By Jonathan Laws, ACA, Ch.FCSI, Senior Adviser at Cameron James USA.
If you have landed here looking for a way to self-invest in a Novia Global SIPP, or to run one on a self-directed, execution-only basis without an ongoing adviser, it is worth knowing the answer up front. The Novia Global platform does not offer that. It is an adviser-led platform by design, and the Novia Global terms require a formal adviser relationship in order to open and operate an account.
That does not make the SIPP a poor choice. It is a well-regulated, UK-registered pension wrapper, and the multi-currency capability makes it a genuinely useful planning tool for expats and other internationally mobile clients. What it means is that the real decision is not whether you can go fully do-it-yourself here, because you cannot. The real decision is whether the adviser attached to your SIPP is actually doing the ongoing work you are paying for. For expats who are US persons in particular, that question sits directly on top of SEC fiduciary duty, which does not stop at the point an account is opened.
Key takeaways
- If you are looking for a way to self-invest, or to run a Novia Global SIPP without an adviser, the short answer is that the platform does not offer it. The platform is adviser-led by design.
- The Novia Global Terms and Conditions require a formal adviser relationship before an account can be opened or dealt with, and dealing instructions are placed through that adviser.
- For expats who are US persons, the fiduciary duty owed by an SEC-registered investment adviser representative is ongoing. It does not end once the account is opened.
- An advisory fee charged against a SIPP where the underlying investments are not being actively reviewed and managed is a mismatch with both the platform terms and the fiduciary obligations of the adviser.
- For SEC-registered advisers, the services delivered also have to match what the firm discloses in Form ADV. Charging an advisory fee for what is in substance a no-advice service can be materially different from a disclosed advice-only model.
- The practical question is not whether you can go fully self-directed here, because you cannot. It is whether the adviser attached to your SIPP is actually delivering the ongoing service you are paying for.
Is the adviser on your SIPP actually doing the work?
If you cannot recall your last documented SIPP review, we will look at it. Fee-based, no commission, individual SEC authorization.
Why You Cannot Self-Invest in a Novia Global SIPP
The Novia Global Terms and Conditions state that a client must have an adviser in order to deal with the platform, and that only one adviser may sit on an account at any one time. Buy, sell, and switch instructions are given through the intermediary of the client rather than placed directly by the client acting alone. The Novia Global Key Features document is equally direct: the adviser instructs Novia Global on your behalf. This is why searches for a self-directed or execution-only Novia Global SIPP do not lead anywhere. The route does not exist on this platform.
That surprises a lot of expats, because the platform was built for them. It is one of the few UK pension structures designed from the outset for people who no longer live in the UK. Being designed for expats, however, is not the same as being open to expats on any terms they choose.
This is not a minor administrative detail. It defines what the product is. A Novia Global SIPP where an adviser is nominally attached to the account, but is not actually directing, reviewing, or taking responsibility for the investment strategy, is being operated outside the basis on which the platform, and the regulatory permissions held by the adviser, were granted.
The platform position in one line
Novia Global Limited is authorized and regulated by the Financial Conduct Authority under Firm Reference Number 653661, and the SIPP is open to non-UK residents where regulated advice is in place. Eligibility is not the same as suitability, and neither of them is the same as self-direction.
Why Ongoing Adviser Involvement Is Not Optional
Under SEC fiduciary duty
For expats who are US persons, an investment adviser representative operating under SEC authorization owes a fiduciary duty under the Investment Advisers Act of 1940. That duty is continuous. In the Commission Interpretation Regarding Standard of Conduct for Investment Advisers, the SEC set out that the duty of care includes providing advice and monitoring at a frequency that is in the best interest of the client, taking account of the scope of the agreed relationship. Where an adviser has an ongoing relationship and is compensated by a periodic asset-based fee, the SEC states that the duty to provide advice and monitoring will be relatively extensive.
That is the sentence that matters here. The scope of the duty tracks the fee. An ongoing advisory fee charged against a SIPP implies an ongoing advisory relationship, and an ongoing advisory relationship carries a continuing obligation to monitor and to advise.
