Regulatory 15/15 Podcast September 2026
Cayman Islands Insurance Industry Background • Well-established and leading international insurance centre • Key hub for captive insurance and insurance-linked securities • Long history of international commercial reinsurers operating in the jurisdiction • Deep bench of experienced local service providers focused specifically on the insurance industry • Local service providers have extensive expertise supporting the Cayman Islands' leading investment funds and finance sectors, which is increasingly important given increasing crossover among the various sectors
Private Equity & Reinsurance Cross-Over • Private equity ("PE") has taken a strong interest in investing in reinsurance, including the establishment of new reinsurance platforms • PE firms are already very familiar with the jurisdiction as the leading international funds domicile, making the Cayman Islands the natural home for their insurance investments • The Cayman Islands can service all aspects of the broader transaction structures, across all the product lines (insurance, funds, finance, corporate) • PE-backed transactions are large in value and have dramatically increased the size of the Cayman Islands insurance market as measured by assets • There are 700+ licensed insurers, with US$176+ billion in assets, an increase of US$100+ billion in five years = strong growth of the reinsurance product over the past few years
NAIC Qualified Jurisdiction Application • The Cayman Islands government has applied to the US National Association of Insurance Commissioners ("NAIC") for Qualified Jurisdiction Status ("QJS") • The Cayman Islands reinsurance industry is already well-aligned with US regulatory regimes. Formal recognition of this alignment is the next natural step in the evolution of the Cayman Islands reinsurance market • QJS will further enhance the credibility and regulatory standing of the Cayman Islands • Eligible Cayman Islands reinsurers may apply for Certified Reinsurer status with relevant US state regulators, to reduce the collateral requirements for US-facing reinsurance business
QJS Timeline & Preparation • A final decision on the QJS application is at least a couple of years away • Given the government's commitment to a successful QJS application, significant further resources are expected to be dedicated to enhancing the insurance regulatory regime • The regulatory regime is already well-aligned with US requirements. The most visible immediate changes will most likely be additional staffing and funding for the insurance regulator, the Cayman Islands Monetary Authority ("CIMA") • CIMA needs to grow its resources to keep pace with a rapidly growing and increasingly complex reinsurance market • Industry is actively engaged in discussions with government around regulatory enhancements. All stakeholders are encouraged to participate in shaping the next phase of the Cayman Islands reinsurance market
CRS Compliance Form • DITC requires all Cayman Islands Financial Institutions ("FIs") with CRS reporting obligations to file an annual CRS Compliance Form, which extends to Trustee Documented Trusts • Separate from the CRS account report and Filing Declaration: collects compliance information on account population, due diligence and service-provider arrangements • 2025 reporting cycle: CRS Compliance Form due 15 September 2026 (after the 31 July CRS / FATCA deadline)
CRS Compliance Form • From 2026 onwards: annual deadline moves to 30 June, aligning with the CRS reporting deadline • Filed via DITC Portal by PPoC or authorised Secondary Users; bulk CSV upload available • Covers: FI profile, financial accounts, AML / KYC arrangements, CRS processes, service providers and a declaration • Non-compliance: automatic penalty of CI$10,000 (entities) / CI$4,000 (individuals); primary penalties up to CI$50,000; continuing CI$100/day • Practical steps: confirm FI classification, verify portal access, reconcile data across CRS Report / Filing Declaration / Compliance Form, allow CSV validation time and retain records 6+ years
AML Return for Restricted & Private Trust Companies • CIMA extending AML Return requirement to Restricted Trust Companies (RTCs) and Private Trust Companies (PTCs) • Part of CIMA's risk-based supervisory approach to AML / CFT / CPF • Initial AML Return issued 1 November 2026, requiring data as at 31 December 2025 • Submission deadline: 31 December 2026 • Distributed via CIMA's Strix software to registered contacts (Registered Office, Principal Office, Directors, AMLCO, MLRO, DMLRO and additional contacts)
AML Return for Restricted & Private Trust Companies • RTCs / PTCs should verify CIMA contact information is current before distribution: contact AMLReturns@cima.ky to add contacts • After initial round, RTCs / PTCs join existing TCSP AML Return cycle, with subsequent returns issued 1 June annually • Return covers two sections: AML Inherent Risks and AML Controls • Non-compliance: may amount to criminal offence; admin fines up to CI$1,000,000 (corporate) / CI$100,000 (individual) • CIMA has published a detailed completion guide for PTCs and RTCs
CIMA: Struck & Dissolved Entities • 28 August 2026: CIMA removed entities from its register that had been struck from the General Registry or dissolved • These entities failed to satisfy CIMA's termination requirements • Entity types affected: Mutual Funds (Administered, Limited Investor, Master Fund, Registered), Private Funds and Securities Registered Persons • 100+ entities removed in total • Routine enforcement action: CIMA periodically cleans its register of inactive or non-compliant entities • Firms should check whether any of their structures appear on the list and ensure timely completion of termination processes
Non-Compliant Directors • CIMA Warning Notice dated 31 August 2026 re non-compliant registered directors • Directors failed to maintain registrations under the Directors Registration and Licensing Act, 2014, by not filing required information and paying the annual fee by 15 January • CIMA unable to locate or correspond with these directors • CIMA Warning Notice published publicly to give notice to directors and interested parties
Non-Compliant Directors • Directors have 45 days from 31 August 2026 to make written representations • If no representations, CIMA proposes to cancel registration under s.25(2)(a) of the Act • Key: lack of communication may be considered in fitness and propriety assessments for other regulated roles and future applications • 130+ directors named on the list
Updated CIMA List of Approved Stock Exchanges • List of Approved Stock Exchanges — August 2026 (Extraordinary Gazette No. 60, 21 August 2026) • Three new exchanges added: • Bahamas International Securities Exchange • Baku Stock Exchange • Pakistan Stock Exchange Ltd. • No exchanges removed and no existing entries amended
Regulatory & Financial Services Team Cayman Islands Chris Capewell Partner +1 345 814 5666 chris.capewell@maples.com
Cayman Islands Ellen O'Brien Associate +1 345 814 5377 patrick.head@maples.com
Cayman Islands John Dykstra Partner +1 345 814 5530 john.dykstra@maples.com
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