Structuring in a New World: Jurisdiction as Strategy

Jurisdictional choice has always mattered in fund structuring. What has changed is why it matters.
In today’s more fragmented and uncertain economic environment, jurisdiction is no longer simply a technical or operational decision. It has become a core risk allocation choice. Fund managers are increasingly asking not only what works today but what will stand up in five years’ time, to investors, boards and regulators. This shift reflects a broader transformation across private markets, driven by evolving investor expectations, product innovation and structural complexity.

These issues and more were discussed at our most recent Funds Focus event (Monday 20 April) titled ‘Structuring in The New World’ hosted in London.

Investor dynamics reshaping structures

Investor composition is playing an increasingly influential role in structuring decisions. Family offices and high-net-worth individuals are expanding their exposure to alternatives, already allocating more than 40% of portfolios to private markets (UBS, Global Family Office Report 2025) , with many planning further increases.

At the same time, managers are diversifying their capital base beyond traditional institutional investors. This is leading to blended investor pools, each with different priorities around governance, liquidity, transparency and fee structures.

The result is a key challenge for managers who are now looking at how to reconcile differing investor expectations without slowing execution.

From standardisation to precision

Alongside investor change, innovation in products and strategies is expanding the structuring toolkit. Growth in areas such as co-investment and continuation vehicles, carry and incentive structuring and tokenisation and digital asset representation have all significantly increased both choice and complexity.

Rather than standardised fund models, managers are increasingly deploying bespoke, multi-layered structures, including non-fund vehicles where appropriate. Co-investments alone now account for a significant share of deal activity, reflecting demand for more tailored exposure.

This is not complexity for its own sake. It is precision, aligning structures more closely with the specific needs of different capital pools.

The rise of digital structuring
Tokenisation and digital investing are also gaining traction, offering the potential for improved liquidity, transparency and operational efficiency.

Jersey has been at the forefront of this evolution, developing expertise early in the tokenisation space and supporting innovative structures that combine traditional legal certainty with digital capabilities. This positions Jersey’s IFC strongly as digital representation of assets becomes more mainstream.

Execution: certainty and efficiency matter more than ever

As structuring becomes more tailored, execution risk becomes a critical consideration.

Managers are prioritising jurisdictions that can deliver:

• speed to market
• regulatory clarity
• cost efficiency
• long-term certainty

The ability to execute structures efficiently, while maintaining flexibility is increasingly a differentiator.

Why this matters for Jersey
These trends are highly relevant to Jersey’s position as an international finance centre.

Jersey’s longstanding strengths including political stability, a pragmatic regulatory framework, and deep industry expertise are increasingly aligned with what managers require in this new environment.

Importantly, Jersey’s flexible approach to defining and regulating funds allows for greater structuring optionality, particularly for co-investment vehicles, single-asset structures and other bespoke arrangements.

Combined with its experience across global markets and continued focus on innovation, this enables Jersey to play a central role whether as a primary domicile or as part of a broader multi-jurisdictional structure.

Ultimately, structuring is not becoming more complex for the sake of it, it is becoming more targeted and defensible. The challenge for managers is bringing together different investor requirements in a way that remains robust, efficient and future proof.

Visit our dedicated fund page, to learn more about Jersey’s Fund offering.

A special thanks to our panel: Katie Leah, Partner, Skadden; Mike Byrne, Jersey Funds Association and Partner and Asset Management Leader, PwC Channel Islands; Robert Milner, Partner, Carey Olsen; Sophie Forbes, Head of Legal, TreasurySpring; and Tim Morgan, Partner, Appleby. And to our event sponsor Grant Thortnon.