THE
Podcast
REGULATORY 15/15
September 2025
Content
• Department for International Tax Cooperation ("DITC") Update
• Cayman Islands Monetary Authority ("CIMA") Update
• Office for Strategic Action on Illicit Finance ("OSAIF")
• National Risk Assessment ("NRA")
• AML / CTF / CPF / Sanctions Training
• Virtual Asset Service Providers ("VASP") Update
• Consultations
• Tokenised Funds
• Common Reporting Standard ("CRS")
• Crypto Asset Reporting Framework
Introduction
Introduction to the 15/15
• A 15-minute summary of the latest developments in the regulatory laws of the Cayman Islands released on the 15th day of every month
• A copy of the previous 15/15 released on 15 June can be accessed on our website: Maples 15/15
• Comments and suggestions to format of the 15/15 are always welcome –please email speakers directly
DITC Update
DITC Updates Bulletin
• In late June 2025, the DITC published a new Updates Bulletin
• The DITC Portal is open for 2024 CRS and FATCA submissions
• In addition to upcoming filing deadlines, the Bulletin also reminded Financial Institutions ("FIs"):
• Once a Participating Jurisdiction Person becomes a Reportable Jurisdiction Person, there is an obligation on the FI to collect the TIN of that Account Holder or Controlling Person. If the TIN is available in the FIs records it must be reported, as the TIN is a mandatory field.
Where the FI does not already have TIN in its records, it must make reasonable efforts to obtain and report the TIN by the end of the second calendar year following the year in which the accounts were identified as Reportable Accounts
Country-by-Country Reporting
• On 29 August 2025, Country-by-Country Reporting ("CbCR") became live on its DITC portal
• Multinational Enterprise Groups (MNE Groups) with Cayman Islands constituent entities must re-register on the new portal by 30 November 2025
• Updated CbCR Guidelines and DITC Portal User Guide (v. 9.5) have also been released
• CbCR reporting functionality is expected on the portal by November 2025
CRS Compliance Form
• The CRS Compliance Form is due today, 15 September
• The form collects data on each FI's non-reportable accounts and business nature, including regulatory status, audited financial statements, AML compliance, service providers, and CRS policies
DITC Penalty Notices
• We are aware of a recent uptick in the DITC's issuance of penalty notices for non-compliance in relation to economic substance ("ES") and in relation to the CRS Regulations
• Entities must ensure correct classifications and timely filings to avoid significant fines
• Maples Group is pleased to assist with ongoing ES and CRS compliance, as well as advice in relation to breaches and penalty notices
CIMA Update
Directors' Amnesty Scheme
• CIMA launched a one-time Non-Compliant Directors' Amnesty Scheme ("the "Scheme") for directors with over two years of unpaid fees as of 31 August 2025
• Eligible directors can settle outstanding fees and penalties at a discounted rate from 16 September to 15 October 2025
• Directors under investigation or enforcement are not eligible
• Applications under the Scheme must be made through the Directors' Gateway Portal at https://gateway.cimaconnect.com
Inspections
• CIMA continues detailed inspections of SIBA Registered Persons (RPs) and banking licensees
• Inspections include review of records, policies, risk assessments, and interviews with key personnel
• Breaches are reported in CIMA's Inspection Report, and remedial actions are required within set timeframes
• Maples Group offers support with compliance and inspections
Fraudulent Notices
• On 27 August 2025, CIMA warned of phishing emails from the domain @cima.ky.zitirxsend.com
• Legitimate CIMA emails end with @cima.ky
• Recipients should not click on links or attachments and should report suspicious emails to abuse@cima.ky
CIMA Relocation
• Effective 30 June 2025, CIMA has relocated to:
2nd Floor, Pavilion East, Cricket Square
205 Elgin Avenue George Town, Grand Cayman
• Telephone numbers and email addresses remain unchanged
• The Currency Division remains at the Government Administration Building
OSAIF
OSAIF
• On 12 August 2025, the Cayman Islands Government ("CIG") established OSAIF as a centralised authority to align with international standards, especially Financial Action Task Force ("FATF")
• OSAIF is part of the Ministry of Financial Services and Commerce and integrates the former Anti-Money Laundering Unit
• OSAIF oversees the national coordination team preparing for the 2027
