AES is a multi-national financial services group focused upon the international, cross-border and increasingly global marketplace. The group consists of a number of separate companies broadly split into financial advisory, wealth management, custody and insurance services.
This page provides information on our regulation and authorisations, and information about Complaints and Redress (including details of statutory bodies in Europe and elsewhere providing a similar service to that of the Financial Ombudsman Service in respect of our business performed outside the UK, as well as that of the Financial Ombudsman Service itself in respect of such limited business as we carry out in the UK).
In short summary: UK law, regulation and redress processes apply in respect of our UK activities only. If you are outside the UK and we advise you or carry out other business, nearly all of the rules, regulations and arrangements made under the Financial Services Act 2000 for the protection of investors will not apply to most aspects of service you receive, such advice or business being provided from outside the UK.
You should therefore clearly understand such rights and protection as are afforded in the jurisdiction where you receive advice. Local law, regulation and redress processes will apply in almost all cases, and will be different from that of the UK. Set out below on this page are the regulating authorities and law in each jurisdiction where we operate, and (further down, under Complaints and Redress) the relevant protections/complaints/compensation arrangements.
We are required to provide information to tax authorities about our clients. For more information about this, please go to our International Reporting page.
Law and regulation applying to your advice and services.
Our regulatory straplines that are on formal documents provided to you (such as Terms of Business (“ToBs”) and advisory letters) set out clearly which AES entity you have terms of business with (and which therefore is providing you with advice and other services), and which law and regulation is relevant to the entity and the advice and services.
Such formal documents also thereby confirm that (i) you are not (unless separately stated) a client of another AES entity, (ii) no other AES entity is providing you with advice or services, and (iii) the advice you receive is not subject to law and regulation other than that on your formal documents. So, for example, no person is a client of AES Financial Services Ltd’s branch in the DIFC (see below) unless they have received formal documentation from AES DIFC with an AES DIFC regulatory strapline, including an onboarding letter.
UK regulation and authorisation
AES Financial Services Ltd (“AESFSL”), trading as AES International, is registered in England no. 06063185, its registered office being at 7 Bell Yard, London, WC2A 2JR. It is authorised and regulated in the UK by the Financial Conduct Authority (“FCA“) in respect of its UK activities. Its number on the Financial Services Register is 464494. AESFSL does not (other than exceptionally) provide financial advice either from its establishment in the UK, or from the UK under Freedom of Services legislation.
The Smart Account™ (formerly the Index Account™) is provided by AESFSL in accordance with its FCA authorisation. The Account provides a means for clients to save, and AESFSL does not provide any financial advice in relation to the Account.
Further Insurance Distribution Directive (IDD) disclosures
AESFSL acts as an insurance intermediary providing advice on insurance products and insurance wrapped investments. AESFSL is not restricted or contractually obliged to conduct insurance distribution exclusively for any insurer. AESFSL has no holding in any insurance undertaking and no insurance undertaking has any holding in AESFSL. AESFSL represents the client in every case, not the insurer. It looks at advising clients based on a fair and personal analysis of their circumstances. Other general IDD disclosures are set out either elsewhere on this website or in our Terms of Business. IDD disclosures required for individual clients are communicated individually, primarily in the context of advisory letters/reports.
UAE regulation and authorisation
UAE (Dubai – ‘onshore’)
AES Middle East Insurance Broker LLC is regulated by the Central Bank of the UAE following Decretal Federal Law No. (25) of 2020 that merged the UAE Insurance Authority, licence no. 189. The firm is also registered with the UAE Ministry of Economy, UAE, licence no. 571368, and Commercial Registration no. 75162, and also with the Dubai Health Authority. The office is at Level 2, Exchange Tower, Al Mustaqbal Street (Future Street), PO Box 191905, Dubai, United Arab Emirates. The authorities above regulate and authorise AES Middle East Insurance Broker LLC in respect of those activities it performs in / or from the UAE (not the DIFC – see below), and the law applicable to these activities is that of the federal UAE (not DIFC). AES Middle East Insurance Broker LLC does not use the trading name AES International.
All AES’ health/medical insurance and life assurance broking services in the Middle East are provided by AES Middle East Insurance Broker LLC alone.
