor to be appointed, and that has to be an authorized firm with a license from the Central Bank of the UAE or SCA. So it's not a function that's taken on by a DIFC or an ATGM representative or office. That space used to be entirely dominated by the local banks. As Ama said, with the enormous growth of products, we've also seen new entrants to the market, many new firms setting themselves up, getting themselves licensed as placement agents, which is also a reflection of the wider opportunity that the asset management industry sees in the region in order to be able to access and service that section of the market.

Angelo Lercara:

Right. So. I guess more competition as well, as a result and more difficulties to get the prospective investors' attention, actually, as you explained. But still, a huge opportunity. Are there any tax aspects that are relevant here, or any tax considerations a manager should have?

Amanjit Fagura:

So, just very high level, I mean, personal income tax is zero, so that's a big driver. I think for a lot of portfolio managers who want to relocate, maybe a branch or set up here. So personal income at the moment is zero. Whilst the tax regime actually allows for income tax, it's not been implemented. So that is at zero. Corporate tax is 9%.

Colin Sharpsmith:

But there are a number of exemptions from that corporate tax, in particular in relation to entities set up inthe financial free zones. So, in the DIFC and ADGM qualifying vs. non qualifying income can be tax exempt, and that will typically include most investment management activities. So, it's still very attractive as well from a corporate tax perspective for asset managers.

Angelo Lercara:

You've already mentioned a few upcoming strategies or trends, like credit. What are the current trends, actually, in the asset management market in the region? Are there any emerging sectors or investment strategies that are gaining popularity? I mean, as I said, You've mentioned a few, but maybe you may want to elaborate on this.

Amanjit Fagura:

Yeah, so I think credit is the new, well, it's not even new anymore. It's several years old now, but it's still very popular. And I think within that there's subcategories. So, like BDCs, I think, on the Sharia side, I can talk about specifically, a lot of the clients are looking at BDC products, which obviously have a very strict regulatory regime in the U.S. so, and navigating those with clients' CLOs and I think the direct-lending type vehicles I'm coming across very little of, so, like, primary lending-type funds. But there is still, and I know earlier I said the private equity, real estate, infra funds are less popular whilst people look at the newer strategies, but they still exist. And if there is a reputable, large manager coming to the region, they have a good book of business, and you've invested with them before, investors still look at those. It just might not make up the, I don't know, the ticket size of $250 million. If you're looking at the larger soverigns, it might be a smaller amount, because they want to put a portion of that to something else that diversifies their overall portfolio. I think, in the tech space, as I touched on earlier as well, crypto, tokenization vehicles, people are a little bit more interested in something that kind of looks different, acts different. Maybe it's a smaller ticket size, but it's something that piques interest.

Colin Sharpsmith:

Yeah, I think we've definitely seen a lot. I mean, the the ADGM was the first jurisdiction in the world to come up with a dedicated regime for virtual assets and digital assets. And the DIFC has also made a big play for this. Dubai has also got its own separate virtual assets regulatory authority, and there's a real drive in the region to try to encourage crypto financing, crypto investment, virtual assets, digital assets. And, as Ama said, tokenization of funds on the blockchain has really been getting a lot of traction and popularity, I think, in the in the region, particularly for newer managers looking to set up.

Angelo Lercara:

Colin, you have already mentioned the SCA clarification with regard to the marketing of funds. Are there any other or have there been any other recent regulatory changes that asset managers should be aware of now when approaching the region?

Colin Sharpsmith:

Yes, there was, so that one, coupled with, as I mentioned as well, the de-registration, they're no longer being able to offer foreign funds to retail investors, which has led to the de-registration of a number of UCITS and other products that have previously been offered, and the rise in the number of local products to seek to access that part of the market.

Angelo Lercara:

So, what would you need to target retail investors in the region?

