# Holowesko Partners Ltd.

> Holowesko Partners Ltd. is an SEC-registered investment advisory firm in Nassau, Bahamas, The, registered since 2010, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated March 20, 2026.

- CRD: 155703
- Filed as: HOLOWESKO PARTNERS LTD.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Nassau, Bahamas, The
- Filing period: October 2026
- Form ADV filing dated: March 20, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/155703
- AdvisorCensus page: https://advisorcensus.com/firm/holowesko-partners-ltd-nassau-155703

## Quick answers

**How is Holowesko Partners Ltd. compensated?**
On its Form ADV (Item 5.E, October 2026), Holowesko Partners Ltd. reports these compensation arrangements: a percentage of assets under its management; performance-based fees.

**Where is Holowesko Partners Ltd. located?**
Holowesko Partners Ltd.'s principal office is in Nassau, Bahamas, The, according to its Form ADV.

**Is Holowesko Partners Ltd. registered with the SEC or a state?**
Holowesko Partners Ltd. is an SEC-registered investment advisory firm, registered since 2010. Status as filed: Approved. CRD 155703.

**How much does Holowesko Partners Ltd. manage?**
Holowesko Partners Ltd. reports $904,135,042 in regulatory assets under management in its Form ADV filing dated March 20, 2026 (100% discretionary).

**How have Holowesko Partners Ltd.'s assets and staff changed since 2021?**
In the Form ADV data for Holowesko Partners Ltd.: Regulatory assets under management: $1,117,125,226 in the October 2021 data and $904,135,042 in the October 2026 data, down 19%. Total employees: 15 in October 2021 and 13 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Holowesko Partners Ltd. serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (6); charitable organizations (1).

**Which custodians does Holowesko Partners Ltd. use?**
Holowesko Partners Ltd.'s most recent Form ADV filing (Schedule D, Section 5.K(3)) lists State Street Bank and Trust Company as a custodian holding 10% or more of its separately managed account assets.

**Does Holowesko Partners Ltd. 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/155703

**Does Holowesko Partners Ltd. state an account minimum?**
Its Form ADV Part 2A brochure dated March 20, 2026 says: "The minimum initial investment by an investor in a private fund client is $3,000,000, however, HPL in its sole discretion may waive this minimum amount."

**What changed in Holowesko Partners Ltd.'s recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 12 to 13. Regulatory assets under management went from $779,283,463 to $904,135,042 (+16%). Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

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

### Fees and minimums (Form ADV Part 2A brochure dated March 20, 2026)

- Account minimum: $3,000,000 (the brochure says it may be waived or negotiated)

> The minimum initial investment by an investor in a private fund client is $3,000,000, however, HPL in its sole discretion may waive this minimum amount.

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

### Custodians (Schedule D, Section 5.K(3))
- State Street Bank and Trust Company

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: $904,135,042
- Discretionary: $904,135,042
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 6 | $685,327,874 |
| Charitable organizations | 1 | $218,807,168 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients

### Firm details
- Registered since: 2010 (15 years)
- Employees: 13 total, 13 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)
- holoweskopartners.com

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $1,117,125,226 | 15 | March 17, 2021 |
| October 2022 | $826,638,767 | 15 | March 24, 2022 |
| October 2023 | $709,107,334 | 15 | March 28, 2023 |
| October 2024 | $783,207,105 | 13 | March 15, 2024 |
| October 2025 | $779,283,463 | 12 | March 26, 2025 |
| October 2026 | $904,135,042 | 13 | March 20, 2026 |

Regulatory assets under management: $1,117,125,226 in the October 2021 data and $904,135,042 in the October 2026 data, down 19%.
Total employees: 15 in October 2021 and 13 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 12 to 13.
- Regulatory assets under management went from $779,283,463 to $904,135,042 (+16%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Holowesko Partners Ltd. (CRD 155703): Form ADV filing data as of October 2026.