VASP, Mutual & Private Funds Amendment Acts Enacted

Parliament has now enacted a coordinated package of amendments to the Virtual Asset (Service Providers) Act, the Mutual Funds Act and the Private Funds Act to give clearer statutory treatment to tokenised fund structures in the Cayman Islands.

The amendments, published in the Legislation Gazette on 24 March 2026, amend the Virtual Asset (Service Providers) Act (2024 Revision) and are now in force. In substance, the VASP amendment draws a clearer boundary between Cayman’s virtual asset regime and its existing funds regime by confirming that the issuance of digital equity tokens by regulated tokenised mutual funds, and digital investment tokens by regulated tokenised private funds, is not treated as a “virtual asset issuance” for VASP purposes. It also aligns core definitions, including digital equity tokens, digital investment tokens, tokenised mutual funds and tokenised private funds, with the Mutual Funds Act and Private Funds Act, and repeals the prior 2025 amendment Act so the framework sits in one cleaner, updated legislative package.

The related Mutual Funds (Amendment) Act, 2026 and Private Funds (Amendment) Act, 2026 complement that change by building out the bespoke regulatory framework for tokenised mutual funds and tokenised private funds within Cayman’s existing CIMA-supervised funds legislation, rather than leaving those structures to sit ambiguously within the VASP regime. Taken together, the three amendments are aimed at legislative consistency, stronger investor protection and clearer AML / CFT oversight, while also making it easier for market participants to structure tokenised funds in the Cayman Islands with greater certainty as to which regulatory regime applies.

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