The investment adviser to the product, Sydney-based H3 Global Advisors, was a Cayman Islands-exempted limited liability company and was not registered under any other jurisdiction, S&P said.
The fund was only suitable for those comfortable that they would not benefit from protections afforded by other laws or regulations, it said.
"The fund opened in 2008 to external investors, but the strategy has been traded since 1999 in managed accounts and other products. It is very similar to the one used in the H3 Global Commodities Fund and blends both short and long-term momentum trends across five sectors and more than 60 markets," S&P fund analyst Simon Scott said.
"This narrower range and lower use of margin-to-equity ratio by H3 helps differentiate the fund from larger CTA peers and keeps volatility in the prescribed range."