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A family office should make emerging-technology investing governable through a written investment policy statement (IPS). The IPS should define the office’s objectives, decision rights, eligible ways to invest, portfolio limits, diligence evidence, operational controls, monitoring duties and review triggers. It should be tailored to the family’s purpose, liquidity needs, time horizon, risk capacity, legal structure and jurisdiction—not copied from a survey or a generic technology forecast.
Start with an IPS, not a technology prediction
An IPS is a governance document. It records how the family office makes investment decisions, who has authority, what constraints apply and how exceptions are handled. Northern Trust describes the IPS as a source of strategic direction and role clarity for family-office decisions; Trish Halper calls it “a rudder” that keeps the office on course while allowing adjustment as circumstances change. Read the firm’s discussion of investment decision-making at Northern Trust.
Emerging technology is not one asset class. A listed semiconductor company, an artificial-intelligence (AI) software company, a venture fund, a data-center project, a digital token and an energy-transition infrastructure investment can have completely different liquidity, valuation, custody, regulatory and operating risks. The IPS therefore needs rules for exposure routes and risks, rather than one broad “technology” allocation.
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Define the policy’s purpose and scope
State what the policy covers
Write a plain-language scope statement before setting percentages. Specify whether the IPS applies to:
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- Public-market securities connected to emerging technologies.
- Private funds, venture and growth investments.
- Direct investments in operating companies or projects.
- Infrastructure such as data centers, power systems or networks.
- Digital assets, token-related vehicles and associated custody arrangements.
- Operating-company investments made by the family office.
- The office’s own use of AI tools for research, administration or communications.
List excluded activities explicitly. For example, the family may permit a diversified fund but prohibit direct token custody, or permit a small direct-investment sleeve only with investment-committee approval. An exclusion is useful only when the office can identify it during trade approval and reporting.
Connect technology exposure to the family’s objectives
Describe why the family is considering these investments. Objectives might include long-term growth, preservation of purchasing power, strategic alignment with an operating business, diversification, impact goals or learning about a sector. Record the time horizon and the amount of capital that must remain available for taxes, philanthropy, distributions, private-business needs and emergencies. A technology theme should not override those obligations.
Separate exposure routes before setting limits
Use a schedule in the IPS to distinguish the routes through which the office can obtain exposure. The route determines liquidity, diligence workload and the type of loss that can occur.
| Exposure route | Policy questions to answer | Risks requiring specific treatment |
|---|---|---|
| Public securities | Which listed securities, exchanges and instruments are eligible? Are derivatives allowed? | Market volatility, issuer concentration, trading liquidity and rapid repricing. |
| Funds | What fund structures, lock-ups, gates and reporting standards are acceptable? | Manager selection, fees, valuation methodology, underlying concentration and redemption limits. |
| Venture and growth investments | Who may approve commitments, follow-on funding and capital calls? | Illiquidity, financing needs, uncertain valuations, dilution and long exit periods. |
| Direct company investments | What ownership, information and governance rights are required? | Company-specific execution, data and intellectual-property rights, key-person dependence and concentration. |
| Infrastructure | What project, geography, power, network and contractual exposures are permitted? | Construction, permitting, financing, operating performance and long-lived illiquidity. |
| Digital assets | Are tokens, funds, lending, staking or decentralized-finance activities permitted? Who controls custody? | Custody and private-key loss, liquidity gaps, platform or protocol failure, valuation and changing regulation. |
For every route, define whether exposure is measured at commitment, invested cost, current value, unfunded obligation or another basis. The policy should explain how a private fund commitment, a project loan and a listed security are aggregated when calculating concentration.
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Assign decision rights and escalation paths
Map the investment workflow
Name the person or body responsible for each stage:
- Origination: identify opportunities and record the source, thesis and proposed exposure route.
- Initial screening: check eligibility, conflicts, strategic fit, liquidity and preliminary concentration.
- Diligence: collect the evidence required by the IPS and document unresolved issues.
- Approval: apply dollar, percentage and route-specific approval thresholds.
- Execution: confirm legal documents, custody, funding, valuation and booking.
- Monitoring: report performance, risk limits, material events and required follow-on decisions.
- Exit or wind-down: define who can sell, redeem, transfer or stop funding and how exceptions are approved.
Set a higher approval level for direct investments, private commitments, digital-asset custody and any transaction that could create a related-party conflict. Require written escalation when a proposed deal exceeds a limit, depends on an unverified claim, changes the family’s liquidity profile or introduces a legal or regulatory uncertainty.
