InvestmentFraudLawyers.com, the consumer-facing brand of Haselkorn & Thibaut, P.A., is following TriLinc Global Impact Fund, LLC, a publicly registered nontraded impact-lending fund whose regular distributions have now been frozen for roughly two and a half years. The fund recently disclosed that it will use cash from two long-distressed loan settlements to pay about $2.5 million of pending death-and-disability redemptions, but it has no plans to resume ordinary distributions or repurchases. We break down what happened, what the fund is worth today, and why the situation may raise suitability and due-diligence questions for the investors who bought in.
What is TriLinc Global Impact Fund?
Table of Contents
TriLinc Global Impact Fund, LLC is a nontraded limited liability company launched in 2013. It is advised by TriLinc Advisors LLC, a subsidiary of sponsor TriLinc Global, LLC, and led by Gloria Nelund, its chairman and chief executive officer. The fund’s strategy is to provide trade finance and term loans to small and medium-sized enterprises (SMEs) in emerging markets, while seeking measurable social and environmental impact alongside financial returns. It is a public fund registered with the Securities and Exchange Commission (SEC); three related TriLinc vehicles are private.
The fund is not listed on an exchange. Investors who want liquidity generally must rely on the fund’s unit repurchase program, which has been largely suspended since mid-2023. TriLinc has warned that even if units could be sold, the price would likely be at a substantial discount.
The distribution freeze
Regular monthly distributions stopped after June 2023. The fund paid two special distributions in February and March 2024, then nothing further. As of September 2026, the freeze has reached two and a half years. The fund’s board recently waived a policy that limited unit repurchases to cash raised through the distribution reinvestment plan. The waiver frees liquidity, including recent settlement proceeds, to process pending repurchase requests tied to unitholder deaths and disabilities. Those requests total approximately $2.5 million based on TriLinc’s net asset value (NAV) per unit as of June 30, 2026.
Despite the incoming settlement cash, TriLinc stated it does not currently intend to resume regular unit repurchases or cash distributions “as a result of these settlements or otherwise.” It also said it “cannot provide any assurances as to when or if” distributions will resume.
| Timeline event | Date | Significance |
|---|---|---|
| Fund peak assets | 2018 | Total assets reached $403 million; $17.5 million in distributions paid |
| Auditor RSM resigns | Early 2023 | Fund says resignation triggered covenant breach and ~$18 million lender repayment |
| Regular distributions stop | After June 2023 | No regular monthly distributions since; repurchase program largely suspended |
| Special distributions | Feb. and Mar. 2024 | Two one-time payments; none since |
| Freeze reaches 2.5 years | Sept. 2026 | Fund still not committing to resume distributions or ordinary redemptions |
Portfolio deterioration and watch-list loans
The fund’s financial statements show a shrinking portfolio. Fair value fell to $262.2 million at the end of 2025 from $268.4 million a year earlier. As of September 30, 2025, investments were carried at fair value of $260.0 million against an amortized cost of $334.1 million. The fund made no new investments in 2024 or 2025 and issued no new units in either year, even though its registration statement remained effective.
At the end of 2025, 22 positions were on TriLinc’s internal watch list. Several were already in default: a Hong Kong-based commodities trader marked down by roughly a third, a Botswana small-business lender marked down by more than two-thirds, and a Kenyan freight and cargo transporter marked down by nearly 80%. The five largest positions made up 57.5% of the portfolio, and the largest holding alone—a Mexican waste-to-fuels processor paying 20% payment-in-kind interest—grew to 27% of the portfolio from 21.6% a year earlier.
| Metric | Value |
|---|---|
| Fair value at Dec. 31, 2024 | $268.4 million |
| Fair value at Dec. 31, 2025 | $262.2 million |
| Amortized cost at Sept. 30, 2025 | $334.1 million |
| Fair value at Sept. 30, 2025 | $260.0 million |
| Watch-list positions at Dec. 31, 2025 | 22 |
| Top five positions at Dec. 31, 2025 | 57.5% of portfolio |
| Pending death/disability redemptions | ~$2.5 million |
The two settlements funding the latest redemptions
The cash TriLinc plans to use for the pending redemptions comes from two distressed-loan settlements. In February 2019 the fund funded an $8.275 million participation in Cevher International B.V., a Netherlands-domiciled holding company for a Turkish aluminum wheel manufacturer. The borrower ran into trouble in 2024 after inflation in Türkiye reached 68.5% and the factory’s union secured wage increases. TriLinc and Cevher signed a discounted settlement term sheet in September 2025, but a prospective strategic investor withdrew in January 2026 and the parties negotiated an amended settlement. The position was carried at approximately $11 million at the end of 2025 and was marked down to nearly $9.99 million as of June 30, 2026.
