Cayman's new beneficial ownership law brings partnerships in and removes most exemptions
The Cayman Islands' Beneficial Ownership Transparency Act, 2023 came into force on 31 July 2024, replacing the earlier beneficial ownership rules with a single Act. Exempted limited partnerships and limited partnerships are covered for the first time, and many previously exempt entities must now identify their registrable beneficial owners. Corporate service providers file the information with the Registry at least monthly, and enforcement began in January 2025.
The Beneficial Ownership Transparency Act, 2023 was gazetted on 15 December 2023 and brought into force on 31 July 2024 with its regulations and guidance.
What changed
- Scope: exempted limited partnerships and limited partnerships are in scope for the first time. Trusts and registered foreign companies remain out of scope.
- Fewer exemptions: entities such as general partners, carry vehicles and special purpose vehicles that were exempt before must identify their registrable beneficial owners.
- Alternative route: funds registered with the Cayman Islands Monetary Authority can name a contact person instead, and regulated or listed entities and their subsidiaries can confirm their status in writing.
- More data: nationality, ID document details and the nature of each owner's ownership or control.
- Filing: corporate service providers deposit the information with the Registry at least monthly. Entities must update their provider within 30 days of a change.
- Penalties: administrative fines of CI$5,000 per breach plus CI$1,000 a month, up to CI$25,000, and criminal fines up to CI$100,000. An entity that doesn't pay a fine can be struck off.
- Enforcement of the new requirements began in January 2025.
Who is affected
Cayman companies, LLCs and partnerships, their general partners and their corporate service providers.
Later developments
Legitimate-interest access to the register began on 28 February 2025. See our coverage.