There is a pension structure that has been sold to thousands of internationally mobile clients over the past decade. It was recommended by advisers in expat hubs from Dubai to Singapore to Hong Kong, often to people who were new to the country, new to managing their finances across borders, and willing to trust a professional who seemed to know the territory. What many of those clients were not told, clearly, at least, was that the structure they were being sold carried two layers of charges instead of one, embedded commissions that would continue flowing to the adviser regardless of whether any service was ever provided, and an offshore component that added cost and complexity without adding any meaningful tax benefit.
That structure is the RL360 SIPP. And if you hold one, there is a reasonable chance that you have been paying more than you know and receiving less than you were promised.
This guide is not here to alarm you. Most situations are fixable, and a portfolio update or pension transfer between registered UK schemes is a straightforward process. But you do need the full picture before you can act on it, and this is where that picture starts.
What Is the RL360 SIPP?
The RL360 SIPP is a Self-Invested Personal Pension (SIPP), a UK-registered pension scheme authorised by HMRC, that holds an RL360 offshore bond as its underlying investment. In other words, it is a two-layer structure: a UK pension wrapper on the outside, with an Isle of Man-based offshore life assurance bond sitting inside it.
The SIPP launched in 2020, initially administered by Hartley Pensions, with either the RL360 Oracle bond (minimum £20,000) or RL360 PIMS, the Personal Investment Management Service (minimum £50,000), as the permitted investment components.
Who Administers the RL360 SIPP Now?
Hartley Pensions, the original SIPP administrator, entered administration in July 2022 after a period of aggressive expansion in which it acquired several troubled SIPP books from other failed providers. Around 17,000 clients were left in limbo.
Following intervention by the FCA and the Financial Services Compensation Scheme (FSCS), RL360 SIPP members were transferred as a block to IFGL Pensions, part of the same International Financial Group Limited that owns RL360, which now administers these plans under the Resolute SIPP structure. The FSCS agreed to cover exit and administration charges for the transfer, meaning most clients did not face additional costs for moving, though annual management fees continued to accrue throughout the administration period.
If your RL360 SIPP was originally administered by Hartley Pensions, you should confirm with IFGL Pensions that your transfer has been completed and that you fully understand your current fee position.
The Two-Layer Structure: Why It Matters
The defining, and most consequential, feature of the RL360 SIPP is that the underlying investment is not a straightforward, directly-held portfolio of funds or ETFs on a modern platform. It is an offshore life assurance bond issued by RL360 Insurance Company Limited in the Isle of Man.
This means you are paying for two wrappers simultaneously: the SIPP administration layer and the offshore bond layer sitting inside it. Each carries its own charges. Understanding the total cost of this combined structure is essential, and is something that many clients were never clearly shown at the point of sale.
A Question Worth Asking
A SIPP is already a tax-advantaged wrapper. Contributions receive UK income tax relief at the contributor’s marginal rate. Growth inside the SIPP is free from UK capital gains tax. The SIPP provides significant tax efficiency in its own right.
An offshore bond is also a tax-deferred wrapper, typically used to defer the recognition of investment gains until withdrawal. When an offshore bond sits inside a SIPP, the tax deferral benefits of the bond are largely redundant, because the SIPP is already providing that deferral. What remains is the cost of the offshore bond wrapper itself, the restrictions on investment choice it imposes, and the dealing costs it introduces.
An offshore bond inside a SIPP may be costing you significantly more than you need to pay, without providing any corresponding tax or investment advantage over a direct SIPP portfolio.
RL360 SIPP Charges: What Does It Actually Cost?
