How to Raise a VC Fund in Australia - Part III (Running the Fund Post-Close)
The ops that quietly kill emerging managers.
A 3-part instruction manual for first-time fund managers.
đ This is Part 3 of a 3-part series on raising and running a VC fund in Australia.
â Want the full checklist of every step across all three parts?
Part III is about the operational load that starts the moment the fund closes.
AML checks. Capital calls. Quarterly NAV statements. Annual AMMA filings. The compliance treadmill that never fully stops.
Reuben AI is built to run this layer so you donât have to, from LP onboarding through to the annual audit, in one platform, from fund one.
Use code BATKO for 15% off â goreuben.com
Disclaimer: this is not financial or legal advice. I donât hold an AFSL. Please consult a lawyer and accountant. Everything below is my experience and recollection, and I may have mis-remembered some finer points
Youâve done it.
The fund is closed. The docs are signed. The LPs are committed.
Youâre ready to invest, right?
Well, not quite. đ
Then the next thing comes up.
Well, not quite. đ
Then the next thing.
This is the part nobody puts in the pitch deck. Before you write a single cheque, thereâs a cascade of compliance steps, registration requirements, and investor onboarding that sits between you and your first investment. And once youâre finally deploying, a reporting treadmill that never fully stops.
Welcome to running the fund.
Audits are like due diligence. The prepared teams make it look easy.
If youâre raising, or helping founders raise, security and compliance will come up. Institutional investors and enterprise customers want to see SOC 2 or ISO 27001. Most startups hit this wall later than they should.
Vanta put together a free, 30-minute on-demand session covering exactly this:
- what audits are,
- what drives up the cost and time, and
- what separates the teams that breeze through from the ones that donât.
An auditor from Armanino shares the honest take from the other side of the table.
Worth 30 minutes if you or any founders in your portfolio are thinking about this.
đ§ Before You Can Invest: The Setup Nobody Mentions
The Trust Deed is signed. The fund is legally established.
Hereâs what still needs to happen before you can touch the money:
Settlor. You need someone appointed as Settlor to formally establish the trust. Usually your accountant. Sounds trivial - itâs another form, another fee, another signature chain.
AUSTRAC. Register the fund with the Australian Transaction Reports and Analysis Centre for VCLP status. This is where your anti-money laundering compliance framework officially starts.
GIIN. If you have foreign investors, apply for a Global Intermediary Identification Number from the IRS - yes, the American IRS. Welcome to the joys of global capital.
Bank account. In theory, simple. In practice, banks take a surprisingly long time to open accounts for new trust entities. Start early.
Insurance. Youâll need Investment Managers insurance and Directors & Officers (D&O) coverage before youâre operational. Get quotes well before close - insurers donât move quickly.
Once all of that is sorted, you can start signing up investors.
Well, not quite. đ
đ Signing Up Investors: The Compliance Gauntlet
Before any LP signs a Subscription Agreement, you need a stack of documents from each of them. Every single one.
AML Check. Anti-Money Laundering verification on every investor - identity documents, source of funds, beneficial ownership confirmation. Regulatory requirement. Non-negotiable.
FATCA/CRS. The Foreign Account Tax Compliance Act and Common Reporting Standard are international tax evasion reporting frameworks. You collect the relevant information at onboarding and then report it annually - for every foreign LP, every year, indefinitely.
PFIC. If youâre considering US investors, stop and read about Passive Foreign Investment Company reporting before you say yes. It is a specific kind of complexity that is genuinely not fun to discover halfway through onboarding your first American LP. Plan for it at the fund design stage, not after the fact.
Wholesale Investor Qualification. You canât accept just anyone as an LP in Australia. You need wholesale investors - defined as:
- Anyone investing $500k+ (automatic qualification)
- Net assets of $2.5m+, or
- Annual income of $250k+ for the last two consecutive financial years
The thing most first-time GPs miss: foreign investors have to meet the wholesale investor equivalent in their home country, not just under Australian law. Every jurisdiction is different. Every one needs checking.
Once AML is verified, FATCA/CRS collected, investor status confirmed, and any foreign jurisdiction requirements satisfied - your LP signs the Subscription Agreement.
The document. The âI will commit $X to this fundâ moment.
đ Hallelujah.
Now you can deploy.
