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ADGM · VARA · El Salvador · BVI · Panama

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RESEARCH NOTE
ADGM / FSRA·14 claims·84%·78s

1. The Regulatory Trigger

COBS 23.12.2 imposes a binary prohibition: an Authorised Person must not offer or arrange for Retail Clients to subscribe to copy trading, mirror trading, or similar services unless it holds a Financial Services Permission to undertake the Regulated Activity of Managing Assets.COBS 23.12.2VERIFIED

2. The Block-Delegation Model

The "similar services" catch-all is purposively broad and captures functional equivalents regardless of how the arrangement is characterised. Parameter-setting by the client does not constitute the investment decision.COBS 23.4.1SUPPORTED

3. FSRA Supervisory Discretion

The requirement to implement systems and controls "to the satisfaction of the Regulator" confers broad FSRA discretion to look through any structural characterisation of the arrangement.COBS 23.12.2SUPPORTED

REFERENCE MATERIAL

VERIFIEDCOBS 23.12.2

COBS 23.12.2 requires a Managing Assets FSP for copy/mirror trading to Retail Clients.

SUPPORTEDCOBS 23.12.2

FSRA retains broad supervisory discretion under the "satisfaction of the Regulator" standard.

INFERREDPRU 1.3.3

A Category 3A licence would be required in addition to the Managing Assets FSP.

● live corpus·ADGM / FSRA·67,056 provisions
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ADGM

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VARA

Dubai

El Salvador

CNAD

BVI

FSC

Panama

SMV

COMING

Saudi Arabia

CMA · Q3 2026

Mauritius

FSC · Q3 2026

Pakistan

SECP · Q3 2026

Bahrain

CBB · Q4 2026

Kenya

CMA · Q4 2026

Nigeria

SEC · Q4 2026

Rwanda

BNR · Q4 2026

Singapore

MAS · Q1 2027

67,056Individual provisions searchable
2,382Regulatory documents indexed
5Jurisdictions live
“

QANUN exists because the regulatory question and the answer to it have always lived in different places. The question lives with the practitioner — the founder applying for a licence, the CLO mapping a product against seventeen provisions, the compliance officer monitoring a regulatory change that landed at 11pm.

The answer lives in a corpus of thousands of provisions, scattered across rulebooks, circulars, and guidance notes, with no index and no memory.

We built QANUN to close that gap. Not with a chatbot. With a system that reads the corpus the way a senior counsel reads it — structurally, adversarially, completely — and gives you a research note you can act on. This is what QANUN does.

Oliver Cook KC

Co-founder · Barrister, Libertas Chambers

Author of the COBS 23.12.2 brief reproduced in the research terminal above.

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