The total cost of holding an RL360 SIPP is not straightforward to calculate. The charge layers typically include:
- SIPP administration/Trustee fee — a fixed annual charge for the SIPP wrapper itself (historically charged by Hartley Pensions, now by IFGL Pensions)
- RL360 bond charges — product-level annual management charges within the Oracle or PIMS bond, based on the fund value at the time of inception
- Dealing and custodian fees — charges for buying and selling investments within the PIMS structure. Reported dealing fees are approximately £40 per transaction
- Underlying fund charges — annual management charges of the investment funds themselves, typically 0.5%–1.5% per annum
- Adviser transaction remuneration — either embedded commission (in older or non-UK-regulated arrangements) or an explicit initial one-off fee
- Adviser ongoing remunerations – ongoing adviser charge layered on top of all the above, which can be directly via the wrapper, or via trail fees paid from underlying funds charges themselves
When all of these are aggregated into a single effective annual cost figure, many clients discover that their total cost of ownership is considerably higher than they realised, and considerably higher than modern alternatives.
How the RL360 SIPP Is Sold: Commissions, Conflicts, and Opacity
The RL360 SIPP is sold exclusively through financial advisers. RL360 does not distribute directly to consumers. This intermediary-only model is not in itself problematic, but the way commission has historically been structured within RL360 products creates a significant and well-documented conflict of interest.
Advisers recommending RL360 products into expat markets have historically received upfront commissions of between 5% and 7% of the investment value. This commission is not paid out of RL360’s own margin; it is funded through charges built into the bond structure that are borne by the client. In some configurations, advisers have also received ongoing trail commissions of 0.5%–1% per annum, paid automatically from the policy value, year after year.
Offshore bonds will often quote an “Indicative Surrender Value,” which will be materially lower than the total value of the wrapper. The spread between those numbers will be mostly explained by commissions, paid to the original adviser upon transfer, which have not yet been recouped by RL360, as the term of the bond (5 to 10 years) has not concluded.
Trail Commission: The Hidden Ongoing Cost
Trail commission is the mechanism by which an adviser continues to receive payment from the product, typically as a percentage of the total policy value, long after the initial sale. It continues regardless of whether the adviser maintains any meaningful contact with the client, provides ongoing reviews, or updates the investment strategy as the client’s circumstances change.
For clients who relocated, changed tax residency, started a family, or experienced significant changes in their financial position after setting up their RL360 SIPP, this is a particularly damaging problem. The adviser is being paid, via trail commission, to provide ongoing service, but in many cases, no such service has ever been provided.
The same RL360 product can cost significantly less when structured through a fee-only adviser rather than on a commission basis.
Critical Considerations for US Citizens and US-Connected Clients
If you are a US citizen, green card holder, or US tax resident, whether living in the US, the UK, or anywhere else, holding an RL360 SIPP with an offshore bond underlying creates several layers of complexity that are rarely addressed by the original adviser.
The UK/US Tax Treaty and SIPP Protection
The UK-US tax treaty provides important protections for UK pension income received by US residents. A properly structured UK SIPP that falls within the treaty’s pension provisions can allow contributions and growth to accumulate without immediate US taxation, with distributions taxed only upon withdrawal. However, claiming this treaty protection requires a formal election to be made; it is not automatic, and the pension must meet certain structural requirements to qualify.
A SIPP that holds an offshore bond as its underlying asset introduces additional complexity. Whether the bond’s offshore structure affects the pension’s treaty-protected status is not straightforward and requires specialist cross-border advice.
PFIC Risk Within the Offshore Bond
Non-US investment funds held within a standalone (i.e. not inside a pension wrapper) RL360 Oracle or PIMS bond are almost certainly classified as Passive Foreign Investment Companies (PFICs) under US tax law. Ordinarily, a US person holding PFICs faces punitive default tax treatment, gains taxed at the highest income tax rate, plus interest charges, unless specific annual elections (QEF or mark-to-market) are made and IRS Form 8621 is filed each year.
Where the PFICs are held within a pension that is fully protected under the UK-US tax treaty, this annual PFIC reporting burden may not arise. But the answer depends critically on whether the pension qualifies for treaty protection and whether that protection has been properly claimed, questions that require specialist advice.
