Introduction of Registration Regime for Closed-Ended Funds

This note has been updated since its original publication on 10 February 2020 to reflect further information in CIMA's FAQs, in particular CIMA have confirmed that funds registering before 7 August 2020 will be required to file their 2020 audit, rather than 2021 as originally indicated by the Cayman Islands government.

On 7 February 2020, the Cayman Islands government enacted the Private Funds Law, 2020 (the “Law”). This advisory summarises its key features and likely impact on closed-ended funds and their managers.

While the publication of the Law and certain ancillary regulations have answered certain of the key questions that we identified when the consultation draft of the Law was published, there remain areas where further guidance is anticipated. As any of the matters discussed in this advisory develop in the coming months, we will publish additional advisories and guidance.

Private funds have until 7 August 2020 to complete their initial registration (whether new funds or existing ones). Aspects of the ongoing obligations, described in further detail below, will not take effect until the next financial reporting period of the relevant fund.


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Ashley GunningPartnerT +1 345 914

Ingrid Pierce Global Managing PartnerT +1 345 814
Tim BuckleyManaging PartnerT +1 345 814 4646
Bicrom DasPartnerT +1 345 814
Ashley GunningPartnerT +1 345 914
Rolf LindsayPartnerT +1 345 914
Ed PearsonPartnerT +1 345 814 4528
Caroline WilliamsPartnerT +1 345 914

Daniel WoodManaging PartnerT +971 4 363

Denise WongPartnerT +852 2596

Hughie WongPartnerT +44 (0)20 7220

Thomas GrangerPartnerT +65 6603