UAE (DIFC – ‘offshore’)
AES Financial Services Ltd (AESFSL), trading as AES International, is registered with the Dubai International Financial Centre (DIFC) as a foreign registered company, licence no. 2128, and is regulated by the Dubai Financial Services Authority (DFSA). The registered office is Office S314, Level 3, Emirates Financial Towers – South Tower, DIFC, PO Box 191905, Dubai, United Arab Emirates. In respect of those activities AES FSL performs in or from the DIFC, the law applicable to these activities is that of the DIFC. For details of our employees approved by us to provide advice to clients of AES Financial Services Limited (DIFC Branch), please see here. Our authorisations may be confirmed here.
Historic business / authorisations
Europe (not Switzerland)
AESFSL had branches in Poland and Spain under European Freedom of Establishment legislation until 01 January 2021. In each of these Member State (“MS”) jurisdictions it was authorised and regulated by the relevant regulatory bodies in respect of those activities it carried out from its establishment in that jurisdiction (primarily financial advice to clients). In previous years, AESFSL has operated from other European Branch Establishments which closed prior to BREXIT. A list of these closed Branch Establishments is available on request. In all other MSs except Croatia, AESFSL had permission to operate under Freedom of Services legislation. Operating under Freedom of Establishment and/or Freedom of Services legislation is known colloquially as ‘passporting.’
European law applicable to a particular piece of advice was given under either: the Insurance Distribution Directive (the IDD – before 30 September 2018 the Insurance Mediation Directive (IMD)), the scope of which is (in broad terms) insurance-based products and investments within such products) or the Markets in Financial Instruments Directive (“MiFID”, the scope of which is (in broad terms) direct investments). In some jurisdictions, one authority may cover IDD matters and another authority covers MiFID matters. The language used for providing advice is English. The FCA website provides a list of all AES authorisations in Europe and the UK.
In this next section, we set out the regulating authorities for our former branches in Poland and Spain, where local law and regulation (not UK law and regulation) will apply. The authority named below regulated AESFSL’s branch in the jurisdiction named for the activities it performed in that jurisdiction. We also provide certain IDD disclosures.
AESFSL’s branch was located at Ul. Prosta 20, 00-850 Warsaw, Poland is registered with the Komisja Nadzoru Finansowego (KNF) and is authorised to give investment advice under the MiFID and undertake insurance mediation under the IDD (previously the IMD).
AESFSL’s branch was located at 8, Ctra Moraira Teulada 62, C C Barclays, 03724 Moraira, Alicante, Spain is registered with the Comisión Nacional del Mercado de Valores (CNMV), the registered number is 2075, and is authorised to give investment advice under the MiFID; it is also registered with the Dirección General de Seguros y Fondos de Pensiones (DGS) and is authorised to undertake insurance mediation activities under the IDD (previously the IMD).
International Pension Transfer Specialists (IPTS)
Under the trading name International Pension Transfer Specialists (and variants such as IPTS, IPTSpecialists), until Sunday 9 September 2018 AESFSL’s branch in Spain provided advice on pension transfers. This advice was provided under Spanish law. If you were advised on or before Sunday 9 September 2018, please see our section on Spain above.
Until the end of March 2018, AES International Financial Services WLL performed business in Qatar. The company was licensed with the Qatari Ministry of Economy and Commerce for the conduct of financial consulting activities: Commercial Registration No 56991, and the registered office was at Office G39, Regus Business Centre, Piazza Level, QQ05A, Qanat Quartier, The Pearl, PO Box 301588, Doha, Qatar. The QMEC regulated and authorised AES International Financial Services WLL in respect of those activities it performed in / or from the State of Qatar, and the law applicable to those activities was that of Qatar.
AES International SA was registered on the Registre du Commerce de Genève no. 20687/2011 and its Swiss federal number was CH/660-3510011-8. Its Registered Office was at AES International SA, 130, route de Saint-Julien 1228 Plan-les-Ouates, Geneva, Switzerland. It was a 100% subsidiary of AESFSL and a Member of L’Association Romande des Intermédiaires Financiers (ARIF), which regulates and authorises AES International SA in respect of those activities it performed in / or from Switzerland, and the applicable law is that of Switzerland.
ARIF is a self-regulating body approved by the Swiss Financial Market Supervisory Authority (FINMA) for the supervision of the financial intermediaries referred to in article 2 para. 3 of the Swiss Federal Law on combating money laundering and terrorism financing in the financial sector (AMLA). ARIF is also recognized by FINMA as a professional organization for laying down rules of conduct relating to the practice of the profession of independent asset manager within the meaning of the Swiss Federal Act on collective investment schemes.
AES Nominees Limited was s a non-trading company providing custody, dealing, and nominee services only. It was registered in England & Wales (no. 07127333), with its registered office at 7 Bell Yard, London, WC2A 2JR).