Charging an ongoing advisory fee against a SIPP while the underlying holdings are set once and then left to run, especially by the client, with no documented periodic review, no rebalancing rationale, and no evidence of active oversight, does not meet that standard. The client is paying for advice. The fiduciary duty attaches to the relationship for as long as the fee continues to be charged, not only at the point of initial placement.
What genuine adviser-basis management looks like
- A documented initial suitability assessment specific to the circumstances of the client, and not simply the output of a generic risk questionnaire.
- Periodic, evidenced portfolio reviews at a defined cadence, with a recorded rationale for holding, rebalancing, or switching.
- An adviser who can be contacted, who knows the file, and who takes responsibility for the investment decisions taken inside the SIPP.
- Clear disclosure of what the advisory fee pays for, and how often that service is actually delivered.
Disclosed services and delivered services have to match
There is a further layer to this for SEC-registered advisers specifically. A registered firm must describe its advisory business in Form ADV, including the types of advisory services offered, how those services are delivered, and the fees charged for them. As the SEC investor bulletin on Form ADV sets out, that disclosure has to be accurate and it must not be misleading, and the firm is expected to deliver services consistent with what it has disclosed and with the advisory agreement signed by the client.
This is where a self-invest arrangement can create a problem that goes beyond any single client file. Where the Form ADV of a firm describes advised or discretionary portfolio management, and the fee schedule is built around that, then providing what is in substance a self-directed, no-advice service while still charging an advisory fee is materially different from what has been disclosed. A firm generally cannot provide services that differ materially from what Form ADV sets out. Where the disclosed model is advice and the delivered reality is self-direction, that gap is the kind of issue that attracts regulatory attention, quite apart from the fiduciary and suitability concerns already described.
For a client, this is worth understanding because it reframes the question. It is not only whether you are receiving good value. It is whether the service you are actually receiving matches the service the firm has told its regulator, and told you, that it provides. That document is public. Advice to US clients of Cameron James USA is delivered through Beacon Global Advisor Network, LLC, and you can read the BGAN Form ADV Part 2A and the BGAN Form CRS and hold the service you receive against them.
Advised on a genuine basis, or advised in name only
| Element of the service | Genuine adviser basis | Advised in name only |
|---|---|---|
| Initial suitability | Documented and specific to your circumstances, objectives, and US tax position | A risk questionnaire score, filed once and never revisited |
| Ongoing review | A defined cadence, evidenced, with dates you can be told on request | No review trail, and no date anybody can give you |
| Rebalancing | A recorded rationale for holding, rebalancing, or switching | Holdings set at outset and left to drift |
| Adviser contact | A named adviser who knows the file and takes responsibility | A name on the account and little else |
| Fee transparency | Clear disclosure of what the fee buys and how often it is delivered | An annual percentage with no stated deliverable |
| Regulatory basis | Consistent with the platform terms, the client agreement, and Form ADV | Potentially inconsistent with all three at once |
Why Expats in the US Keep Getting Pushed Off UK Platforms
Many expats searching for a way to self-invest with Novia Global arrive at that search having just been told to leave somewhere else. Interactive Investor has confirmed that it is exiting the US-resident market and wrote to affected clients requiring them to transfer their SIPP, ISA, and GIA accounts out by an individually assigned cut-off date, with services restricted from 7 January 2026. Vanguard UK places restrictions on accounts for non-UK residents generally, but the position on US persons is more specific. Vanguard states that it does not offer its services to US persons, and that a client who moves to the US will need to close the account or transfer to another provider.
Hargreaves Lansdown, AJ Bell, Bestinvest, and Standard Life Aberdeen have all arrived at the same destination. The direction of travel has been clear for over a decade, and the interesting question is not why these platforms are leaving, but why some of them stayed as long as they did.
