What it was
Three Arrows Capital was a hedge fund that traded crypto assets. Two entities carried the name. Three Arrows Capital, Ltd. was the fund, incorporated in the British Virgin Islands. Three Arrows Capital Pte. Ltd. was the Singapore manager, which held registered fund management company status from the Monetary Authority of Singapore in August 2013. That status allowed it no more than 30 qualified investors and no more than S$250 million under management.
MAS records that the Singapore firm transferred management of its only fund to an offshore entity in the British Virgin Islands on 1 September 2021, resumed managing part of that fund's assets in February 2022, and told MAS on 29 April 2022 that it would stop fund management in Singapore from 6 May 2022. Two months later the fund was in liquidation.
The collapse
On 27 June 2022 the Eastern Caribbean Supreme Court in the High Court of Justice in the British Virgin Islands placed Three Arrows Capital, Ltd. into liquidation and appointed Russell Crumpler and Christopher Farmer of Teneo as joint liquidators. The liquidation is still running, with filings published on the liquidators' own site.
What the regulator found
The Monetary Authority of Singapore reprimanded Three Arrows Capital Pte. Ltd. on 30 June 2022. The findings were that the firm had failed to ensure information given to MAS was not false or misleading, contrary to section 329(1) of the Securities and Futures Act, that it had failed to notify MAS of changes to its directors' shareholdings, and that it had exceeded the S$250 million threshold between July 2020 and September 2020 and again between November 2020 and August 2021.
On 14 September 2023 MAS issued nine-year prohibition orders against Zhu Su, the firm's chief executive and a director, and Kyle Livingston Davies, its chairman and a director, for contraventions of the same Act and its regulations, including a further instance of providing false information in January 2022 and a failure to have any risk management framework for the crypto assets under management.
These are regulatory findings of statutory breach, not findings of fraud, and the entry is tagged accordingly.
Three Arrows built nothing on Bitcoin. It was a borrower and a holder, and it is listed because the size of its book made its liquidation a fact the rest of this batch has to be read against. Listing here is not endorsement.