A comprehensive register, heat map, dependency analysis, and milestone schedule governing Fund I's path to first close and first deployment. Each risk is owned, scored, and on a defined review cadence.
| 1 | Remote — <10% probability |
| 2 | Unlikely — 10–30% |
| 3 | Possible — 30–60% |
| 4 | Likely — 60–85% |
| 5 | Near-certain — >85% |
| 1 | Nuisance — minimal disruption |
| 2 | Minor — limited delay or cost |
| 3 | Material — significant delay or cost |
| 4 | Severe — puts first close at risk |
| 5 | Existential — could end the fund |
| Severity | Score Range | Review Cadence |
|---|---|---|
| High | ≥ 15 | Weekly review by Founding Principal |
| Medium | 8 – 14 | Bi-weekly review |
| Low | ≤ 7 | Monthly review |
| Category | High | Medium | Low |
|---|---|---|---|
| US Regulatory | 1 | 5 | 4 |
| Bolivia / Cross-Border | 4 | 3 | 2 |
| Operational | 1 | 3 | 2 |
| Capital Formation / LP | 3 | 4 | 1 |
| Counterparty | 1 | 2 | 1 |
| Compliance / AML / Sanctions | 1 | 2 | 1 |
| Personnel / HR | 1 | 1 | 1 |
| Market | 1 | 2 | 1 |
| Technology / Cyber | 1 | 2 | 2 |
| ID | Category | Risk | L | I | Score | Owner |
|---|---|---|---|---|---|---|
| R-US-02 | US Regulatory | Reg D 506(b) general-solicitation violation before 506(c) decision | 3 | 5 | 15 | Founder + Counsel |
| R-BO-01 | Bolivia | ASFI / Ministry of Mining licensing changes restricting foreign-funded purchasing | 3 | 5 | 15 | Bolivia Counsel |
| R-BO-07 | Bolivia | OECD / responsible-sourcing audit failure or NGO red-flag on artisanal mining | 3 | 5 | 15 | Ops + CCO |
| R-LP-01 | Capital / LP | Anchor LP withdraws before first close | 3 | 5 | 15 | Founder |
| R-LP-02 | Capital / LP | First-close minimum not reached by target date | 3 | 5 | 15 | Founder |
| R-CM-01 | Compliance | AML program inadequate at first subscription | 3 | 5 | 15 | CCO |
| R-HR-03 | Personnel | CCO / compliance hire fails or departs | 3 | 5 | 15 | Founder |
| R-IT-01 | Technology | Wire fraud — spoofed email instructing capital movement | 3 | 5 | 15 | Treasury |
| R-BO-02 | Bolivia | Bolivian tax / royalty regime change reducing exporter margins | 3 | 5 | 15 | Bolivia Counsel + CFO |
| R-CP-04 | Counterparty | Primary US bank de-risks the Partnership; capital-call account closure | 3 | 5 | 15 | Treasury + Founder |
| R-LP-06 | Capital / LP | Track-record gap deters second-close LPs; AUM growth stalls | 3 | 5 | 15 | Founder + IR |
| R-MK-02 | Market | Bolivia political instability / elections-driven policy shift on mining exports | 3 | 5 | 15 | Bolivia Counsel + CCO |
All twelve risks scoring ≥ 15 are listed above. Full register and mitigation detail in the Risk Management Framework PDF.
| Gate | Trigger | Hard Conditions That Must All Be Met |
|---|---|---|
| Gate A — First-Close Ready | Cannot accept any subscription until met | (i) Delaware LP formed; (ii) LPA, IPS, Subscription Agreement, Investor Questionnaire executed by counsel; (iii) FinCEN-compliant AML program in place; (iv) outsourced CCO engaged; (v) fund admin engaged; (vi) US operating + capital-call bank accounts open; (vii) anchor LP soft-circled and side-letter terms agreed. |
| Gate B — Operational Proof | Cannot deploy first Bolivia trade until met | (i) Bolivia counsel engaged; (ii) licensed exporter onboarded with KYC clear; (iii) OECD due-diligence pack complete; (iv) Miami refinery PO executed; (v) third-party escrow agent engaged with staged-release framework; (vi) marine cargo insurance bound; (vii) auditor engagement letter signed. |
| Scenario | What's Stressed | What Triggers Action |
|---|---|---|
| 1. Commodity shock | 25% decline in gold and silver spot | If estimated portfolio net IRR < 10%, IC convenes special review of pipeline & reserves |
| 2. Hold extension | 90-day extension on every Bolivia trade in process | Liquidity reserve must remain ≥ 10%; new trade pacing slows |
| 3. Refinery counterparty failure | Loss of one Miami refinery counterparty mid-trade | Activate secondary refinery PO; trigger insurance and assay-holdback workflows |
| 4. LP default cluster | 25% of committed capital becomes Defaulting Partner status | Default remedies invoked; deployment cadence rebuilt against reduced AUM |
| 5. Loss of single licensed exporter | Largest exporter relationship goes offline (license, regulatory, business) | Activate backup exporter pool; suspend new pipeline until alternative onboarded |
Stress-test results are summarized in each quarterly LP letter without disclosing counterparty identities subject to confidentiality.
| Risk | Mitigation in Place |
|---|---|
| Anchor LP withdrawal pre-close | Two-anchor strategy — never depend on a single anchor for first close. |
| 506(b) general-solicitation slip | Pre-existing-relationship documentation collected before any substantive discussion; counsel-reviewed outreach materials. |
| Compliance ramp lag | Outsourced CCO firm engaged by Month 2; in-house CCO target by Month 12. |
| Wire fraud | Dual-control policy on every outgoing wire + verbal callback to a verified phone number for any payment-instruction change. |
| Bolivia license / regime shift | Bolivia counsel monthly regulatory monitoring; trade pacing tied to license renewal cadence; insurance per case. |
| OECD / NGO audit failure | Pre-trade OECD due-diligence pack required before deployment; CCO quarterly review. |
| AML inadequacy at first subscription | FinCEN-compliant program live before Gate A; KYC vendor SLA in place. |
| Bank de-risking | Backup banking relationship pre-onboarded by Month 6. |
| ID | Risk | Score | Embedded Mitigant |
|---|---|---|---|
| R-BO-05 | Title / chain-of-custody dispute on mineral lot | 10 | Independent assay at origin; signed handoff docs at every stage; insured custody. |
| R-BO-06 | Refinery counterparty repudiation or payment delay | 10 | Pre-negotiated PO; bonded warehouse receipt; escrow-holdback for assay variance > 2%. |
| R-BO-08 | Bribery / FCPA exposure via Bolivian intermediary or customs broker | 10 | Vetted intermediary list; FCPA training; CCO quarterly review. |
| R-OP-03 | Cargo theft, hijack, or pilferage in transit | 10 | GPS tracking; full replacement-value cargo insurance; vetted freight operator. |
| R-OP-05 | Six-stage process bottleneck — KYC clearance > 7-day SLA | 12 | KYC vendor SLA contract; CCO ownership; pipeline staging. |
| R-CP-01 | Exporter default — fails to deliver after deposit paid | 10 | No advance capital to exporter under any circumstances; staged escrow release tied to verified milestones. |