| Platform | Published position on US persons |
|---|---|
| Novia Global | Open to non-UK residents, but only on an adviser basis. No self-directed or execution-only route exists. |
| Interactive Investor | Exiting the US-resident market. Affected clients written to, with services restricted from 7 January 2026. |
| Vanguard UK | Does not offer its services to US persons. A client moving to the US must close the account or transfer away. |
| Standard Life Aberdeen | US-resident SIPP holders required to transfer out, citing fund-level restrictions on US-resident investors. |
| Hargreaves Lansdown, AJ Bell, Bestinvest | Decline US-resident clients. Applications from US persons are not accepted. |
The reason is regulatory rather than commercial pique. The SEC takes a broad, extraterritorial view of investment adviser and broker-dealer regulation. A firm dealing with, or managing money for, a US resident is on that view generally providing those services in the United States, and may be required to register accordingly unless an exemption applies. A UK-only, FCA-authorized platform that is not registered in the US, and that does not have an appropriately registered adviser in the chain, is exposed if it services US persons directly. Faced with that, most UK platforms simply decline to serve US persons at all. That is why Vanguard singles out US persons for closure rather than applying the milder restriction it uses for other overseas clients.
This is where the self-investment question stops being a matter of convenience. An arrangement that lets an expat self-direct investments through a platform, with no properly registered US adviser or broker-dealer anywhere in the structure, sits in exactly the territory that these US registration requirements were designed to capture. Running an adviser-led platform as though it were an execution-only, self-invest service does not sidestep that exposure. If anything, it risks recreating it, potentially for the platform and for the adviser firm as well as for you. That is one reason the distinction is not merely academic, and it is the same point we make about platform eligibility versus advice compliance more generally.
The point for a US person is straightforward. The presence of a genuinely SEC-authorized adviser representative in the structure is part of what keeps a US-connected pension arrangement on the right side of these rules. It is not a box-ticking formality, and it is not something that can be satisfied by an adviser whose name is attached to the account but who is not actually providing an ongoing, regulated service.
The Risk of an Advised-in-Name-Only Structure
Where a SIPP is opened on an adviser-led platform but is, in substance, operated as though it were self-directed, three separate obligations are put at risk at the same time. The terms of business between the platform and the adviser firm. The terms of business between the adviser and the client. And the fiduciary duty owed by the adviser under SEC rules. Any one of these going unmet is a problem. All three going unmet at once, on the same account, is a structural issue rather than an isolated oversight.
For the client, the practical risk is simple to state. An advisory fee is being paid for a service that is not, in substance, being delivered, and the pension holdings may drift out of suitability with nobody actively monitoring for it. If a dispute or a regulatory question ever arises, the absence of a documented, ongoing review trail is very difficult to remedy after the fact.
How to Check Your Own Novia Global SIPP
Three questions to ask your adviser
- When was my portfolio last formally reviewed, and on what date?
- What is the documented rationale for the current allocation?
- How often is that review repeated, and where is it recorded?
If those answers are not readily available, the account may not be operating on a genuine adviser basis.
Cameron James USA advisers hold individual SEC authorization through Beacon Global Advisor Network, LLC (CRD 288833) and provide documented, ongoing portfolio review for every advised SIPP. Our fee schedule is published in full on our Our Cost page, and you can contact us to have an existing Novia Global SIPP reviewed.
A Note From Jonathan Laws
Frequently Asked Questions
Can I self-invest in a Novia Global SIPP?
No. The Novia Global SIPP sits on an adviser-led platform. There is no self-directed or execution-only version that lets you manage the pension yourself without an adviser. If you want a fully self-directed pension, you would need a different type of provider, and as a US person your realistic options are extremely limited.
Can a UK expat living in the US self-invest in a Novia Global SIPP?
No. The platform is adviser-led for every client, and for an expat who is a US person there is a second reason as well. Advice to a US person generally has to come from an adviser holding SEC authorization, so removing the adviser does not simplify the arrangement. It removes the part of the structure that keeps it compliant.
Can I hold a Novia Global SIPP without an ongoing adviser relationship?
No. The Novia Global terms require a formal adviser relationship in order to open and operate an account, and dealing instructions are placed through that adviser. The SIPP is not offered as a direct, execution-only product.
Does SEC fiduciary duty apply only when an account is first opened?
No. Fiduciary duty under the Investment Advisers Act of 1940 is ongoing for as long as the advisory relationship and the fee continue. The SEC has stated that where an adviser is compensated by a periodic asset-based fee, the duty to provide advice and monitoring is relatively extensive. It is not a single assessment performed at outset.
