Appleby Regulatory and Compliance (ARC) - Cayman Islands

Appleby Regulatory and Compliance (ARC) in the Cayman Islands provides practical advice to clients faced with new, unfamiliar, confusing and time-consuming regulatory obligations.

AML Compliance

Relevant financial businesses are required to maintain and adhere to adequate compliance and anti-money laundering policies and procedures. ARC can help you prepare AML policies tailored to your business, or review existing policies to ensure that they meet current requirements. In addition to ensuring that the right policies are in place, we can assist with an audit and gap analysis, to ensure that systems and processes are actually meeting the needs of your business. ARC can procure the appointment of the necessary AML and Compliance officers in Cayman. We provide training to your staff and officers, and update you when there are changes to the law, regulations or applicable deadlines.

FATCA and CRS Solutions

FATCA and CRS impose regulatory and reporting obligations on many Cayman entities. ARC can assist with reviewing your existing processes, advising on the configuration of your reports, and ensuring that you have the right appointments in place for compliance.

Economic Substance Analysis and Compliance

Cayman’s economic substance legislation requires that relevant entities conducting relevant activities must have a certain level of presence in the Islands. All Cayman entities need to think about whether or not they are in scope of the economic substance regime. Even if an entity is not required to meet the test for compliance, it still has filings to make. ARC has developed fast, cost-effective tools to assist you with determining whether or not you have compliance obligations, and our legal and regulatory experts can help you with all aspects of compliance.

Privacy and Data Protection

There are now data protection laws in more than 120 countries around the world. Data is commonly viewed as one of the most valuable commodities in today’s global digital economy. Protecting those assets is understandably a priority for governments, businesses and individuals alike. The increasing complexity of regulation and the meteoric rise of technology, together with cyber security concerns and international data sharing regimes (such as FATCA and the OECD’s CRS and CbC reporting standards) make the protection and use of data more complex than ever before. ARC can assist with data protection policies, audits, gap analysis and systems configuration. Our cyber-security experts offer practical, detailed solutions to reduce risks. Responding to data subject access requests requires advanced planning, and we can help you prepare and respond in a timely and efficient manner.

Corporate Regulatory Services

Regulated entities in the Cayman Islands face a minefield of filing requirements, shifting deadlines, and time-sensitive demands. ARC can assist in configuring your internal policies and procedures to align with regulatory filing obligations, ensuring that your business can meet all of its obligations painlessly. Emerging sectors, such as virtual asset service providers and cryptocurrency platforms, are entering a regulatory landscape that is evolving quickly and constantly. ARC’s experts have been at the leading edge of legislative and regulatory developments in Cayman and can help you prepare not just for what your business needs to do today, but for what is likely to come tomorrow.

Regulatory Enforcement and Contentious Matters

Cayman Islands’ regulators and competent authorities are empowered to undertake audits of regulated businesses, order remediation objectives and impose fines for regulatory and AML breaches. ARC’s legal experts can assist with negotiations with these authorities and to advise on your best defence.

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CIMA’s 2026 Reinsurance Thematic Review: Focus Points for Boards

The Cayman Islands Monetary Authority (CIMA) has published its 2026 Thematic Review of Reinsurance Companies (Thematic Review). This reflects fieldwork conducted by CIMA between mid-2025 and Q1 2026 at selected Class B(iii) and Class D licensed reinsurers. The focus being on compliance with the Insurance Act (as revised) and other applicable legislation, regulations, rules and statements of guidance as issued by CIMA centering around stress-testing, cash flow testing frameworks, capital and collateral adequacy management, and corporate governance. Corporate governance weaknesses account for 68% of all findings with the remaining 32% spread across stress-testing, cash flow testing capital and collateral adequacy. Notwithstanding these findings, CIMA has noted several good practices across all areas including, importantly, comprehensive risk management frameworks covering key risk areas and strong capital and collateral adequacy monitoring processes. With Cayman’s reinsurance sector having grown to an institutional scale, and over 110 licensed reinsurers writing in the order of US$30 billion in annual premiums against over US$100 billion in assets, this latest Thematic Review demonstrates development in CIMA’s supervisory expectations of Cayman’s licensed reinsurers. It represents a reflection of the jurisdiction’s increasingly sophisticated and maturing reinsurance market and reinforces that CIMA’s expectations align closely with the standards that onshore counterparty cedants, rating agencies and US state regulators already expect. We take this opportunity to review certain of the key findings alongside CIMA’s cross-sectoral 2026 Thematic Review on Outsourcing, note some of the good practices highlighted by CIMA and make some associated recommendations for Cayman reinsurers.

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CIMA Enforcement Action in Focus: Reminders and Recommendations

The Cayman Islands Monetary Authority (CIMA) has recently published a number of Enforcement Notices that provide helpful context for regulated entities, including Licensees and Registered Persons under the Securities Investment Business Act (Revised) (SIBA), seeking to understand and meet their ongoing regulatory obligations in the Cayman Islands. In early June 2026, CIMA exercised its enforcement powers under SIBA Section 17 to cancel the registrations of several SIBA Registered Persons on the basis that it had reasonable grounds to believe that such Registered Persons had failed to meet certain key regulatory obligations. The Appleby Team takes this opportunity to review the relevant findings and CIMA enforcement action; and to highlight certain key obligations that attach to regulated entities in the Cayman Islands.

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Important Cayman Islands Industry Advisory: Common Reporting Standard 2.0 and Economic Substance Updates

Further to the introduction of the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 (the CRS Amendment Regulations or CRS 2.0), the Cayman Islands Department for International Tax Cooperation (DITC) has issued an Industry Advisory flagging certain key updates in respect of Common Reporting Standard (CRS) and Economic Substance (ES) reporting in the Cayman Islands. Cayman Financial Institutions will be required file 2025 CRS Returns and Declarations by 31 July 2026, ahead of the online DITC Portal’s closure to facilitate its transition to XML Schema v3.0. ES courtesy reminders (which have historically been sent by email to designated Responsible Persons in advance of annual ES reporting deadlines) will no longer be issued such that Relevant Entities will need to independently track such deadlines themselves. Updated Individual and Entity CRS Self-Certification forms, aligned with CRS 2.0, are now available online via the DITC website.

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