The second settlement involves Dock Brasil Engenharia e Serviços S.A., a Brazilian shipyard and offshore-vessel repair company TriLinc partly financed with a $5.5 million loan in December 2018. A lost joint-venture contract and regional flooding hurt the business in 2024, prompting a shareholder-led sale process. In November 2025 TriLinc agreed to a settlement allocating it roughly $14.1 million of the eventual sale proceeds. The fund received a first installment of about $1.99 million in June 2026, with the sale expected to close in the third quarter.
The IIG sub-adviser controversy
A cluster of Argentine watch-list positions traces to IIG Trade Opportunities Fund B.V., a former sub-adviser that managed five of the 22 watch-list investments, or 6.9% of the portfolio by fair value at the end of 2025. TriLinc has stated that IIG “failed to provide us with complete and accurate information” about those holdings and, in 2017, sold the fund a $6 million participation in a loan that did not exist.
Why this raises suitability and due-diligence questions
For investors, the TriLinc situation is a textbook example of the risks that can hide inside non-traded fund and REIT losses. Nontraded funds can suspend distributions and repurchases with little warning, leaving shareholders unable to access capital for years. Concentrated, illiquid emerging-market loans amplify that risk. When a single borrower can grow to more than a quarter of the portfolio and nearly a quarter of the portfolio is carried well below cost, the investment may have been too speculative for investors who needed income or liquidity.
The case also raises broker-dealer due diligence failures. Broker-dealers that recommended TriLinc had a duty under Financial Industry Regulatory Authority, or FINRA, rules to perform reasonable due diligence before offering the fund to retail investors. Broker-dealers who recommended TriLinc had a duty to understand the fund’s valuation practices, sub-adviser controls, concentration risk, and liquidity terms before offering it to retail clients—many of whom, according to court documents cited by trade press, are retirees.
What investors can do
If you invested in TriLinc Global Impact Fund and are now facing frozen distributions, suspended redemptions, or a portfolio value well below your purchase price, consider these steps:
- Review your subscription documents, prospectus, and sales materials for risk disclosures and suitability representations.
- Request a complete account history showing all contributions, distributions, and current unit valuation.
- Document what your broker or adviser told you about liquidity, income, and risk before you invested.
- Consult a securities attorney to evaluate whether you have a claim for unsuitable recommendations, failure to disclose material risks, or lack of due diligence.
Related reading
How we can help
Haselkorn & Thibaut, P.A., operating as Investment Fraud Lawyers, represents investors who have suffered losses in nontraded funds, interval funds, business development companies, and other alternative investments. Our partners are former Wall Street defense attorneys who now use that insider knowledge to hold broker-dealers and advisers accountable. We operate on a contingency-fee basis: no recovery, no fee.
If you believe TriLinc Global Impact Fund caused your losses, call 1-888-885-7162 or visit InvestmentFraudLawyers.com for a free, confidential case review. You owe nothing unless we recover money for you.
Frequently asked questions
What is TriLinc Global Impact Fund?
TriLinc Global Impact Fund, LLC is a publicly registered nontraded impact-lending fund that provides trade finance and term loans to SMEs in emerging markets. It is advised by TriLinc Advisors LLC.
How long has TriLinc’s distribution been frozen?
Regular monthly distributions stopped after June 2023. As of September 2026, the freeze has reached roughly two and a half years.
Is TriLinc still making new loans?
No. The fund made no new investments in 2024 or 2025 and issued no new units in either year, according to its disclosures.
Can TriLinc investors recover losses?
Investors may have claims against the broker-dealers or advisers who recommended the fund if the investment was unsuitable, material risks were not disclosed, or due diligence was inadequate. Our firm reviews these cases on a contingency-fee basis.
Past results do not guarantee future outcomes. This page provides general information and is not legal advice. No attorney-client relationship is formed by reading this content.
There is no assured recovery in any securities matter. Consult a qualified attorney regarding your specific situation.