What should I ask my current adviser if I already hold a Novia Global SIPP?
Ask when your holdings were last reviewed, what the documented rationale for the current allocation is, and how often reviews take place. You are entitled to clear answers, because you are paying an advisory fee for exactly that service.
Is this specific to Novia Global?
No. The same principle, that an ongoing advisory fee requires ongoing and documented adviser involvement, applies to any adviser-led platform. Novia Global is used as the example here because the platform terms state the adviser-basis requirement explicitly.
Why do UK platforms keep closing accounts for expats in the US?
Because serving US persons can trigger US registration requirements. The SEC generally treats a firm dealing with or advising a US resident as providing those services in the United States, which can require registration unless an exemption applies. Most UK-only platforms are not registered in the US, so they decline US-resident clients rather than take on that exposure. Interactive Investor is exiting the US-resident market, and Vanguard states that it does not offer its services to US persons.
What does Form ADV have to do with a self-invest arrangement?
An SEC-registered adviser must disclose the services it offers and the fees it charges in Form ADV, and must deliver services consistent with that disclosure. If a Form ADV describes only advised or discretionary management, but a client is in practice left to self-direct with no advice while still paying an advisory fee, then the delivered service is materially different from the disclosed service. That mismatch is a regulatory issue in its own right, separate from the suitability and fiduciary concerns.
Is Your SIPP Actually Being Advised, or Only Being Charged?
The only question that matters is whether your fee is buying work. We will give you a clear written view before you change anything. Fee-based, no commission, individual SEC authorization.
Related Articles
If you are an expat reviewing a UK pension from the United States, these are the pieces most readers of this article go to next.
Vanguard UK Closed Your Account Because You Live in the US? Here Is What to Do
Vanguard states plainly that it does not serve US persons. This explains the closure process and the compliant transfer route.
Interactive Investor SIPP Closing for US Residents: Deadlines and Transfer Options
The exit that sends most expats looking for a new SIPP home in the first place, with the deadlines and the traps.
Understanding the Beacon Global Advisor Network (BGAN) Model and Cameron James USA
How individual SEC authorization actually works in practice, and who you are legally contracting with in the United States.
AJ Bell Investcentre and Non-UK Residents: A Cross-Border Compliance Guide
Why platform eligibility and advice compliance are two different questions, and why confusing them creates real risk.
International SIPP for US Residents
The pillar guide to how an International SIPP works, what it holds, and what it costs as an expat in the US.
Disclaimer and Disclosures
This article is provided for general educational purposes only and does not constitute personalized financial, tax, or legal advice. It reflects publicly available information about the Novia Global SIPP and general principles of US securities regulation, Form ADV disclosure obligations, and fiduciary duty under the Investment Advisers Act of 1940, as at the date of last review. References to specific platforms describe the publicly stated positions of those platforms on servicing non-UK or US-resident clients, and are not allegations of wrongdoing. This article does not assert that any specific firm is in breach of any regulatory requirement, or that any firm has made an inaccurate regulatory disclosure.
Regulatory requirements and platform terms may change. You should not rely on this article as a substitute for reviewing your own adviser agreement or platform terms, or for regulated financial advice specific to your circumstances. Cameron James USA accepts no liability for any loss arising from reliance on this information, or for any errors or omissions.
Jonathan Laws, ACA Ch.FCSI
Senior Independent Financial Adviser, Cameron James
“Almost every week I speak to an expat who has typed a phrase like self-invest Novia Global SIPP into Google. They are rarely looking for a new hobby. They are usually looking for a way to stop paying for something they no longer believe they are receiving. That instinct is sound. The conclusion is not. On this platform you cannot remove the adviser, so the real question is whether the adviser you already have is doing the work.
The test I would apply is a simple one. Ask for the date of the last documented review and the written rationale for your current allocation. A properly run advisory relationship produces both within a day. If neither can be produced at all, the issue is not the platform and it is not the level of the fee. It is that you are paying for a service that is not being delivered, and that is a problem for the adviser long before it becomes a problem for you.”