your principal owner(s).
Small Enterprise Assistance Funds began in 1989 as a program of CARE with funding from the
United States Agency for International Development (USAID). In 1995, the CARE Small
Business Assistance Corporation spun out of CARE to become Small Enterprise Assistance
Funds, a 501(c)(3) not-for-profit organized under New York law. Since its launch Small
Enterprise Assistance Funds has created additional affiliates, the SEAF Advisers as defined
below, both in the United States and in other countries to help manage its investment entities
listed below.
As a New York non-for-profit corporation, SEAF has no shares or capital stock, and hence no
owners. It is controlled by the Board of Directors of the company.
The SEAF Advisers:
Small Enterprise Assistance Funds (501(c)(3) NY), SEAF Advisory Services BV (Netherlands,
Financial Services only), SEAF Caucasus Partners LTD (Cayman Islands), SEAF Caribbean
Management LLC (DE), SEAF Caucasus Management Ltd. (Cayman Islands), SEAF
Management LLC (Delaware), SEAF Management Colombia S.A.S. (Colombia), SEAF
Management Sichuan LLC (Delaware), SEAF Ventures Management LLC (Delaware), and
SEAF Ventures Management Ltd (Bangladesh), (collectively “SEAF” and individually a “SEAF
Adviser”), provide investment advisory services to its clients which include: (i) private investment
funds (the “Private Investment Funds”); and (ii) accounts, which may include entities structured
as permanent limited liability commercial finance companies or on-lending companies, but are
non-discretionary investment entities (the “Accounts”).
The Private Investment Funds include:
1. Fondo de Capital Privado Agroempresas Colombia de SEAF, a Colombian private equity
fund
2. SEAF Colombia Agribusiness Fund, a Delaware limited liability company
3. SEAF Bangladesh Ventures LLC, a Delaware limited liability company
4. SEAF Bangladesh Ventures LTD, a Bangladesh limited company
5. SEAF Caribbean SME Growth Investments Ltd, a St Lucia International Business
Company and Private Mutual Fund
6. SEAF Caribbean SME International LP, an Ontario limited partnership
7. SEAF Caucasus Growth Fund LP, a Cayman Islands limited life fund partnership
8. SEAF Caucasus Growth Fund BV, a Netherlands Besloten Vennootschap
9. SEAF Caucasus Growth Fund Coop, a Netherlands Cooperative
10. SEAF Macedonia II Fund LP, a Delaware limited partnership
11. SEAF Serbia Impact Fund BV, a Netherlands Besloten Vennootschap
12. SEAF Sichuan SME Investment Fund LLC, a Delaware limited liability company
13. SEAF South Balkan Fund B.V., a Netherlands limited partnership
14. SEAF Single Vintage Flex Fund, a Delaware limited liability company
15. Wise Venture Capital, S.A. a Moroccan limited company
The Accounts include:
EECP I, S.a.r.l., a Luxembourg private limited liability company which is now 100%-owned by
SEAF.
SEAF additionally administers several funds based on grants from government institutions, as well
as SEAF’s own funds.
The Grants include:
SEAF Tanzania (formerly Kasi Agriventures), a Tanzania company limited by guarantee funded
by the USDA.
SEAF Jordan Growth & Impact Fund, in a pre-first close creation phase, funded by the Government
of Canada
Daraja Impact Foundation, a loan and grant foundation funded by the Government of Switzerland
SEAF further administers a number of lending facilities, sponsored by different government
entities. As lending facilities, they do not receive investment advisory services and are not included
on SEAF’s ADV.
The Loan Facilities include:
SEAF Covid-19 Global Gender Lends Emergency Loan Finance LLC (US Development Finance
Corporation)
SEAF Tunisia Resilience Fund (INVEST through a grant from USAID)
SEAF Caribbean Loan Finance LLC (Inter-American Investment Corporation)
The Private Funds, Accounts, Grants and Loan Facilities are all treated with fiduciary care and
generally as “Advisory Clients,” though each may have its unique requirements, and not all are
“Advisory Clients” for ADV Part 1 reporting purposes. Each SEAF Adviser is principally owned
by Small Enterprise Assistance Funds which is a New York not-for-profit corporation with
headquarters in Washington, DC that is tax-exempt under Section 501(c)(3) of the Internal
Revenue Code.
Several of the Advisory Clients have an Advisory Committee or Council which depending on the
Advisory Client consists of a combination of or solely of SEAF appointees, investor appointees,
and/or independent parties. However, as of 2016, the Global Investment Committee, or a portion
thereof, must approve each investment made by the Advisory Clients and shall be responsible,
together with each SEAF Adviser, for the implementation of the investment objectives and policies
thereof. Since 2020, the Global Credit Committee must approve each loan or similar instrument
made by an Advisory Client and shall be responsible, together with each SEAF Adviser, for the
implementation of the lending objectives and policies thereof.
In addition, several of the Advisory Clients have a Board of Directors which meet to discuss and
vote on more high-level decisions and policies of its respective Advisory Client.
It should be noted that SEAF may create entities solely for accepting fees/grant proceeds, etc. in
jurisdictions where this may be needed for various tax and legal reasons. It may be that no advisory
services or investment advice is conducted with these various entities.
specializing in a particular type of advisory service, such as financial planning, quantitative
analysis, or market timing, explain the nature of that service in greater detail. If you provide
investment advice only with respect to limited types of investments, explain the type of
investment advice you offer, and disclose that your advice is limited to those types of
investments.