Build family-specific portfolio boundaries
The available evidence does not support a universal emerging-technology percentage. Instead, the IPS should set target ranges or maximums that reflect the family’s balance sheet and governance capacity. Include:
- Strategic range or ceiling: the permitted aggregate exposure and any separate limits for AI, digital assets, energy transition, quantum computing or other themes.
- Concentration limits: maximum exposure to one issuer, manager, technology dependency, geography, protocol or counterparty.
- Illiquidity limits: a cap on committed and invested capital that cannot be sold or redeemed within the family’s required liquidity horizon.
- Unfunded-commitment limits: a test showing that capital calls can be met without forced sales of liquid assets.
- Loss tolerance: the amount and type of loss the family can absorb without impairing distributions, operating businesses or obligations.
- Currency and leverage rules: permitted borrowing, hedging and foreign-exchange exposure.
- Exception rules: who may approve a temporary breach, for how long and with what remediation plan.
State whether limits are calculated at cost, fair value, commitment or look-through exposure. Without that definition, a fund holding and a direct holding can be counted inconsistently.
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Make diligence evidence-based
Core questions for every emerging-technology investment
Require a standard memorandum that answers the same core questions regardless of theme:
- What product or service is being bought, and what customer problem does it solve?
- Which customers pay, how recurring is revenue and what evidence supports the economics?
- Who manages the company or fund, and how are governance, controls and conflicts handled?
- Who owns the relevant data, software, patents, models, licenses and other intellectual property?
- Which suppliers, cloud providers, chips, networks, protocols or counterparties are operational dependencies?
- What regulation applies now, what may change and which permissions are required?
- How much additional financing may be needed, and on what terms?
- How is the asset valued, who provides the valuation and what could make that valuation unreliable?
- What are the realistic exit paths, lock-ups and transfer restrictions?
- Can the office monitor the position with the staff, data and specialist advice it actually has?
Additional diligence for AI investments
AI claims require more than a product demonstration. Morgan Lewis identifies data rights, governance maturity, regulatory readiness, intellectual-property ownership and model dependencies as important diligence topics in its June 29, 2026 analysis, “AI and the Family Office: Adoption, Investment, and Risk Management.” Add questions such as:
- Does the company have documented rights to training, customer and third-party data?
- Are model outputs tested for accuracy, bias, security and harmful failure modes?
- What external models, application-programming interfaces, cloud services or hardware are essential?
- Can a supplier change pricing, access or terms in a way that damages the economics?
- Who owns models and improvements created from customer data or employee work?
- What human review, audit trail and incident process applies to consequential outputs?
- Is the company prepared for applicable privacy, copyright, safety and sector regulation?
Request evidence—contracts, policies, testing records, customer references, security reports and cap-table or financing information—rather than accepting marketing language as proof.
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Investment ownership and internal tool use create different risks, so cover both in the IPS or in a linked technology-governance schedule. Morgan Lewis advises establishing governance before broad adoption and cautions against both blanket prohibition and uncontrolled consumer-tool use.
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Document approved use cases, accountable owners and prohibited data. Define which tools may receive confidential family, portfolio, client, employee or deal information; require access controls and vendor protections; and keep records of material AI-assisted work. A human reviewer should approve consequential investment decisions, legal or tax communications and external statements. Set an incident path for data leakage, fabricated output, unauthorized access or a materially wrong recommendation. The governing principle is that AI should augment, not replace, human judgment.
Handle digital assets and infrastructure as distinct risks
Digital assets
A digital-asset policy should specify eligible instruments, exchanges or counterparties, custody model, segregation of duties, transaction approval, wallet or key recovery, valuation source, liquidity assumptions and tax records. If staking, lending or decentralized-finance activity is allowed, address smart-contract, counterparty and withdrawal risks separately. Do not treat a liquid listed vehicle as operationally equivalent to direct token custody.
Energy transition, data centers and other infrastructure
Infrastructure diligence should examine permits, power availability, construction status, grid or network dependencies, contracts, insurance, financing, operating assumptions and exit rights. A project can be connected to an attractive technology theme while still carrying property, construction or utility risks that do not appear in a software investment. The IPS should identify who can assess those specialist risks and what independent reports are required.
Use surveys as context, not allocation advice
Recent surveys show why families are formalizing policy, but they do not establish a suitable allocation for an individual office.