Well, not quite. đ
Every LP requires AML verification, FATCA/CRS collection, wholesale investor confirmation, and if theyâre foreign, jurisdiction-specific compliance on top.
Miss one and you canât accept their capital.
Reuben AI manages the full LP onboarding compliance stack: document collection, verification status tracking, and ongoing reporting obligations per LP.
So when a regulator asks, youâre ready.
See how it works â goreuben.com (code BATKO for 15% off)
đ Capital Calls: You Donât Have the Money Yet
An LP who committed $1m didnât hand you $1m in cash at signing.
They made a legal commitment to fund. When you need capital, you call it in tranches over the investment period. This is a capital call.
What a capital call covers:
The investment amount
Management fees for the period
Establishment fees - included in your very first capital call, which is when you recoup what you personally fronted
What good capital call management looks like:
Give LPs advance notice so they can plan their own cashflow
Be explicit on timing - when is the money due?
Track responses across every LP; some will be slow
Have a documented process for late payers - your Trust Deed should define the consequences
The first capital call is also the moment you stop personally bleeding for establishment costs and start running on fund economics.
Managing calls across 10 LPs is fine. Across 50+ LPs - many offshore, many with their own cashflow cycles, some slow - it becomes a real operational burden. Especially when your deal timeline doesnât care about any of it.
Capital calls require clean LP records, clear communication, and a way to track whoâs responded and who hasnât. Reuben AI manages the full capital call workflow: LP communication, commitment tracking, and cashflow projections so you always know where you stand before a deal closes.
Start for free â goreuben.com (code BATKO for 15% off)
đ The Reporting Treadmill
This is the one that surprises every first-time GP.
You expected to spend your time finding deals and helping founders. You did not expect to spend a meaningful chunk of your working life generating compliance reports.
Hereâs what the annual calendar actually looks like:
Quarterly:
TFN (Tax File Number) reporting
Net Asset Value (NAV) statements - institutional LPs often require delivery within 2 business days of quarter-end
Annually:
FATCA/CRS international reporting
US PFIC reporting (if you have US investors)
Trust tax return
AMMA statements (Attribution MIT Member Annual Statement) for every single LP
Annual fund audit
Thatâs a compliance event every quarter and a substantial project every financial year. Each deadline is real. Each one has consequences for missing it.
The NAV statements are where Iâve seen GPs get caught most often. Superfund LPs will contractually require delivery within a couple of business days of quarter-end. If your valuations arenât current, your accounting isnât clean, and your systems arenât built for speed - youâll be scrambling every three months, forever.
The honest reality: for small funds, this reporting workload is largely fixed cost. The time and money required is nearly identical whether youâre running $10m or $100m. Itâs the quiet operational tax on being an emerging manager. And it compounds year after year.
This is the main reason institutional-grade infrastructure matters from day one - not once youâve scaled to the point where you can afford it. From the first close.
The reporting workload is largely fixed cost, nearly identical whether youâre running $10m or $100m. That's the quiet operational tax on being an emerging manager.
Reuben AI automates the reporting layer: compliance calendars, NAV statement generation, FATCA/CRS, AMMA, and audit trails built in from day one.
The infrastructure that used to require a dedicated back-office, from fund one.
Get the reporting stack right from the start â goreuben.com (code BATKO for 15% off)
⥠Quick Reference: Part 3 Checklist
â Want the full checklist of every step across all three parts?
đ Final Words
Thatâs the full picture.
Three years of lessons, three posts.
Raising the Startmate Continuity Fund was one of the most complex, humbling, and genuinely fascinating things Iâve done. The regulatory architecture is deeper than it looks. The investor landscape is more opaque than youâd expect. The operational load is relentless.
And itâs absolutely worth it.
If youâre thinking about raising a fund - or youâre in the middle of one and recognising some of this - hit me up. Iâve been through most of it and Iâm happy to share what I know.
Questions in the comments.
Corrections welcome.
Things I missed - Iâd genuinely love to hear them.
đ¤
Three posts.
One consistent theme: the operational load on emerging managers is relentless, largely fixed cost, and hits from day one.
Reuben AI is built to absorb it. LP onboarding, capital calls, IC governance, and the full reporting stack, one platform, from fund one.
Use code BATKO for 15% off â goreuben.com
