<\/p>\n
In the UK, the SPV must rely on one of the FCA\u2019s financial promotion exemptions, most commonly the high-net-worth individual or sophisticated investor categories defined under FSMA 2000. UAE DIFC-based SPVs may issue interests under the DFSA\u2019s Offered Securities Rules or as private placements to a maximum of 50 investors. Canadian issuers rely on the accredited investor exemption or minimum investment amount exemption under National Instrument , each carrying its own disclosure obligations and investor qualification requirements.<\/p>\n<\/p>\n