# Amberlake Partners SAM

> Amberlake Partners SAM is an SEC-registered investment advisory firm in Monaco, Monaco, registered since 2023, reporting $25 million to $100 million in regulatory assets under management in its Form ADV filing dated March 19, 2026.

- CRD: 322274
- Filed as: AMBERLAKE PARTNERS SAM
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Monaco, Monaco
- Filing period: October 2026
- Form ADV filing dated: March 19, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/322274
- AdvisorCensus page: https://advisorcensus.com/firm/amberlake-partners-sam-monaco-322274

## Quick answers

**How is Amberlake Partners SAM compensated?**
On its Form ADV (Item 5.E, October 2026), Amberlake Partners SAM reports these compensation arrangements: a percentage of assets under its management; commissions.

**How much does Amberlake Partners SAM charge?**
Its Form ADV Part 2A brochure dated March 19, 2026 states: Asset-based fee: 1% to 3% a year (a range, as the brochure states it). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Amberlake Partners SAM located?**
Amberlake Partners SAM's principal office is in Monaco, Monaco, according to its Form ADV.

**Is Amberlake Partners SAM registered with the SEC or a state?**
Amberlake Partners SAM is an SEC-registered investment advisory firm, registered since 2023. Status as filed: Approved. CRD 322274.

**How much does Amberlake Partners SAM manage?**
Amberlake Partners SAM reports $97,121,000 in regulatory assets under management in its Form ADV filing dated March 19, 2026 (0% discretionary).

**How have Amberlake Partners SAM's assets and staff changed since 2023?**
In the Form ADV data for Amberlake Partners SAM: Regulatory assets under management: $23,000,000 in the October 2023 data and $97,121,000 in the October 2026 data, up 322%. Total employees: 4 in October 2023 and 7 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Amberlake Partners SAM serve?**
By number of clients on Form ADV Item 5.D: high net worth individuals (9); corporations or other businesses not listed above (3); insurance companies (2).

**Which custodians does Amberlake Partners SAM use?**
Amberlake Partners SAM's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists CMB Monaco, Julius Baer Monaco and Societe Generale Monaco as custodians holding 10% or more of its separately managed account assets.

**Does Amberlake Partners SAM report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/322274

**What changed in Amberlake Partners SAM's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 3 to 4. Regulatory assets under management went from $57,200,000 to $97,121,000 (+70%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Commissions

### Fees and minimums (Form ADV Part 2A brochure dated March 19, 2026)

- Asset-based fee: 1% to 3% a year (a range, as the brochure states it)

> Typically, depending on the complexity of the portfolio , the Firm charges between 1.00% and 3.00% per annum.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- CMB Monaco
- Julius Baer Monaco
- Societe Generale Monaco

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $97,121,000
- Discretionary: $0
- Non-discretionary: $97,121,000

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| High net worth individuals | 9 | $33,875,000 |
| Insurance companies | 2 | $45,150,000 |
| Corporations or other businesses not listed above | 3 | $18,096,000 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Selection of other advisers (including private fund managers)
- Publication of periodicals or newsletters

### Firm details
- Registered since: 2023 (3 years)
- Employees: 7 total, 4 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- amberlakepartners.com
- LinkedIn @amberlakepartners

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2023 | $23,000,000 | 4 | May 17, 2023 |
| October 2024 | $29,000,000 | 5 | June 4, 2024 |
| October 2025 | $57,200,000 | 6 | March 18, 2025 |
| October 2026 | $97,121,000 | 7 | March 19, 2026 |

Regulatory assets under management: $23,000,000 in the October 2023 data and $97,121,000 in the October 2026 data, up 322%.
Total employees: 4 in October 2023 and 7 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 3 to 4.
- Regulatory assets under management went from $57,200,000 to $97,121,000 (+70%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Amberlake Partners SAM (CRD 322274): Form ADV filing data as of October 2026.