CIMA Launches Prudential Information Survey for SIBA Registered Persons

Cayman Islands Regulatory Round Up - Winter 2025/26

The round-up provides a concise yet thorough summary of regulatory developments relevant to financial service providers (FSPs) and other stakeholders in the Cayman Islands. It highlights key legislative changes, publications by the Cayman Islands Monetary Authority (CIMA), updates on financial sanctions, and anticipates upcoming changes through "horizon scanning”. Links to the underlying CIMA publications, as well as related Appleby published briefings and e-alerts are available throughout this document. The information provided is “as of” 28 May 2025.

Simon Raftopoulos, Menelik Miller, Miriam Smyth, Maree Martin, Martin Byers

Preparing for and Managing a CIMA Onsite Inspection

The Cayman Islands Monetary Authority (CIMA) is empowered, under the Monetary Authority Act and certain other regulatory laws, to inspect regulated financial service providers (FSP) in the Cayman Islands such as banks, trust companies, administrators, investment managers and virtual asset service providers for compliance with applicable regulatory frameworks. CIMA routinely conducts onsite inspections of such regulated entities – which can be full-scope (involving a review of all areas of a regulated entity's business operations) or thematically focused on specific areas such as corporate governance and/or internal controls, policies and procedures pertaining to AML/CFT/CPF. With the breadth and number of onsite inspections carried out by CIMA having increased through 2024 and 2025 we consider, in this briefing: (i) the CIMA onsite inspection process; (ii) the latest feedback available from CIMA in respect of inspections conducted to date; and (iii) some frequently asked questions in relation to CIMA onsite inspections.

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Martin Byers, Simon Raftopoulos, Peter Colegate, Maree Martin, Menelik Miller

Injunctive Relief in Another Form? Cayman Court's Jurisdiction to Appoint JPLs Despite Ongoing Arbitration

In Peakwave Investment Management Ltd v Energy Evolution GP Ltd [link],[1] the Grand Court confirmed that it has jurisdiction to appoint provisional liquidators notwithstanding the fact that the company’s shareholders are engaged in an arbitration over its affairs, as mandated by a binding arbitration agreement. This article considers the decision and its implications.

David Lee, Will Porter

When the Court intervenes… and when it does not: Grand Court Reaffirms Limited Curial Intervention in Support of Foreign Arbitrations

The Financial Services Division of the Grand Court’s judgment in In the matter of A v B & C (FSD 270 of 2025) provides a timely reminder of the proper boundaries between national courts and international arbitration tribunals in respect of the grant of interim relief. The decision underscores the Cayman Islands' commitment to the principle of limited curial intervention and confirms that the Court’s powers under section 54 of the Arbitration Act 2012 are ancillary to the arbitral process and are only to be exercised when the tribunal cannot provide effective relief itself. The judgment helpfully sets out clear parameters for those seeking ancillary relief and highlights that the Cayman courts will support arbitration proceedings without supplanting them.

David Lee, Zuhair Farouki

Recusal For Apparent Bias Is Not A New Frontier

In Re New Frontier Health Corporation,[1] Justice Doyle decided to recuse himself, such that he would not hear the trial listed to commence weeks later, on the basis that he made findings in his recent Re 51job Inc judgment, as to the reliability and credibility of the same two experts who would give evidence at the New Frontier trial. The New Frontier judgment represents a further endorsement by the Cayman courts of the fundamental maxim that justice must not only be done, but must be seen to be done.

Andrew Jackson, Charlotte Walker

The New Crypto-Asset Reporting Framework – Relevance for Cayman Investment Funds

The Tax Information Authority (International Tax Compliance) (Crypto-Asset Reporting Framework) Regulations, 2025 (CARF Regulations) came into effect on 1 January 2026 and provide for the collection, reporting and automatic exchange of information on transactions in crypto-assets.  The CARF Regulations will operate in a similar fashion to the existing Cayman Common Reporting Standard (CRS) regime which facilitates the automatic exchange of financial account information.  For information on recent changes to the CRS, please see our December advisory here.

Matt Mulry, Martin Byers, Peter Colegate, Maree Martin

Compulsory ADR in Cayman: Court Confirms It Has Teeth But Declines to Bite

David Lee, Zuhair Farouki

Aquapoint LP v Fan: Privy Council Confirms Equitable Constraints Can Override Strict Contractual Rights in Cayman ELP Winding Up

In its recent judgment in Aquapoint LP (in Official Liquidation) v Fan,[1] the Privy Council upheld the judgments of the Grand Court and Cayman Islands Court of Appeal (CICA). The ruling confirms that the exercise of strict legal rights under a limited partnership agreement – even one containing detailed contractual terms and “entire agreement” clauses – can nevertheless be subject to equitable considerations in certain circumstances. Where those equitable considerations arise, they may justify the winding up of an exempted limited partnership on the “just and equitable” basis. Appleby acts for the joint official liquidators of Aquapoint; for further details on the background of this case, see Appleby’s previous article here.

David Lee, Susan Fallan, Charlotte Walker, Jae Shin

JCPC Guidance on Remuneration Applications

David Lee, Daniel Coelho