# Sengu Capital Limited

> Sengu Capital Limited is an SEC-registered investment advisory firm in Hong Kong, Hong Kong, registered since 2024, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated April 8, 2026.

- CRD: 333451
- Filed as: SENGU CAPITAL LIMITED
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Hong Kong, Hong Kong
- Filing period: October 2026
- Form ADV filing dated: April 8, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/333451
- AdvisorCensus page: https://advisorcensus.com/firm/sengu-capital-limited-hong-kong-333451

## Quick answers

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

**How much does Sengu Capital Limited charge?**
Its Form ADV Part 2A brochure dated March 24, 2026 states: Asset-based fee: 1.25% to 1.5% 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 Sengu Capital Limited located?**
Sengu Capital Limited's principal office is in Hong Kong, Hong Kong, according to its Form ADV.

**Is Sengu Capital Limited registered with the SEC or a state?**
Sengu Capital Limited is an SEC-registered investment advisory firm, registered since 2024. Status as filed: Approved. CRD 333451.

**How much does Sengu Capital Limited manage?**
Sengu Capital Limited reports $859,097,343 in regulatory assets under management in its Form ADV filing dated April 8, 2026 (100% discretionary).

**How have Sengu Capital Limited's assets and staff changed since 2025?**
In the Form ADV data for Sengu Capital Limited: Regulatory assets under management: $153,410,000 in the October 2025 data and $859,097,343 in the October 2026 data, up 460%. Total employees: 6 in October 2025 and 6 in October 2026. Assets under management move with markets as well as with clients coming and going.

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

**Which custodians does Sengu Capital Limited use?**
Sengu Capital Limited's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Barclays, GS, J.P. Morgan Securities LLC and Morgan Stanley & Co. LLC as custodians holding 10% or more of its separately managed account assets.

**Does Sengu Capital Limited 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/333451

**What changed in Sengu Capital Limited's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $153,410,000 to $859,097,343 (+460%).

## 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 24, 2026)

- Asset-based fee: 1.25% to 1.5% a year (a range, as the brochure states it)

> The Firm receives a management fee ranging from 1.25% - 1.50% of the net asset value (“NAV”) of the Funds (“Management Fee”) monthly in arrears.

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

### Custodians (Schedule D, Section 5.K(3))
- Barclays
- GS
- J.P. Morgan Securities LLC
- Morgan Stanley & Co. LLC

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: $859,097,343
- Discretionary: $859,097,343
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 1 | $422,535,642 |
| Other | 6 | $436,561,701 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)

### Firm details
- Registered since: 2024 (1 year)
- Employees: 6 total, 2 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)
- sengu-capital.com

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2025 | $153,410,000 | 6 | March 26, 2025 |
| October 2026 | $859,097,343 | 6 | April 8, 2026 |

Regulatory assets under management: $153,410,000 in the October 2025 data and $859,097,343 in the October 2026 data, up 460%.
Total employees: 6 in October 2025 and 6 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $153,410,000 to $859,097,343 (+460%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Sengu Capital Limited (CRD 333451): Form ADV filing data as of October 2026.