Funds that are registered with the Cayman Islands Monetary Authority (“CIMA”), whether under the Private Funds Act (as Revised) or the Mutual Funds Act (as Revised) are subject to ongoing regulatory requirements as set out by CIMA .
CIMA will expect to see a fully compliant AML Manual (and supporting logs and ancillary documents) in place, as well as the following suite of policies:
- An Anti-Money Laundering Manual together with the following supporting items:
- Training Log in respect of all senior staff and directors (specifically in respect of Cayman AML laws) and a training plan for annual training;
- Competent Authority enquiries log;
- Complaints log;
- Declined business log;
- SAR log;
- PEP log; and
- An Annual review of the AML Manual and related policies.
- Data Protection Policy (and privacy notice for investors);
- Operational and Governance Policy; and
- Automatic Exchange of Information (AEOI) Policy.
It may be possible to rely on policies provided by your service providers, however each policy will need to be compliant with CIMA’s requirements, and will need to be formally adopted by the fund in question. Policies should also be reviewed regularly, and the AML Manual in particular should be reviewed on an annual basis.
Further detail on the updates can be viewed on CIMA’s website.
Further information is provided in our Guidance Notes below.
Registration and Continuing Obligations of Section 4(3) Mutual Funds 
Registration and Continuing Obligations of Section 4(4) Mutual Funds
Registration and Continuing Obligations of Private Funds
Should you believe that for any reason your fund does not currently have any of the listed policies in place, then Stuarts would be happy to assist with drafting them and causing them to be adopted by the Fund. Please contact your usual Stuarts attorney if you have any questions, or email one of our experts below.
The 2024 Regulatory Filing Dates can now be viewed.
How Stuarts Can Help
Stuarts Investment Funds and Regulatory teams have extensive experience advising funds and other regulated entities in the Cayman Islands on corporate governance and compliance matters. Through our subsidiaries, Stuarts Corporate Services and Southern Management Services our team of experienced corporate professionals can provide you with a full suite of corporate governance and directorship services including Cayman resident directors and corporate secretarial services, to assist in meeting the ongoing regulatory obligations of your fund and regulated entities in the Cayman Islands.
Please contact Chris Humphries or Jonathan McLean for assistance with your entities’ regulatory compliance obligations or contact us for more information.
Chris Humphries
Jonathan McLean