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| Survey | Reported result | How to interpret it |
|---|---|---|
| J.P. Morgan Private Bank, 2026 | 65% plan to prioritize AI; more than half report no venture or growth-market exposure; 79% report no infrastructure allocation. The report covers 333 family offices in 30 countries. | Interest, current exposure and infrastructure participation can diverge; these figures are not target weights. |
| UBS Global Family Office Report 2026 | 65% of surveyed offices were invested across the AI value chain, including data-center infrastructure, software platforms and semiconductor producers. The survey covers 307 offices across more than 30 markets. | “Already invested” is a different measure and sample from a plan to prioritize, so the figures should not be combined. |
| UBS Global Family Office Report 2025 | 27% reported a clear generative-AI investment strategy and 27% a clear energy-transition strategy; respondents also sought information about blockchain or DeFi, 6G, quantum computing and agriculture or sustainable living. | Many offices may have interest without a fully documented strategy, which is a governance issue rather than a reason to invest. |
Set monitoring and review triggers
Assign one owner for policy compliance and require a regular report to the investment committee or family governing body. The report should show:
- Exposure by technology, route, issuer, manager, geography and currency.
- Current value, cost, unfunded commitments, valuation date and liquidity terms.
- Concentration, leverage, counterparty, custody and loss-limit status.
- Material changes in technology, suppliers, regulation, financing, management or intellectual-property rights.
- Exceptions, breaches, remediation deadlines and pending approval decisions.
Choose a review schedule appropriate to the family’s complexity, then require an off-cycle review after a major family, portfolio, legal or technology change. Northern Trust emphasizes that an IPS should allow adjustment; flexibility works only when the change process, documentation and approval authority are explicit.
Implement the policy in a controlled sequence
- Inventory the starting point: map existing public, private, operating-company, infrastructure and digital-asset exposures, including indirect holdings and unfunded commitments.
- Document family constraints: record liquidity needs, distributions, taxes, time horizon, risk capacity, jurisdiction and governance documents.
- Classify technologies and routes: separate AI, digital assets, energy transition, quantum and other themes by how exposure is obtained.
- Approve authority: identify originators, diligence owners, approvers, monitors and exception decision-makers.
- Set measurable boundaries: define ranges, ceilings, concentration tests, illiquidity rules and the measurement basis.
- Adopt diligence templates: require evidence for economics, governance, data, IP, regulation, dependencies, valuation and exit.
- Establish operating controls: cover custody, cybersecurity, AI-tool use, records, human review and incident escalation.
- Run a pre-trade check: confirm eligibility, capacity, conflicts, liquidity and approvals before signing or funding.
- Report and rehearse exceptions: test how the office responds to a limit breach, capital call, valuation shock, data incident or regulatory change.
- Review and amend: record the reason for each change, the approving body and the effective date.
Address legal and jurisdictional limits
Family-office rules vary by jurisdiction, legal structure and the services performed for family members. In the United States, SEC staff responses about the family-office rule expressly state that they are staff views, not a rule, regulation or statement approved by the Commission. The current staff FAQ is at SEC Division of Investment Management. Confirm the current law and obtain qualified legal, tax and regulatory advice for the relevant structure before relying on an exemption or offering an investment to anyone outside the permitted family group.
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Common policy failures to avoid
- Using a theme as an allocation: “AI” can hide public equities, venture, infrastructure and operating risk that should be limited differently.
- Copying survey percentages: survey populations, dates and definitions differ, and reported interest is not a family-specific risk budget.
- Approving on product enthusiasm: require contracts, data rights, customer evidence, governance records and dependency analysis.
- Ignoring internal tool use: confidential information can leave the office even when the investment itself is well controlled.
- Counting illiquidity incorrectly: commitments, lock-ups and capital calls can matter before they appear as current-value exposure.
- Writing limits without owners: a rule has little effect unless someone measures it, reports breaches and can stop a transaction.
- Treating the IPS as permanent: technology, regulation, family needs and portfolio capacity change; the amendment process must be usable and documented.
What a strong policy accomplishes
A well-designed IPS does not predict which technology will win. It lets the family office move when a credible opportunity appears without improvising authority, liquidity tests, diligence standards or operational safeguards. As Morgan Lewis puts it, “governance enables speed.” The practical test is whether the office can explain, before committing capital, why the exposure fits the family, who approved it, what could go wrong, how much can be lost or locked up, and who will notice when the facts change.
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