The Australian Prudential Regulation Authority (APRA) announced it has accepted an enforceable undertaking from former Trio Capital Limited (Trio) director John Godfrey. Mr Godfrey has undertaken not to act as a trustee or as a responsible officer of a body corporate that is a trustee, investment manager or custodian of an APRA-regulated superannuation entity without obtaining APRA’s prior written consent. APRA’s concerns included that Trio: (i) failed to redeem existing investments in the Exploration Fund Limited (EFL), an offshore hedge fund, and made ongoing investments in the EFL, given: there was a lack of arms’-length arrangements in place as the EFL was a related party to Trio; the investment risks associated with the EFL; Trio had failed to comply with the provisions in its Overarching Investment Policy dealing with hedge fund and related party investments; and failed to redeem existing investments in the ASF and made ongoing investments in the ASF, given there were similar issues to those associated with the EFL investment.  Trio failed to adequately consider counterparty risk, the risks of investing in offshore hedge funds and the risks associated with the investment structure of the ASF through Deferred Purchase Agreements.