Colin Sharpsmith:

Yes, so you need a public offering, a fund that's approved for public offering. So you'd have your typical public offering wrapper, and then you would need a domestic fund of some description. So, either an onshore product managed by an SCA regulated asset manager or, more commonly, particularly for our international client base, a feeder vehicle established on either the ADGM or the DIFC, which has then been notified to be sold to retail investors as part of a public offering through the rest of the UAE. So that's been a big shift, and we've seen a lot of growth in that area of feeders being set up in order to be able to continue to access that market. The other development which we're still awaiting, there have been various updates in relation to asset managers that currently got permissions to manage assets in the DIFC and the ADGM, their regulatory rules - in particular regarding regulatory capital substance requirements, systems and controls - are under review by the regulators. They're keen to adopt a proportionate and risk-based approach to encourage managers. The DIFC itself has been setting aside a specific part of the geography of the DIFC, of the buildings, to generate a specific fund management hub to make it easier for new fund managers to get office space, which has often been a bit of a challenge for managers looking to set up as space is a real premium. It's at over 99% occupancy, and so it can be a real fun fight to actually get an office. But then looking out more widely to the GCC, so outside the UAE, but looking also to Saudi, Kuwait, Oman Bahrain and Qatar, there has been agreement between the various regulators of those countries to introduce a fund marketing passport. We have yet to see what the regulatory rules will actually look like for that regime. It's not expected to apply to managers that are just based in the DIFC or ADGM, at least in its first iteration, but that's something that's being looked at more widely, and we're expecting to see something in the future.

Angelo Lercara:

Right. So that would mean, like we have in the EU for UCITS and AIFs, as we know, you would register in one country, and you could then passport throughout the GCC.

Colin Sharpsmith:

In theory. We'll wait to see what it looks like in practice.

Angelo Lercara:

OK.

Amanjit Fagura:

I mean, look, there's obviously, we're waiting to see. I think if it comes up, it's a great achievement, but there's a lot of economics that need to be discussed about how you share the fees and who gets what, and how it would look for doing it.

Angelo Lercara:

Okay. Thank you. We will continue our conversation after a short break.

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Angelo Lercara:

OK, so let's assume you meet somebody, an asset manager at an event who would currently be considering entering the market. What would be your immediate advice? So what should they, in any event, consider and think about?

Amanjit Fagura:

I mean, look, I'm going to say something now that will probably, the listeners will obviously roll their eyes out, but I'm going to say it. I think, look, given our experience in the region, getting good representation and advice, be it legal or from the local service providers, to ensure that what you are coming to the region for, understanding what you are able to do with the license you're looking to get. In place, there are a variety of licenses you can get, and Colin can talk about that kind of different ones and what they entail and what they allow you to do. But what we found from a practice perspective is a manager will come and say, "Oh, I only want to do X," but halfway down, like the process before engaging legal counsel, they've changed their mind, and then it becomes a bit more of an issue, or they feel like they haven't received the right advice, or don't have the right information to make the judgment about which license they actually need, based on what they will, in practice, be doing, versus what maybe the regulatory packets tell you you can do under license one, two or three. So I would say, if you're coming to the region, trying to understand exactly and making it very clear about what you're trying to do here. And then, from a legal perspective, we can obviously let you know what the right path is to go down and to Colin's point earlier is, if you're very serious about it, then if you find real estate that you want to sign up to do it really fast, otherwise it will probably go within a day or two. So, you'll be looking again, because that's what we've been seeing, and we've experienced with some of our clients in the past. So, I think take a practical approach in terms of setting up or looking at the region, and then in terms of more of a long term, what I would say is the market data about who's coming to the region, what managers are coming, the growth in terms of population, demographic and the types of firms and investment that is coming into the region, I think that says a lot, and that will pique a lot of our listeners' and clients' interest to see whether this is something they feel they should also be doing. So, I think that says a lot, but also just knowing that being here won't necessitate or mean that you will get cash. You have to make sure you're invested in the region, and that you are going through a process, seeing those investors that you're targeting, getting in front of them, having kind of those conversations, just being very aware of that. But again. noting that there is a lot of opportunity and there's a lot of prospect, and if those things like kind of tick your boxes, so to speak, then yeah. I mean, it's definitely something that is worth considering, if nothing else.