The Adviser Qualification Problem
Advisers selling RL360 products in Dubai, Singapore, Hong Kong, Nairobi, or elsewhere in the expat market are typically regulated by the local authority, not by the FCA, and almost certainly not by the SEC. Providing investment advice to US persons without SEC registration or an applicable exemption is a violation of the US Investment Advisers Act of 1940.
If your RL360 SIPP was recommended by an adviser who was not qualified or registered to advise US persons, not only may the original advice have been given in breach of regulatory requirements, but the ongoing structure of your pension may never have been designed with your US obligations in mind.
If your RL360 SIPP was sold by an adviser outside the UK/US regulatory framework and you have US connections, your pension structure may have been designed without any regard to your US tax position.
Your Options: Reviewing, Restructuring, or Transferring Your RL360 SIPP
If you hold an RL360 SIPP and have concerns, whether about cost, US tax compliance, ongoing service, or the Hartley Pensions administration fallout, you have options.
Step 1: Review Your Current Position
Before taking any action, understand exactly what you have. This means confirming your current SIPP administrator (is your plan now with IFGL Pensions?), quantifying the full annual cost of the plan, reviewing the funds you hold and whether they remain appropriate for your circumstances, and assessing whether the pension is set up correctly for your current country of residence and tax position.
Step 2: Undertake a Full Cross-Border Financial Review
For non-UK residents, the SIPP is rarely an isolated question. It sits within a broader picture that may include, for US residents, US retirement accounts (401k, IRA), UK property, non-pension investments, IHT exposure on both sides of the Atlantic, Social Security and State Pension entitlements, and estate planning. A comprehensive review, by an adviser who is qualified in both the UK and US dimensions, is the most valuable starting point.
Option 3: Transfer to a Lower-Cost, More Appropriate SIPP
A UK SIPP transfer is generally straightforward, provided the receiving SIPP is a recognised pension scheme. The process typically takes several weeks and involves completing a transfer request with your existing administrator. There are no HMRC penalties for transferring between registered UK SIPPs. Any adviser commission embedded in the existing bond structure should cease upon transfer.
The key is ensuring that the receiving SIPP and the adviser managing it are appropriate for your circumstances, particularly if you are a non-UK resident or have US connections. Not all SIPP providers will accept non-UK residents, and not all advisers are qualified to advise US persons.
A pension transfer is a transaction. A financial plan is a strategy. The goal is not simply to move your pension — it is to make sure your entire financial picture works coherently for where you are now and where you are going.
How Cameron James Can Help
All Cameron James advisers are FCA and EU regulated; several are also SEC-authorised. We work with US citizens living in the UK, British expats living in the US, and internationally mobile clients who have financial ties to both countries.
We are a fee-based firm. We do not receive commission from product providers. We do not receive trail commission. Our interests are aligned entirely with yours.
Our work in this area includes:
- Reviewing existing RL360 SIPPs and quantifying the full cost of the current structure
- Advising on pension transfers to lower-cost, open-architecture SIPPs appropriate for non-UK residents, where suitable
- Helping facilitate advice to US persons on the UK/US treaty treatment of their UK pension, and the implications of the treaty election
- Providing holistic financial planning that addresses UK and cross-border dimensions in a single, coordinated strategy
- Reviewing whether an offshore bond within a SIPP is genuinely adding value, and advising on alternatives where it is not
Next Steps
If you hold an RL360 SIPP, or if you are unsure whether what you hold is an RL360 product inside a pension wrapper, and you would like an honest, expert review of your position, Cameron James is here to help.
We have advisers who are FCA-authorised, EEA and SEC-registered. We do not receive commission. We specialise in cross-border UK/EU/US financial planning and have extensive experience reviewing offshore-linked pension structures held by expats and internationally mobile clients.
Get in touch today. Understanding what you have costs nothing. The cost of not understanding it could be significant.
Frequently Asked Questions About the RL360 SIPP
My RL360 SIPP was with Hartley Pensions. What happened to it?
