Asset Atrium Compliance Framework
Internal Use Only
Mandate sources
Investment mandates in Asset Atrium originate from three sources: the fund prospectus (legally binding investor-facing limits), Investment Policy Statements (IPS) (client-specific guidelines), and regulatory requirements (UCITS, AIFMD, SEC). All three are modeled as compliance rules and evaluated together.

Mandate rule library

Asset Atrium maintains a centralized rule library where compliance teams define reusable rule templates. Each rule template specifies a limit type, applicable asset class, threshold parameters, and breach severity. Rules are assigned to funds individually or through inheritance from fund groups.

Rule TypeDescriptionParameter ExampleBreach Severity
Percentage LimitMaximum or minimum portfolio weight for an asset class, sector, country, or issuerMax 5% in single issuerConfigurable
Absolute LimitMaximum notional or quantity exposure in a specific instrument or currencyMax USD 50M in OTC derivativesConfigurable
Count LimitMaximum number of positions meeting a conditionMax 3 unrated bond positionsSoft
Rating FloorMinimum credit rating for individual holdings or weighted average portfolio ratingMin avg BBB-; no holdings below CCCHard / Soft
Duration LimitPortfolio effective duration must stay within a bandDuration between 3.0 and 7.0 yearsSoft
Liquidity RatioMinimum percentage of portfolio that can be liquidated within N daysMin 80% liquidatable in 5 business daysSoft
Restricted ListInstruments or issuers explicitly prohibited from the portfolioNo tobacco companies; no sanctioned entitiesHard
Eligible UniverseOnly instruments from a defined universe may be heldOnly MSCI World constituentsHard
Relative-to-BenchmarkExposure deviation from benchmark within allowed tracking error bandSector weight within +/- 5% of benchmarkSoft

Rule inheritance hierarchy

Asset Atrium supports a hierarchical rule assignment model. Rules defined at a higher level are inherited by all funds in the hierarchy. Fund-level overrides can tighten inherited limits but cannot relax them (unless explicitly authorized by CCO).

Hierarchy LevelScopeOverride Behavior
Firm-wideAll funds managed by the firmCannot be relaxed at lower levels
Fund Family / UmbrellaAll sub-funds under an umbrella structure (for example, SICAV)Inherits firm-wide; can add or tighten
Share Class GroupAll share classes of a fundInherits umbrella; can add or tighten
Fund / Sub-FundIndividual fund or sub-fundInherits parent; can add or tighten; relaxation requires CCO approval
Sleeve / StrategyPortfolio sleeve or strategy bucket within a fundInherits fund; limits apply to sleeve NAV
Inheritance lock
Firm-wide and regulatory rules are flagged as locked in the rule library. Locked rules cannot be modified or overridden at any level in the hierarchy. Only the Chief Compliance Officer can unlock a rule, and the unlock action is recorded in the compliance audit trail.

Mandate lifecycle

  1. Fund onboarding: Compliance team models the fund prospectus, IPS, and applicable regulatory limits as rules in Asset Atrium.
  2. Rule assignment: Rules are assigned to the fund directly or inherited from the hierarchy. Effective rule set is computed.
  3. UAT validation: Rules are tested in simulation mode using historical portfolio data to verify expected behavior.
  4. Activation: Rules are activated for pre-trade and post-trade compliance. Activation date is logged.
  5. Mandate change: When IPS or prospectus changes, rules are versioned. Old version is deactivated; new version activated. Both versions are retained for audit.
  6. Fund termination: Rules are deactivated upon fund liquidation. Rule history is retained per regulatory retention schedule.

Rule versioning

Every change to a compliance rule creates a new version. Asset Atrium maintains the complete version history including:

Exception handling

In specific circumstances, a fund may require a temporary exception to a mandate rule. Asset Atrium supports formal exception management:

Exception TypeApproval RequiredDurationMonitoring
Temporary limit relaxationCCO + PM + Fund Board (if prospectus limit)Max 90 days; renewable onceDaily compliance check continues; exception flagged in report
New instrument eligibilityCompliance Officer + PMPermanent (new rule version) or time-limitedPre-trade checks updated immediately
Regulatory grace periodAutomatic (system-configured per regulation)Per regulation (for example, 30 days for UCITS passive breach)Countdown visible in breach manager; auto-escalation at deadline
Benchmark transitionCompliance OfficerUntil rebalance completeRelative-to-benchmark rules suspended with audit flag
Bulk rule assignment
When onboarding a large fund family (for example, 50+ sub-funds under a SICAV), use the Asset Atrium bulk rule assignment feature. Define rules at the umbrella level and apply them to all sub-funds in a single operation. Fund-specific overrides can be applied afterward.