Colin Sharpsmith:

I completely agree that in the first instance, I have discussions very regularly with international managers considering setting up in Abu Dhabi or in in Dubai. A lot of it depends on the team that you're actually going to have on the ground, you know. So, who you're going to have is crucial, because essentially the license, depending on what license you seek, is going to provide you with regulatory coverage for real individuals on the ground to be carrying on real activities. And so that needs to be really sort of, you know, one of the main the main considerations as to, who are you actually going to have on the ground, what do you want them to be able to do?

Angelo Lercara:

Right. So, let's take a look into the future. What do you see as the future outlook for the asset management industry in the Emirates and, you already said several times, growth opportunities. Anything else?

Colin Sharpsmith:

Yeah, AUM, growth from that. The big trend has been, you know, about those sort of managers that I've been speaking to and that have set up presence. So for a long time, I think a lot of the typical applications that were being seen were predominantly marketing offices, sales offices. Increasingly, I mean there were always managers and decision makers, but the number of new entrants to the market or offices who've expanded, who've actually got portfolio managers and decision makers on the ground, living, based in, resident in Abu Dhabi and Dubai, taking investment decisions in, launching new products and managing them from Dubai and Abu Dhabi, rather than merely providing advice or marketing, has absolutely exploded. You know, AUM has increased well over 100% in the two jurisdictions over the last couple of years to hundreds of billions of dollars in each so still small compared to the big financial centers of London and New York, but very, very large in the region, and their goal of Dubai and Abu Dhabi is to encourage more of those, both international managers and local managers, to set up and to really be the center point or financial services and asset management in the in the region. And we started off talking about growth, but Dubai is planning to, on their own projection,s to double in size from about 3.4 million currently to 7 million inhabitants by 2040 so it definitely sees itself on that trajectory. And the geography of the DIFC is being expanded enormously to try and accommodate that perceived growth that the asset management industry expects in the region.

Angelo Lercara:

OK, and Ama, you said I think more strategies, more diversification, but also probably smaller tickets.

Amanjit Fagura:

Yeah, I mean, look, not necessarily. We still have very large investors and capital pools in the region, so you will still see large tickets, but maybe we will see slightly contracted, but still look large from the outside, but they may be spread a little bit more from a smaller ticket size point. And the other thing is that originally, the sovereigns were where everyone was targeting, and now I think the wider GCC, and I think again, moving away from the UAE a little bit, there's a lot more opportunity there, as they are kind of seeing the opportunity for investment and growth, and that means that it's not just the UAE, it's the wider GCC which actually helps the region and the UAE in itself, because while the wider GCC is growing, Dubai, UAE is still preferred place to live, and so people may spend a few days of the week in a different GCC region, but actually come back and home and base will be in the UAE. So I think that's definitely something that should play into the minds of the asset venture clients we have. And I think the last point I wanted to just make in terms of development in the outlook, the industry is obviously a lot younger than other jurisdictions we operate in, but one thing that we have noticed, especially in the regulatory space, is the regulators are a lot more nimble and willing to and able to react and respond to questions, to queries, and also where the market is telling them that this is not in line with or we want something slightly different. They can do that a lot faster than maybe some of the more established markets, and it's easier to have a conversation with someone two steps removed from the decision maker, within a regulator here, or even one step, or even the person who makes the decisions, then maybe it is in other jurisdictions. And I think that bodes very well, because what that demonstrates is the region really wants to grow. They really want to be doing the best in practice. And I think that is shown by how their AML regime, data privacy and other areas of law that they've actually implemented and cemented into the registry framework. That's all driven because they understand they need to keep up, and they need to be compared to and comparable with, when people are looking to invest, and they're able to react and do it a lot faster, I feel, than maybe other jurisdictions. Good point. Thanks

Angelo Lercara:

Good point. Thanks. Amanjit, Colin, a big thank you for joining us and sharing your insights with us. We really appreciated your expertise, and it's been great having you in this conversation. Thanks a lot.

Amanjit Fagura:

Thank you so much. Angelo,

Colin Sharpsmith:

Thank you.

Angelo Lercara:

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