Caribbean Financial Action Task Force ("CFATF") evaluation in December 2027
NRA
NRA
• On 21 August 2025, the Cayman Islands launched its 2025-2026 NRA
• The NRA helps countries identify and address financial crime risks and shapes risk-based policies
• Completion of the NRA is key for the Cayman Islands' upcoming 5th Round CFATF Mutual Evaluation in December 2027
• The 2025-2026 NRA is being coordinated by OSAIF, with initial meetings held during the launch week
Reminder
AML / CTF / CPF / Sanctions
Training Reminder
• The Anti-Money Laundering Regulations (as revised) ("the AML Regulations") apply to anyone conducting "relevant financial business in or from the Cayman Islands"
• Financial service providers must train employees on AML / CTF / CPF procedures and the AML regime annually
• Maples Group offers comprehensive and cost-effective online AML / CTF
/ CPF / Sanctions training for clients
VASP Update
Virtual Asset (Service Providers) (Amendment) Act
• On 27 June 2025, CIG passed the Virtual Asset (Service Providers) (Amendment) Act, 2025, addressing tokenised funds (not yet in force)
• The Act amends the definition of "issuance of virtual assets" and excludes certain tokens and interests
• Amendments will apply retroactively to prior tokenisation
VASP Application Form
• Effective 8 July 2025, the VASP application form, APP 101-84-05, has been amended to streamline the process
• All new VASP applications from 8 July 2025 must use the updated form from the REEFS portal
• Applications in progress as of 8 July 2025 may use the previous form
• The Completion Guide has also been updated to version 3.0
New VASP Regulatory Measures
• On 10 September 2025, CIMA published new regulatory measures for VASPs, including rules and procedures for cancellation of licences, registrations or waivers
• Key updates from the Consultation versions to note:
• The Rule and Regulatory Procedure now address both waivers and cancellation of licences / registrations
• Material changes must be reported to CIMA within 15 days of the VASP's awareness
• Clarified requirements for confirmations from the VASP Compliance Officer and stakeholders
• Increased flexibility for submitting final audit reports to CIMA, based on business size, nature, and complexity
• These regulatory measures are now in effect
Consultations
Tokenised Funds
• On 26 August 2025, the Ministry of Financial Services and Commerce ("the Ministry") distributed a Consultation on 2025 Amendments to Introduce Tokenised Funds
• Proposed amendments affect the Mutual Funds Act (as revised), the Private Funds Act (as revised) and the Virtual Asset (Service Providers) Act (as revised)
• The legislation introduces new definitions, new requirements for administrators and operators, and clarifies rights and transfer requirements for digital tokens
• Responses to Consultation are due by 5pm on 12 September 2025
Crypto Asset Reporting Framework
• On 13 August 2025, the Ministry distributed the Crypto-Asset Reporting Framework ("CARF") and draft CARF Regulations, developed in line with the OECD's framework approved in August 2022 to address crypto-asset risks
• CARF, similar to the CRS, establishes a global tax transparency framework for the automatic exchange of tax information on crypto-asset transactions between jurisdictions, enhancing cooperation among tax authorities, combat tax evasion and money laundering
• The draft CARF Regulations outline the Cayman Islands' proposed legal framework, with plans to enact the regulations by the end of 2025 and begin CARF exchanges in 2027.
• Responses to the Consultation are due by 5pm on 15 September 2025
• On 13 August 2025, the Ministry distributed a Consultation on Amendments to the CRS with draft CRS Regulations
• All CRS jurisdictions must implement OECD amendments from June 2023
• The CIG plans to enact the amended CRS Regulations by end of 2025
• Responses to Consultation are due by 5pm on 15 September 2025
This presentation was presented on, and is only accurate to 15 September 2025. The information within this presentation is provided for general guidance only, is not intended to be comprehensive and does not constitute legal advice or give rise to an attorney / client relationship.
Specialist legal advice should be taken in relation to specific circumstances. If you require legal advice, please reach out to your usual Maples and Calder contact.
Published by Maples and Calder (Cayman) LLP.
2025
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