Skip to main content
Link to Walkers homepage

Update on the beneficial ownership regime in the Cayman Islands - New Technical Guidance for corporate services providers

Mar 18, 2024

Advisory
A sleek black pen with 'Walkers' branding lies atop a closed notebook, both featuring raised 'Walkers' logos.

KEY TAKEAWAYS:

  • CSPs must adopt the new CSV file format for reporting beneficial ownership information via corporate administration platform

  • Commencement date for Beneficial Ownership Transparency Act to be announced at later date

  • Compliance with new elements of beneficial ownership framework required by 1 January 2025

On 15 March 2024, the Ministry of Financial Services and Commerce (the "Ministry") issued Technical Guidance for corporate services providers ("CSPs") to facilitate changes to internal processes in support of the transition to a new CSV file format used to report beneficial ownership information via the corporate administration platform ("CAP").

The Technical Guidance is accompanied by an example CSV file showing the new data fields and an excel worksheet with sample data, which will be downloaded once you click on the link.

The changes to the CSV file format are against the backdrop of significant technological updates and the introduction of the Beneficial Ownership Transparency Act, 2023 (the "BOTA"), which was gazetted on 15 December 2023, updating the beneficial ownership regime ("BOR") in place since 2017 in line with evolving international standards. The BOTA expands the scope of the BOR and the information which needs to be reported.  For further details of the BOTA, please see our advisory here.

The Ministry will announce the commencement date for the BOTA and accompanying regulations at a later date.

Compliance with the new elements of the beneficial ownership framework will be required by 1 January 2025. 

The Ministry will issue general guidance on the updated beneficial ownership obligations following industry consultation, as well as guidance on error messages.

The Technical Guidance will be available on the CAP once the BOTA and regulations commence. Once the new CSV file format is implemented CSPs will not be able to use the old file format, which will be rejected by the system.

Beneficial ownership information filing will be temporarily halted to allow the rollout of the new CSV file format. Once the new CSV file format is rolled out, CSPs will be brought back online in predesignated groups. The Ministry will contact CSPs directly to provide further guidance on the re-enrolment arrangements in due course.

Walkers can assist with all aspects of compliance with the beneficial ownership regime applicable in the Cayman Islands.

Regulatory & ComplianceCayman Islands

Authors

Colm Dawson

Colm Dawson

Partner/Cayman Islands

T/+1 345 914 6384
M/+1 345 938 6384
E/Email Colm Dawson
More articles from this author View profile
Lucy Frew profile image

Lucy Frew

Partner/Cayman Islands

T/+1 345 814 4676
M/+1 345 939 4676
E/Email Lucy Frew
More articles from this author View profile
Andrew Howarth

Andrew Howarth

Partner/Cayman Islands

T/+1 345 814 4561
M/+1 345 926 4561
E/Email Andrew Howarth
More articles from this author View profile
Ian Mason

Ian Mason

Partner/Cayman Islands

T/+1 345 814 4600
M/+1 345 916 4600
E/Email Ian Mason
More articles from this author View profile
Steven Manning

Steven Manning

Chief Executive Officer – WPS/Cayman Islands

T/+1 345 814 7612
M/+1 345 938 7612
E/Email Steven Manning
More articles from this author View profile

Nicholas Quin

Managing Director, Americas/Cayman Islands

T/+1 345 914 4295
M/+1 345 923 4295
E/Email Nicholas Quin
More articles from this author View profile

Nick Reid

Director/Cayman Islands

T/+1 345 814 6862
E/Email Nick Reid
More articles from this author View profile

Related links

Decisions Steps: Determine whether an entity is required to report its RBOsDecisions Steps: Determine a Legal Person's RBOsFAQsCayman Islands beneficial ownership regime: Update and progress towards 1 January 2025August 2024 Beneficial Ownership Advisory

Key Contacts

Get in touch with our team

//
Natalie Curtis
Natalie Curtis

Natalie Curtis

Partner

Hong Kong

T

+852 2596 3357

M

+852 9225 8084

E

Email Natalie Curtis
View profile
Sara Hall
Sara Hall

Sara Hall

Partner

London

T

+44 (0) 2072 204 975

M

+44 (0) 7904 132 128

E

Email Sara Hall
View profile
Louise Denman
Louise Denman

Louise Denman

Senior Counsel

Dubai

T

+971 4 363 7904

E

Email Louise Denman
View profile
Benjamin Twidle
Benjamin Twidle

Benjamin Twidle

Senior Counsel

London

T

+44 (0) 20 7398 4999

M

+44 (0) 7903 044 616

E

Email Benjamin Twidle
View profile
Jason Hung
Jason Hung

Jason Hung

Counsel

Hong Kong

T

+852 2596 3355

M

+852 6973 3340

E

Email Jason Hung
View profile
Daniel Booth
Daniel Booth

Daniel Booth

Managing Director, Asia and Middle East

Hong Kong

T

+852 2596 3334

M

+852 9160 7809

E

Email Daniel Booth
View profile

Get the latest insights and expertise in your inbox 

Fluid ink image
Sign up
logo footer

Connect with us

FacebookFacebook
InstagramInstagram
LinkedInLinkedIn

Employee login

Self Service Password ResetWalkers AnywhereWalkers Sharefile
Legal notices/Cookies policy

All rights reserved - © 2025 Walkers Global