The structures regulators
won't explain for you.

Black Sea advises fund managers, family offices and digital-asset operators on the parts of a structure where regulation, jurisdiction and cross-border practice intersect. We work where most consultancies stop and most law firms slow down.

13
Jurisdictions we operate in
2wk
From first call to written gap report
Zero
Hourly billing. Ever.
One
Conversation to know if we fit

We work with specific
types of problems.

Yes This is for you if
  • You are raising a fund into defense or dual-use and need end-to-end compliance from regulator to LP closing.
  • You hold an AIFC, ARIP, VARA, or ADGM licence and are not certain your compliance infrastructure would survive a routine supervisory visit.
  • You are a digital asset operator trying to navigate a jurisdiction — AFSA, NBG, SEC Nigeria — where the rules are new and the advisors are scarce.
  • You need a fractional CCO on a retained basis because a full-time hire is not yet justified.
  • You have a specific structural problem — multi-jurisdiction AML, UBO complexity, counterparty due diligence — and want it solved with a defined scope and fixed price.
  • You are a fund administrator, law firm, or placement agent whose client needs compliance support outside your core mandate.
No This is not for you if
  • You want general business advisory, strategy consulting, or market research without a specific regulatory or structural problem.
  • You need a regulated legal opinion signed by a licensed lawyer. We work with partner counsel for that; we are not the law firm.
  • You are looking for the cheapest route through a compliance requirement. We scope properly, which means we price properly.
  • You cannot provide verifiable beneficial ownership information. We run UBO and sanctions screening on all prospective clients before engagement.
  • You want an advisor who will tell you what you want to hear. The first call is a qualification exercise — we say no when we should.

Diagnostic in two weeks.
Everything starts here.

What you bring
  • A 30-minute call describing what you are trying to structure or solve
  • Basic information about your entity, jurisdiction, and current compliance status
  • Existing regulatory correspondence or licences, if any
  • No preparation required beyond that
What you receive
  • A written gap report identifying compliance gaps against the applicable framework
  • A prioritised remediation list with clear next actions
  • A timeline and scope for what a full engagement would involve
  • An honest assessment of whether one is needed
Who it is for
  • AIFC-authorised firms facing the post-amendment supervisory cycle
  • Digital asset operators before or after licensing in ARIP, VARA, ADGM, NBG
  • Fund managers before a first LP closing or regulatory submission
  • Any operator who suspects a gap but does not know where to start

Three types of problems
we solve.

Emerging manager
Problem
First-time fund manager with AIFC authorisation needed to raise a closed-end fund targeting dual-use technology. January 2026 AFSA amendments had invalidated key elements of existing compliance documentation. Regulator submission window approaching.
Scope
Updated approved person assessments. AML/CFT framework redesigned for amended Digital Assets Rules. New regulatory submission drafted and filed.
Outcome
Submission complete in 6 weeks. Fractional CCO retained at €600/month for ongoing supervision.
Crypto operator
Problem
Nigerian digital asset custodian under SEC ARIP with 7 days to CBN June 2026 deadline. No AML implementation roadmap existed. Previous advisor had focused on ARIP and missed the CBN obligation entirely.
Scope
CBN-compliant AML roadmap covering all 12 functional areas. Automated monitoring architecture specified. Submission package prepared.
Outcome
Delivered in 7 days. Submitted to CBN Compliance Department ahead of deadline.
Licensed operator
Problem
Crypto fund manager with ADGM and VARA entities needed a unified AML/CFT framework satisfying both regulators without contradiction. UAE Federal CPF Decree added a third layer of obligation.
Scope
Unified AML/CFT architecture across both entities. CPF obligations integrated. MLRO function documented and certified.
Outcome
8-week delivery. Quarterly review retainer ongoing.

Three things, done properly.

We do not consult on everything. Black Sea operates in three areas, each defined by a regulatory or structural problem that benefits from operator-side experience. Every engagement starts with a fixed-price diagnostic.

EU · Defense Capital

Fund formation for emerging managers

Structuring vehicles for first- and second-time fund managers raising into European defense and dual-use opportunities. End-to-end from regulator engagement through closing.

  • SICAV and AIF design
  • Regulator submission support
  • Fractional CCO mandate
  • LP onboarding readiness
Full details →
Frontier Markets

Cross-border regulatory positioning

Licensing and compliance advisory for crypto and fintech operators navigating frameworks most advisors avoid. AIFC, Nigeria ARIP, UAE VARA, Georgia NBG.

  • ARIP and AFSA gap analysis
  • VARA and ADGM licensing
  • Multi-jurisdiction AML/CFT
  • UBO and sanctions screening
Full details →
Regulatory Advisory

Compliance architecture and assurance

For operators who already hold licences and need EU-grade compliance infrastructure. AML/KYC framework design, MiCA readiness, counterparty due diligence.

  • AML/KYC framework design
  • MiCA and DORA readiness
  • Counterparty due diligence
  • Ongoing retainer from €600/mo
Full details →

Not sure which practice applies to your situation? That is what the 30-minute call is for.

Request a call →

Operator-side.
Not consultancy-side.

01

We've sat the seat

Our team has built and run regulated structures. The advice is what we would have wanted when we were on the other side of the table.

02

Clear scope, fixed price

Diagnostic in two weeks. Full mandates scoped on the front end. Hourly billing creates the wrong incentives — we don't use it.

03

Licensed counsel when needed

For matters requiring regulated legal opinion, we retain partner counsel in the right jurisdiction. We do not pretend to be the law firm.

Writing on what we see.

All briefings →

A short conversation tells you
whether we're the right fit.

Most engagements start with a 30-minute call. We review what you're trying to structure or solve, tell you honestly whether we can help, and what it would look like if we did.