# Stenham Asset Management Limited

> Stenham Asset Management Limited is an SEC-registered investment advisory firm in St. Peter Port, Guernsey, registered since 2012, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated June 30, 2026.

- CRD: 164382
- Filed as: STENHAM ASSET MANAGEMENT LIMITED
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: St. Peter Port, Guernsey
- Filing period: October 2026
- Form ADV filing dated: June 30, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/164382
- AdvisorCensus page: https://advisorcensus.com/firm/stenham-asset-management-limited-st-peter-port-164382

## Quick answers

**How is Stenham Asset Management Limited compensated?**
On its Form ADV (Item 5.E, October 2026), Stenham Asset Management Limited reports these compensation arrangements: a percentage of assets under its management; performance-based fees. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Stenham Asset Management Limited located?**
Stenham Asset Management Limited's principal office is in St. Peter Port, Guernsey, according to its Form ADV.

**Is Stenham Asset Management Limited registered with the SEC or a state?**
Stenham Asset Management Limited is an SEC-registered investment advisory firm, registered since 2012. Status as filed: Approved. CRD 164382.

**How much does Stenham Asset Management Limited manage?**
Stenham Asset Management Limited reports $3,956,403,604 in regulatory assets under management in its Form ADV filing dated June 30, 2026 (95% discretionary).

**How have Stenham Asset Management Limited's assets and staff changed since 2021?**
In the Form ADV data for Stenham Asset Management Limited: Regulatory assets under management: $2,519,000,000 in the October 2021 data and $3,956,403,604 in the October 2026 data, up 57%. Total employees: 8 in October 2021 and 14 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Stenham Asset Management Limited serve?**
By number of clients on Form ADV Item 5.D: other (146); pooled investment vehicles (other than investment companies and business development companies) (7); pension and profit sharing plans (but not the plan participants or government pension plans) (2).

**Which custodians does Stenham Asset Management Limited use?**
Stenham Asset Management Limited's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists JP Morgan and Northern Trust as custodians holding 10% or more of its separately managed account assets.

**Does Stenham Asset Management 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/164382

**What changed in Stenham Asset Management Limited's recent Form ADV filings?**
In the July 2026 filing data: Regulatory assets under management went from $3,383,707,000 to $3,956,403,604 (+17%). 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

### Custodians (Schedule D, Section 5.K(3))
- JP Morgan
- Northern Trust

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: $3,956,403,604
- Discretionary: $3,755,843,085
- Non-discretionary: $200,560,519

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Investment companies | 1 | $722,000 |
| Pooled investment vehicles (other than investment companies and business development companies) | 7 | $2,654,941,000 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 2 | $434,762,000 |
| State or municipal government entities (including government pension plans) | 2 | $15,943,500 |
| Other | 146 | $850,035,104 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 2012 (14 years)
- Employees: 14 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)
- stenhamassetmanagement.com
- LinkedIn @STENHAM-ASSET-MANAGEMENT

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $2,519,000,000 | 8 | June 29, 2021 |
| October 2022 | $2,609,000,000 | 9 | June 28, 2022 |
| October 2023 | $2,784,000,000 | 11 | June 29, 2023 |
| October 2024 | $2,936,600,000 | 11 | August 14, 2024 |
| October 2025 | $3,383,707,000 | 11 | June 30, 2025 |
| October 2026 | $3,956,403,604 | 14 | June 30, 2026 |

Regulatory assets under management: $2,519,000,000 in the October 2021 data and $3,956,403,604 in the October 2026 data, up 57%.
Total employees: 8 in October 2021 and 14 in October 2026.

## Changes in the filing (last 12 months)

### July 2026
- Regulatory assets under management went from $3,383,707,000 to $3,956,403,604 (+17%).
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Stenham Asset Management Limited (CRD 164382): Form ADV filing data as of October 2026.