Case Studies
What the work
actually looks like.
All client details are anonymised. Jurisdictions, regulatory frameworks, and mandates are accurate. These represent the type of problems Black Sea is engaged to solve.
First-time manager structures defense-adjacent fund under AFSA Capital Markets Rules following January 2026 amendments
A European national with existing AIFC authorisation sought to raise a closed-end fund targeting dual-use technology investments. The structure needed to satisfy AFSA's expanded approved person requirements under the January 2026 amendments, accommodate non-Kazakh LP onboarding from three jurisdictions, and demonstrate full AML/CFT compliance under the amended Digital Assets Rules — all before a regulatory submission window closed.
The problem
The manager had completed initial AIFC authorisation under the pre-amendment framework. The January 2026 amendments invalidated several elements of the existing compliance documentation. A new regulator submission was required, but the pre-amendment advisors did not understand the updated requirements.
Outcome
Updated regulatory submission completed in 6 weeks. AML/CFT framework redesigned for the amended Digital Assets Rules. Approved person assessments updated. Fractional CCO engaged for ongoing supervision at €600/month.
Digital asset custodian builds CBN-compliant AML implementation roadmap for June 2026 deadline under dual ARIP and CBN obligations
A Nigerian digital asset custodian operating under the SEC Regulatory Incubation Programme faced simultaneous compliance obligations under two separate frameworks. The CBN's Circular BSD/DIR/PUB/LAB/019/002 required a formal automated AML implementation roadmap covering 12 functional areas by June 10, 2026. The ARIP framework added additional investor onboarding and custody documentation requirements. No existing advisor had clear visibility across both frameworks.
The problem
Seven days to deadline. No roadmap in place. Previous compliance advisor had focused on ARIP and had not addressed the CBN AML automation requirement, which applied separately and required a distinct submission to the CBN Compliance Department.
Outcome
CBN-compliant roadmap covering all 12 functional areas delivered in 7 days. Automated transaction monitoring architecture specified. Sanctions screening integration documented. Submitted to CBN Compliance Department ahead of deadline.
Crypto fund manager builds unified AML/CFT architecture across ADGM and VARA jurisdictions, incorporating CPF obligations under UAE Federal Decree
A fund manager with separately licensed entities in ADGM and the VARA jurisdiction needed a single AML/CFT compliance architecture that satisfied FSRA and VARA requirements without creating internal contradictions. The UAE Federal Decree-Law No. 10/2025 on Combatting Proliferation Financing added a third layer of obligation that applied across both entities simultaneously. MLRO certifications were due for renewal under VARA's February 2026 cycle.
The problem
The existing compliance documentation had been produced separately for each entity by different advisors. The two frameworks had developed conflicting definitions and inconsistent escalation procedures. The CPF decree created new obligations that neither existing framework addressed.
Outcome
Unified AML/CFT framework designed across both entities. CPF obligations integrated across ADGM and VARA frameworks. MLRO function documented and certified. 8-week delivery. Ongoing quarterly review retainer.
Fractional CCO mandate supports emerging defense fund manager through first AIFMD regulatory cycle, LP onboarding, and regulator correspondence
A first-time European fund manager targeting NATO-adjacent defense and dual-use investments needed ongoing compliance oversight after fund formation without the cost of a full-time CCO. The manager's investor base spanned three EU jurisdictions, each with different KYC/AML expectations for institutional LP onboarding. The first annual AIFMD reporting cycle was approaching.
The problem
Fund formation had been completed but the compliance infrastructure was minimal. No documented LP onboarding procedure, no AML policy, no internal escalation framework. The first LP closing required institutional-grade documentation that did not exist. The regulator was expecting a first annual report within 60 days.
Outcome
Complete AML/KYC policy framework documented in 3 weeks. LP onboarding procedures built for three jurisdictions. First AIFMD annual report prepared and filed. Regulator correspondence handled. Retained at €600/month for ongoing CCO mandate.
VASP operator prepares for NBG registration following October 2025 enforcement push, while positioning for Open Finance programme engagement
A digital asset operator active in the Georgian market was operating without formal NBG VASP registration at the time of the October 2025 enforcement push. The operator needed to both remediate the registration gap and position for the World Bank-backed Open Finance initiative that NBG was driving simultaneously. Two separate regulatory tracks with overlapping timelines.
The problem
No existing advisor in Georgia with combined VASP compliance and Open Finance regulatory expertise. The operator had relationships at NBG but not the compliance documentation infrastructure required for formal registration. The Open Finance initiative required engagement at a different level of the institution.
Outcome
NBG VASP registration documentation completed. AML/CFT framework designed for Georgian regulatory requirements. Open Finance regulatory advisory engagement established with relevant NBG team. Ongoing advisory retainer.
Licensed exchange prepares MiCA readiness assessment while maintaining ADGM compliance, managing cross-regulatory gap between EU and UAE obligations
A digital asset exchange with ADGM authorisation sought to understand its MiCA obligations as it began onboarding European retail and institutional clients. The MiCA requirements for crypto asset services providers interact with, but do not align cleanly to, the ADGM framework. The operator needed to understand what was required, what gaps existed, and whether a separate EU authorisation was the right path.
The problem
No advisor with visibility across both frameworks. MiCA specialists understood EU requirements but not ADGM. ADGM specialists understood the local framework but not MiCA's extraterritorial reach for non-EU operators targeting EU clients.
Outcome
MiCA applicability assessment completed. Gap analysis against existing ADGM framework produced. Recommended pathway: enhanced ADGM compliance documentation with EU-equivalent disclosure standards, deferring full EU authorisation pending volume thresholds. Written report delivered in 2 weeks.
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