Financial Services Update – Cayman Islands Government

The Cayman Islands Government Ministry of Financial Services (the "Ministry") released an industry advisory on 21 March 2020. The Ministry addressed a number of matters as part of its business continuity plans in relation to the coronavirus (COVID-19) pandemic.

The announcement includes:

Beneficial Ownership Filings Have One Month Extension
The General Registry is giving a one-month extension for beneficial ownership submissions in the face of the COVID-19 pandemic. The extension goes into effect as of Monday, 23 March and will cease on 20 April 2020.

Economic Substance Obligations Continue
The DITC is aware that COVID-19 may impact travel in 2020, which may in turn affect the ability of some entities to hold their board of directors meetings in Cayman during the year but industry is reminded that the directed and managed requirement is only one element of the ES test.

Filings for Entity Changes Extended
Extensions for 30 days will come into effect for notification of changes to directors and officers, to registered offices and amended memorandum and articles of association (including increases in share capital). These extensions to file pertain to changes which occurred on or after 1 March 2020. Filings will not incur penalties before 30 April 2020.

Mutual Funds Regulations Take Effect
The Mutual Funds (Annual Returns) (Amendment) Regulations, 2020 is now in effect after being gazetted on Tuesday, 17 March 2020.

Virtual Assets and Administrative Fines Consultations Extended
The deadlines for responding to consultations relating to (i) the development of a regulatory framework for virtual assets service providers and (ii) the administrative fines regime are extended to 8 April and 6 April respectively.

Click here to view the Ministry's complete industry advisory.


Please contact your usual Walkers contact with any questions.