Updates to the Cayman Islands Beneficial Ownership Regime March 2018

The Cayman Islands beneficial ownership regime (“Regime”), which came into force on 1 July 2017, requires Cayman Islands companies and limited liability companies (together “Companies”) to establish and maintain beneficial ownership registers unless they fall within an exemption to the Regime. Partnerships and foreign companies are out of scope.

Amending legislation which came into force on 13 December 2017 refines the categories of exemption from the Regime so that certain Companies which would have been in scope now fall within an exemption and, conversely, certain Companies which would have fallen within an exemption are now in scope.

Also, a Company that claims an exemption from the Regime is now required to provide its corporate services provider (“CSP”) with written confirmation of the specific exemption. This requirement is new.

Details of the specific information to be included in the written confirmation are now available, in the form of amending regulations which were gazetted on 2 March 2018 (namely the Beneficial Ownership (Companies) (Amendment) Regulations, 2018 and the Beneficial Ownership (Limited Liability Companies) (Amendment) Regulations, 2018) (together, the “Amending Regulations”).

This advisory summarises the key action points for Companies falling within an exemption. Please see our previous Client Advisories of 10 April 2017 and 5 January 2018 for further details in relation to the Regime more generally.


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