Complaints and redress
If you have become dissatisfied with our services, please see our Complaints and Redress Process for the first steps in what you should do in the first instance.
Law relevant to the matter complained of will be that of the jurisdiction in which the event complained of occurs. Complaints concerning matters performed carried out outside the UK (primarily advice and the process of such advice) are therefore matter for the local jurisdictional authority. Therefore, if the initial complaints process does not result in the complainant being satisfied, and the complainant wishes to take the matter further, the relevant regulatory authority is that of the jurisdiction in which the event complained of occurred. The relevant authorities are set out below. In the initial process of resolution, AES will inform a complainant that if they wish to take a matter further, then it is the local authority that will have jurisdiction.
In the UK, the next step if you wish to pursue the matter is the Financial Ombudsman Service. You can call them on: 0800 023 4567, 0300 123 9123 or from overseas +44 20 7964 0500, or email them at: complaint.info@ﬁnancial-ombudsman.org.uk, or use their online complaint form. You can also write to them at: The Financial Ombudsman Service, Exchange Tower, Harbour Exchange, London, E14 9SR.
Your investments may be covered by the FCSC up to their limits set from time to time (currently £50,000 for investments, £85,000 for deposits, per person per ﬁrm).
In Europe, relevant redress authorities are usually members of FIN-NET. On its website, FIN-NET summarises itself as a financial dispute resolution network of national out-of-court complaint schemes in the EEA (the EU Member States plus Iceland, Liechtenstein and Norway) responsible for handling disputes between consumers and financial services providers. The schemes cooperate to provide consumers with easy access to out-of-court complaint procedures in cross-border cases. If a consumer in one country has a dispute with a financial services provider from another country, FIN-NET members will put the consumer in touch with the relevant out-of-court complaint scheme and provide the necessary information about it.
Where advice has been given and received in one EEA country alone (for example under Freedom of Establishment legislation), FIN-NET has no application beyond confirming the relevant local jurisdictional authority. It does not, for example, permit a complainant about advice received in one MS under Freedom of Establishment legislation to bring a complaint to a jurisdictional authority in another.
The Financial Ombudsman Service has no territorial jurisdiction over any complaint that is not carried on from an AES establishment in the UK. AES advisory activities are generally not carried on from AES’s establishment in the UK, and the FOS will not have jurisdiction. In some (rare) cases, an activity carried on in European MSs will have been carried out from AES’s establishment in the UK under Freedom of Services legislation, and the FOS will have jurisdiction. The FOS’s contact details are above.
The following are the statutory authorities to hear complaints out of court in the following jurisdictions where AES has most recently had branches, if AES’ internal complaints process does not resolve matters.
Poland (former branch)
Rzecznik Ubezpieczonych (Insurance Ombudsman) (Website). Address: Biuro Rzecznika Ubezpieczonych, Al. Jerozolimskie 87, 02-001 Warszawa. Telephone: +48 22 333 37 328.
Spain (former branch)
IMD (insurance-product and pensions-related) matters: Dirección General de Seguros y Fondos de Pensiones (DGSFP) (Website). Address: Paseo de la Castellana, 44, 28046 Madrid. Telephone: +34 902 19 11 11.
MiFID (investment (not pensions)-product-related) matters: Comisión Nacional de Mercado de Valores (CNMV) (Website). Address: Edison, 4, 28006 Madrid. Telephone: +34 91 585 15 00.
Switzerland (former subsidiary)
Chambre Suisse de Médiation Commerciale (Website). Address : Chambre Suisse de Médiation Commerciale , Section Romande, 11bis, rue Rodolphe-Toepffer, CH-1206 Genève. Telephone: +41 22 789 50 20.
If your complaint relates to health insurance, and we cannot resolve it, please go to the Dubai Health Authority’s iPROMeS webpage at http://ipromes.eclaimlink.ae/.
Dubai (DIFC – ‘offshore’)
DFSA (Website). Address: Level 13, The Gate, PO Box 75850, Dubai, UAE. Fax: +971 (0) 4 362 0801.
Formal advice: written only
The formal record of our advice, the reasons for our advice, and factual background, is in writing only. Spoken discussions, whether at a distance or face-to-face, do not represent our formal advice, reasons, or background, and are not to be relied on by you or us.
This is so that there is a complete and comprehensive record and agreement between you and us, of what we have advised, the reasons, and context. Setting clear boundaries on what we have advised formally creates fairness for both you and us by.
