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Update on the beneficial ownership reporting regime in the Cayman Islands - ongoing obligations and developments

Apr 15, 2025

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

Key takeaways

  • Entities have ongoing obligations to keep beneficial ownership information up to date.
  • Legislative developments have clarified what information needs to be reported for trusts and deemed beneficial owners.
  • Regulations gazetted previously are all now in effect.

Update on the beneficial ownership reporting regime

Ongoing obligations and developments

Changes to the beneficial ownership reporting regime took effect on 31 July 2024, with enforcement relating to the new requirements commencing in January 2025. 

Many entities that previously had few or no obligations have recently had to take steps to comply, in particular identifying any beneficial owners and filing monthly reports. Now that the monthly reporting process is well bedded in, this advisory aims to provide a brief reminder of the ongoing obligation of in-scope entities ("Legal Persons") to keep information up to date, as well as to highlight the latest legislative developments. 

Do Legal Persons which benefit from an alternative route to compliance have an obligation to file updated information?

Where a Legal Person that benefits from an alternative route to compliance becomes aware that any information in the written confirmation of its alternative route to compliance (see below) has ceased to be true, it must, within 30 days, provide its corporate services provider ("CSP") with an amended written confirmation correcting the erroneous information and providing any additional information required, and instruct its CSP to file the amended confirmation with the competent authority.

By way of reminder, the information in the written confirmation of a Legal Person’s alternative route to compliance is as follows:

• for CIMA registered investment funds, the CSP must provide the contact details of a Contact Person;
• for Legal Persons licensed under a Cayman Islands regulatory law, the CSP must provide the regulatory law under which the Legal Person is licensed;
• for Legal Persons listed on the Cayman Islands Stock Exchange or an approved stock exchange, the CSP must provide the name and jurisdiction of the stock exchange; and
• for Legal Persons which are subsidiaries of an entity listed on the CSX or an approved stock exchange, the CSP must provide details of its parent's listing.

What ongoing obligations to file updated information apply to Legal Persons which do not benefit from an alternative route to compliance?

If a Legal Person becomes aware of a relevant change, it must as soon as reasonably practicable (and no later than 30 days after it learns of the change or had reasonable cause to believe that the change had occurred), request its CSP update the register accordingly. For this purpose, a "relevant change" will occur if the registrable beneficial owner ("RBO") ceases to be a RBO, or a new RBO is identified due to changes in a Legal Person's direct or indirect ownership or control or there is a change in the particulars the Legal Person has previously provided (see below). The Legal Person must also update its CSP if the RBO is deceased and has ceased to be a RBO. By way of reminder of the particulars, please see the table below.

Further developments

Clarification of the details required of DBOs and CTs as discussed above was contained in amendments to the Beneficial Ownership Transparency Act and related regulations gazetted on 27 February 2025, following consultation with industry.
Additional legislative developments, as set out in our previous advisory came into effect in February 2025 relating to: (i) access to beneficial ownership information by foreign beneficial ownership competent authorities subject to certain restrictions; and (ii) the ability for a limited category of persons to apply to the Registrar for access to beneficial ownership information in respect of a specific Legal Person where they have a legitimate interest and there is evidence that the Legal Person is linked to money laundering and its predicate offences or terrorist financing. Also in February, regulations came into effect which provide a mechanism whereby an individual beneficial owner can apply to the Registrar for their beneficial ownership information to be withheld from such disclosure where the applicant reasonably believes that the disclosure of such information will place the applicant or an individual living in the same household as the applicant at serious risk of kidnapping, extortion, violence, intimidation or any similar danger or serious risk. 

Next steps

Please view our detailed advisory and FAQs for an overview of the BORR. 

Our extensive beneficial ownership reporting regime compliance experience means we are always on hand to help. Please get in touch with one of the contacts listed below or your usual Walkers contact if you wish to discuss.
Regulatory & ComplianceCayman Islands

Authors

Lucy Frew profile image

Lucy Frew

Partner/Cayman Islands

T/+1 345 814 4676
M/+1 345 939 4676
E/Email Lucy Frew
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Andrew Howarth

Andrew Howarth

Partner/Cayman Islands

T/+1 345 814 4561
M/+1 345 926 4561
E/Email Andrew Howarth
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Related links

News: Changes to the beneficial ownership reporting regimeAugust 2024 Beneficial Ownership AdvisoryFAQsDecision Steps: Determine a Legal Person's RBOsDecision Steps: Determine whether an entity is required to report its RBOs

Key contacts

Get in touch with our team

Lucy Frew
Lucy Frew profile image

Lucy Frew

Partner

Cayman Islands

T

+1 345 814 4676

M

+1 345 939 4676

E

Email Lucy Frew
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Andrew Howarth
Andrew Howarth

Andrew Howarth

Partner

Cayman Islands

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+1 345 814 4561

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+1 345 926 4561

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Email Andrew Howarth
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Natalie Curtis
Natalie Curtis

Natalie Curtis

Partner

Hong Kong

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+852 2596 3357

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+852 9225 8084

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Sara Hall

Sara Hall

Partner

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+44 (0) 2072 204 975

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Louise Denman
Louise Denman

Louise Denman

Senior Counsel

Dubai

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+971 4 363 7904

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Benjamin Twidle
Benjamin Twidle

Benjamin Twidle

Senior Counsel

London

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+44 (0) 20 7398 4999

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Steven Manning
Steven Manning

Steven Manning

Chief Executive Officer – WPS

Cayman Islands

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+1 345 814 7612

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+1 345 938 7612

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Nick Reid

Nick Reid

Director

Cayman Islands

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+1 345 814 6862

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Colm Dawson
Colm Dawson

Colm Dawson

Partner

Cayman Islands

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+1 345 914 6384

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Ian Mason
Ian Mason

Ian Mason

Partner

Cayman Islands

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+1 345 814 4600

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+1 345 916 4600

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Juliana Tang
Juliana Tang

Juliana Tang

Partner

Cayman Islands

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+1 345 814 4612

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+1 345 936 4612

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Email Juliana Tang
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