SEAF provides investment advisory services to pooled investment vehicles operating as private
investment funds and accounts which may include entities structured as permanent limited
liability commercial finance companies or on-lending companies. For purposes of this ADV,
these may be entities referred to as the SEAF Advisory Clients.
The SEAF Advisory Clients
generally invest in and lend to privately-held small and medium-
sized enterprises (SMEs) outside the United States in emerging and frontier markets. SEAF
provides equity and debt growth capital and business assistance to SMEs in markets underserved
by traditional sources of capital. SEAF seeks to achieve long-term capital growth by making
direct equity, equity-related, debt and participatory debt investments in each individual portfolio
company in which it invests. SEAF seeks to enhance the business performance of its investments
by actively assisting its portfolio companies in implementing appropriate improvements in
management techniques and practices, especially relating to financial control, cost accounting,
quality control, and marketing. In addition, the investment officers chosen to work with the
portfolio company will be actively engaged in implementing business strategy and in following
- up advice rendered by outside experts.
As well, SEAF invests with the objective of realizing a positive and measurable developmental
impact resulting from its partnerships with SMEs. Through its experience, SEAF has found that
fostering profitable, competitive local enterprises generates significant environmental, social and
governance benefits for local communities.
Although SEAF’s investment advice is generally limited to these types of investments, it has
broad and flexible investment authority (in conjunction with approval from the relevant
Investment Committee) with respect to the Private Investment Funds. Each Private Investment
Fund’s structure, investment objective and strategy are set forth in a confidential private offering
memorandum or other governing documents provided to each investor in the relevant Private
Investment Fund.
The Accounts’ investment objectives and the types of investments that such portfolios will hold
are individually negotiated and established between SEAF and the Account. In four of the eight
Accounts, SEAF does not have full investment decision making authority.
needs of clients. Explain whether clients may impose restrictions on investing in certain
securities or types of securities.
Although SEAF does not allow restrictions to be imposed on investor-by-investor level for the
Private Investment Funds, investors have mandated restrictions that have been adopted at the
fund level and may allow an investor to opt out of a fund investment. In the case of the Accounts,
SEAF has: (i) tailored the investment objectives to the specific objectives/restrictions of the
Account; and/or (ii) individually negotiated the terms and fees for each Account, which are
different to the terms and fees than those of the Private Investment Funds. It should also be noted
that any Account relationships are generally subject to significant account minimums.
SEAF may, in its sole discretion, offer to one or more investors (including, without limitation,
strategic investors and unaffiliated financial investors), the opportunity to co-invest with certain
of the Private Investment Funds in certain transactions.
It should be noted that SEAF has and may enter into separate agreements with certain investors
allowing such investors to invest on different terms than those described in the respective Private
Investment Fund’s offering memorandum or other governing documents, including without
limitation, with respect to fees or liquidity provided to such investors. In addition, SEAF may
offer certain investors additional or different information and reporting than that offered to other
investors.
(1) describe the differences, if any, between how you manage wrap fee accounts and how you
manage other accounts, and (2) explain that you receive a portion of the wrap fee for your
services.
SEAF does not participate in wrap fee programs.
discretionary basis and the amount of client assets you manage on a non-discretionary basis.
Disclose the date “as of” which you calculated the amounts.
As of December 31, 2023, SEAF Caucasus Partners LTD manages $20,257,105 of Advisory
Client assets on a discretionary basis including undrawn capital commitments. SEAF Caucasus
Partners LTD does not currently manage any assets on a non-discretionary basis.
As of December 31, 2023, SEAF Caucasus Management LTD manages $8,862 of Advisory
Client assets on a discretionary basis including undrawn capital commitments. SEAF Caucasus
Management LTD does not currently manage any assets on a non-discretionary basis.
As of December 31, 2023, SEAF Management Colombia S.A.S. manages $2,783,694 of
Advisory Client assets on a discretionary basis including undrawn capital commitments. SEAF
Management Colombia S.A.S. does not currently manage any assets on a non-discretionary
basis.
As of December 31, 2023, SEAF Management LLC manages $5,923,990 of Advisory Client
assets on a discretionary basis including undrawn capital commitments. SEAF Management
LLC does not currently manage any assets on a non-discretionary basis.
As of December 31, 2023, SEAF Management Sichuan LLC manages $174 of Advisory Client
assets on a discretionary basis including undrawn capital commitments. SEAF Management
Sichuan LLC does not currently manage any assets on a non-discretionary basis.
As of December 31, 2023, SEAF Ventures Management LLC manages $10,334,641 of Advisory
Client assets on a discretionary basis including undrawn capital commitments. SEAF Ventures
Management LLC does not currently manage any assets on a non-discretionary basis.
As of December 31, 2023, SEAF Ventures Management Ltd manages $3,963,721 of Advisory
Client assets on a discretionary basis including undrawn capital commitments. SEAF Ventures
Management LLC does not currently manage any assets on a non-discretionary basis.
As of December 31, 2023, SEAF Caribbean Management LLC manages $58,637,117 of
Advisory Client assets on a discretionary basis including undrawn capital commitments. SEAF
Caribbean Management LLC does not currently manage any assets on a non-discretionary basis.
As of December 31, 2023, SEAF manages $18,046,658 of Advisory Client assets on a
discretionary basis including undrawn capital commitments. SEAF does not currently manage
any assets on a non-discretionary basis.