Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Apex Investments Management, S.A.
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Apex Investments Management, S.A..
Reported ownership and control details
Form ADV · Filing date 2026-09-11 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | PEDRO A PALMAMANAGING PARTNERIndividual | APEX INVESTMENTS MANAGEMENT, S.A. | Less than 5%Code NA | Yes | MANAGING PARTNER03/2022 | Schedule APDF page 28 |
| 2 | APEX CAPITAL ASSETS, S.A.SHAREHOLDERForeign entity | APEX INVESTMENTS MANAGEMENT, S.A. | 75% or moreCode E | Yes | SHAREHOLDER03/2022 | Schedule APDF page 28 |
| 3 | JOSE GUILLERMO MATAMANAGING DIRECTORIndividual | APEX INVESTMENTS MANAGEMENT, S.A. | Less than 5%Code NA | Yes | MANAGING DIRECTOR03/2022 | Schedule APDF page 28 |
| 4 | ANDRES CHAVEZVICE PRESIDENTIndividual | APEX INVESTMENTS MANAGEMENT, S.A. | Less than 5%Code NA | Yes | VICE PRESIDENT10/2022 | Schedule APDF page 28 |
| 5 | CARLOS ENRIQUE MATAINVESTMENT COMMITTEE MEMBERIndividual | APEX INVESTMENTS MANAGEMENT, S.A. | Less than 5%Code NA | Yes | INVESTMENT COMMITTEE MEMBER03/2022 | Schedule APDF page 28 |
| 6 | JUAN PABLO MATAINVESTMENT COMMITTEE MEMBERIndividual | APEX INVESTMENTS MANAGEMENT, S.A. | Less than 5%Code NA | Yes | INVESTMENT COMMITTEE MEMBER03/2022 | Schedule APDF page 28 |
| 7 | GUILLERMO LEON GAVIRIAINVESTMENT COMMITTEE MEMBERIndividual | APEX INVESTMENTS MANAGEMENT, S.A. | Less than 5%Code NA | Yes | INVESTMENT COMMITTEE MEMBER09/2022 | Schedule APDF page 28 |
| 8 | CARLOS ENRIQUE CASTILLOINVESTMENT COMMITTEE MEMBERIndividual | APEX INVESTMENTS MANAGEMENT, S.A. | Less than 5%Code NA | Yes | INVESTMENT COMMITTEE MEMBER01/2026 | Schedule APDF page 28 |
| 9 | CRISTOBAL FERNANDEZ ABASCALCHIEF COMPLIANCE OFFICERIndividual | APEX INVESTMENTS MANAGEMENT, S.A. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER09/2026 | Schedule APDF page 28 |
| 10 | EMSA HOLDINGS CORPSHAREHOLDERForeign entity | APEX CAPITAL ASSETS, S.A. | 75% or moreCode E | Yes | SHAREHOLDER05/2022 | Schedule BPDF page 28 |
| 11 | GRUPO EMPRESARIALMARIPOSA CORP.SHAREHOLDERForeign entity | EMSA HOLDINGS CORP | 75% or moreCode E | Yes | SHAREHOLDER05/2022 | Schedule BPDF page 28 |
| 12 | WINDSOR BUSINESS LTD.SHAREHOLDERForeign entity | GRUPO EMPRESARIALMARIPOSA CORP. | 75% or moreCode E | Yes | SHAREHOLDER05/2022 | Schedule BPDF page 28 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 9/11/2026 11:24:19 AM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions5 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.