Talabot Investments LLP in March 2021 acquired “a qualifying holding in a credit institution governed by Luxembourg law without obtaining prior authorisation from the European Central Bank,” said a 5 April 2024 press release from the financial regulator CSSF, explaining a fine imposed on Talabot Investments LLP. Archive photo: Romain Gamba/Maison Moderne

Talabot Investments LLP in March 2021 acquired “a qualifying holding in a credit institution governed by Luxembourg law without obtaining prior authorisation from the European Central Bank,” said a 5 April 2024 press release from the financial regulator CSSF, explaining a fine imposed on Talabot Investments LLP. Archive photo: Romain Gamba/Maison Moderne

Luxembourg’s Financial Sector Supervisory Commission has imposed an administrative fine of €97,500 on Talabot Investments LLP for “non-compliance with professional obligations related to prior notification of a qualifying holding in a credit institution.”

The Financial Sector Supervisory Commission (CSSF) announced in a that it had imposed an administrative penalty on the London-headquartered entity Talabot Investments LLP. The fine, imposed on 19 February 2024, is for non-compliance with the notification requirements of a law concerning access to the activity of credit institutions and the prudential supervision of credit institutions.

Talabot Investments LLP in March 2021 acquired “a qualifying holding in a credit institution governed by Luxembourg law without obtaining prior authorisation from the European Central Bank,” said the CSSF’s press release. “The administrative fine is imposed on the acquiring entity; the administrative breaches here observed do not interfere with the banking activities performed by the credit institution.”

Details of the March 2021 acquisition

Talabot Investments LLP’s annual report for the financial year ending 31 March 2021,  website (business register), stated that: “On 31 March 2021, Talabot Investments LLP purchased 100% of the share capital of Talabot Finance Ltd, 34% of the share capital of LinkedTrade Holding Ltd, 34% of the share capital of LinkedTrade Technology ltd, 13.67% of the share capital of BalRe Technologies Ltd, 20% Adon Capital Ltd and 67.388% of the share capital of RRBF Sarl from RiverRock European Capital Partners LLP, a limited liability partnership incorporated in the UK who share the same ultimate business owners.”

Which brings us to the question: what is the credit institution in which Talabot Investments LLP acquired a qualifying holding?

RRBF and Riverbank

In its annual report for the financial year ending 31 March 2022, Talabot Investments LLP wrote: “Riverbank SA is a 15.45% owned investment of the group, with the principal activity of a bank incorporated in Luxembourg, authorised by the ECB and the CSSF (Lux). Riverbank is a fintech company leveraging technology for loan origination, credit analysis and liability financing.”

Riverbank, which has its offices at 5 Boulevard Royal in Luxembourg City and was established in 2015, noted in its 2022 annual report and filed with the Luxembourg Business Registers, that “during the year 2018, RRBF S.à r.l. purchased 299,421 class C shares that were subsequently converted into B shares.”

RRBF is a soparfi (holding vehicle) that was established in 2015 and has its registered office at 5 Boulevard Royal. According to its 2022 annual report, it has 23.05% ownership of Riverbank.

Therefore, if Talabot Investments LLP purchased share capital in RRBF in 2021, that would give Talabot Investments LLP a holding in a credit institution governed by Luxembourg law.

Delano has asked Riverbank for comment.

Delano was unable to find an active email address, phone number or social media account to ask Talabot Investments LLP for comment.