Hartley Pensions entered administration in July 2022. For RL360 SIPP members, IFGL Pensions, part of the same corporate group as RL360, was appointed as the new trustee and administrator. The FSCS agreed to cover the costs of this transfer, so most RL360 SIPP members should not have incurred additional charges for the move. However, annual management fees continued to accrue throughout the administration period. If you are unsure of your current position, contact IFGL Pensions directly or seek independent advice.
Why is there an offshore bond inside my SIPP? Is that normal?
It is unusual from a pure financial planning perspective. A SIPP already provides the tax deferral and pension wrapper that an offshore bond is typically designed to achieve. Placing an offshore bond inside a SIPP creates a two-layer cost structure, paying for two wrappers when one would suffice. This structure is more common in the expat financial planning market than in mainstream UK planning, and is often driven by the commission arrangements available to advisers rather than the optimal outcome for the client.
Can I transfer my RL360 SIPP to a different provider?
Yes, in most cases. A transfer between registered UK pension schemes does not trigger any HMRC charges. You will need to complete a transfer request with your current administrator (IFGL Pensions) and the new SIPP provider. Any adviser commission embedded in the existing bond structure should cease once the bond is encashed as part of the transfer. Some fund ranges within the RL360 Oracle bond may have exit fees or dealing costs, so you should understand the full transfer cost before proceeding.
I am a US citizen living in the UK. Is my RL360 SIPP a problem for US taxes?
Not necessarily, but it requires careful assessment. A UK SIPP that qualifies as a pension under the UK/US tax treaty and for which a treaty election has been made should allow growth to accumulate without annual US taxation. However, the presence of an offshore bond as the underlying investment introduces additional questions about treaty qualification, PFIC treatment of the underlying funds, and appropriate reporting. You should seek advice from a cross-border specialist who is qualified in both the UK and US contexts.
Am I paying trail commission without receiving any ongoing service?
This is a very common situation. If your RL360 SIPP was set up by an adviser who built trail commission into the structure, that commission continues to be paid from your plan value regardless of whether the adviser provides any ongoing service. To understand whether trail commission is embedded in your plan, review your original policy documentation or request a full fee and charge disclosure from IFGL Pensions. A fee-based adviser can help you quantify this cost and model whether transferring to an alternative structure would be financially worthwhile.
I’m not a US person. Is this article still relevant to me?
Yes. While US-connected clients face the most acute regulatory complexity around RL360 SIPPs, the issues of commission structures, layered charges, opaque fees, poor ongoing service, and the questionable rationale for an offshore bond inside a UK pension are relevant to any client, wherever they are based. Cameron James works with internationally mobile clients globally, not only those with US connections.
How much does Cameron James charge for a review?
We operate on a fully transparent, fee-based model with no commission and no product-linked payments. Our fee schedule is published on our website. We do not charge for initial Discovery Meetings.
Important Information
US persons — including US citizens, green card holders, and US tax residents — should be aware that UK pensions, including SIPPs, may carry specific US tax reporting obligations, including but not limited to FBAR (FinCEN Form 114), FATCA (IRS Form 8938), and the requirement to make a tax treaty election to obtain treaty-protected pension treatment. This article does not constitute US tax advice. Please consult a qualified US tax professional in conjunction with cross-border financial planning advice.
RL360 is a trading name of RL360 Insurance Company Limited, regulated by the Isle of Man Financial Services Authority (IOMFSA). IFGL Pensions Limited is authorised and regulated by the Financial Conduct Authority (FCA). Hartley Pensions Limited entered administration in July 2022. Cameron James Financial Planning is not affiliated with RL360, IFGL Pensions, or Hartley Pensions, and this article is independent of and not endorsed by any of those entities.
Information is based on our understanding at the date of publication. Regulatory positions, product structures, and tax legislation may change. Past performance is not a reliable indicator of future results. The value of pensions and investments can fall as well as rise. You may get back less than you invest.
