Two entities, one depositary, an independent AIFM.
The architecture is deliberately conservative. Capital sits in a Luxembourg RAIF; origination happens in a regulated French SAS; assets are held by Swissquote; investment decisions are made by an independent AIFM. No co-mingling, no shortcuts.
Counterparties
Why two entities
Cross-border financing for the diaspora collapses without a clean separation between the side that originates loans (subject to French consumer-credit and intermediation rules) and the side that pools investor capital (subject to AIFMD II in Luxembourg). A single entity would compromise both.
The RAIF holds the receivables; the SAS executes the originations under French law; the depositary verifies asset ownership and cash movements; the AIFM signs off on every investment decision. Each party has one job and one regulator.
Editorial activity (Nova Observatory) sits outside both structures. Articles are not investment advertisements; the firewall is documented in our editorial standards.
Documents
The constitutive documents — RAIF prospectus, AIFM mandate, depositary agreement, French originator license — are available to qualified counterparties on request. A redacted memorandum is provided to LPs entering due diligence.