What Is a RAIF Fund and Why Did Corinth Use One?

A Registered Alternative Investment Fund (RAIF) is a collective investment vehicle available under Cyprus and Luxembourg law. RAIFs are subject to lighter regulatory oversight compared to fully licensed funds — they do not require individual product approval from the securities regulator, but they must be managed by a licensed AIFM (Alternative Investment Fund Manager). [Source: CySEC regulatory framework]

How the RAIF Structure Works

Under the Cyprus RAIF framework, the fund itself is registered (not licensed) with CySEC, while the fund manager must hold a separate AIFM licence. This creates a two-tier structure: the RAIF is the investment vehicle that holds assets and issues shares to investors, and the AIFM is the management company responsible for investment decisions, risk management, and regulatory compliance. The RAIF can be structured with multiple sub-funds, each with different investment strategies. [Source: Cyprus Alternative Investment Funds Law of 2018]

Corinth's RAIF Structure

Corinth Capital RAIF V.C.I.C. Ltd (HE 409232, RAIF31) was structured as a Variable Capital Investment Company with five sub-funds, including a "Naturalization Estate Fund" — named in a manner suggestive of connection to Cyprus's Citizenship by Investment Programme (CBI), which was abolished in November 2020 following corruption scandals. The RAIF was managed externally by SCSS Fund Management Ltd (AIFM04/56/2013) and internally by Corinth Fund Management Ltd (AIFM48/56/2013). [Source: CySEC RAIF register, Cyprus company registry]

What Happened to Corinth's RAIF

CySEC revoked the AIFM licence of Corinth Fund Management Ltd on 3 October 2022, after only 7.5 months. The Corinth Capital RAIF was subsequently dissolved in January 2023. A successor entity — Three Tuns Capital RAIF F.C.I.C. PLC (C 439913, RAIF143) — was established with entirely new directors, but is itself now under Members Voluntary Winding Up. The directors of the original Corinth Capital RAIF included a mix of Swiss nationals (Matthias Baechler, Dr. Conrad Weinmann), Cypriot professionals (Andreas Matsas, Socrates Fekkas, Charalambos Stefanou), and an Austrian/German financier (Dr. Gerhard Waldheim). [Source: CySEC registers, Cyprus company registry]

Why the RAIF Structure Is Relevant

The RAIF structure is relevant to the Corinth Group investigation because it provided a regulated fund vehicle that could be used to market investments to institutional and qualified investors. Multiple independent complainants describe a pattern where the existence of a CySEC-registered fund was cited as evidence of legitimacy when soliciting advance fees. The rapid revocation of the AIFM licence and dissolution of the RAIF raises questions about the governance and compliance of the fund structure. [Source: Third-party fraud reports on Ripoff Report and Diebewertung.de]

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