Your signing a document confirms to us that you have read it and agree with it; likewise, your responding to an electronic communication from us confirms that you have read, understood, and agree with that electronic communication unless you write indicating otherwise. For these purposes generally, “writing” includes email and other non-spoken electronic communications.
It is therefore crucial that you read our written communications with care and in detail to ensure that they reflect accurately and in full what you and we have formally advised (and include any material matter from informal discussions to make it formal), the reasons, and context. This does not mean, though, that all our written communications are formal: many electronic communications do not represent formal advice, reasons or background. Whether a general electronic communication from us is intended to be formal should be clear from tone, style and context. Where a formal letter is provided (including in electronic format), this will generally over-ride any other electronic communication (in particular those sent before such letter) on the subject matter, unless such communications are plainly and clearly intended to override the formal letter.
Similarly, if you instruct us, your communications must be in writing, and clear and unambiguous as to meaning.
Website and financial promotions
This website is owned and all information, opinion and comment is issued by AES Financial Services Ltd, UK, unless otherwise stated. To the extent that any material on this website constitutes a financial promotion, such financial promotion is issued by AES Financial Services Ltd, UK.
AES Financial Services Ltd DIFC does not issue financial promotions through this website unless otherwise stated.
In respect of information provided on our pages about our Middle East medical/health insurance and life assurance broking services, such information is issued by AES Middle East Insurance Broker LLC.
Regulation means that we aim to maintain high standards in relation to both providing you with financial planning, and in administering your financial affairs thereafter. Not all the products and services we offer are regulated, and if you have any doubts, you must discuss this with your adviser.
Our website contains information on investments but you should not regard these as an offer to subscribe without reference to the relevant prospectus. Nothing on our site should be construed as investment advice. Some products and services may not be legally available to residents of certain countries and jurisdictions. If you are unsure as to whether an investment is suitable for you, please seek professional advice from us before proceeding.
The value of investments and the income from them can fall as well as rise and you may not receive back the original amount invested. Exchange rate movements between currencies may also affect the value of investments. Past performance is no guarantee of future performance.
Knowledge Tools and News/Blogs
The information contained in any Blog on this website (a “Blog“) is intended solely to provide general guidance on matters of interest for the personal use of the reader, who accepts full responsibility for its use. The application and effect of laws can vary widely depending on individual circumstances. Given the changing nature of laws, rules and regulations, and the potential risks of electronic communication, there may be delays, omissions or inaccuracies in information contained in a Blog. Accordingly, the information on any Blog is provided with the understanding that the authors and publishers are not thereby engaged in rendering financial, legal, accounting, tax, or other professional advice or services. As such, it must not be used as a substitute for consultation with professional financial, accounting, tax, legal or other competent advisers in relation to specific matters. Before making any decision or taking any action, you should consult a professional adviser.
While we have made every attempt to ensure that the information contained in any Blog has been obtained from reliable sources, AES International is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information in any Blog is provided “as is”, with no guarantee of completeness, accuracy, timeliness or of the results obtained from the use of such information, and without warranty of any kind, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose. Nothing shall to any extent substitute for the independent investigations and the sound technical and business judgment of the reader. In no event will AES International, or its partners, employees or agents, be liable to anyone for any decision made or action taken in reliance on the information in any Blog or for any consequential, special or similar damages, even if advised of the possibility of such damages.
The information in AES emails is confidential, and may be legally privileged. Each email intended solely for the addressee(s), and access by other persons is not intended. If you receive an AES email and are not the intended recipient of an AES email, please delete it unread. Any disclosure of an AES email or of the parties to it, or copying or distribution or any action taken or omitted to be taken on it may be unlawful. AES does not accept liability for any changes to an email after it has been sent.
Employees and independent contractors of AES are expressly required not to make defamatory statements or to infringe or authorise the infringement of copyright or other intellectual property rights. Any communication by an employee or independent contractor of AES that is defamatory or infringes another’s intellectual property rights is contrary to company policy and outwith the scope of the employment or the appointment of the person concerned. AES does not accept liability in respect of any such communication and the person sending any such communication is personally liable for any consequences, legal, or otherwise.
AES may monitor email traffic data and also the content of email for the purposes of security and staff training.
The CII’s trademark shown in the bottom right of our our homepage and status this implies is applicable only to AESFSL’s activity’s within the United Kingdom.
Disclosure (Pillar 3)
The FCA’s Prudential Sourcebook for Investment firms (IFPRU) requires certain disclosures to be made annually. These are made in AESFSL’s annual report and accounts.