Registered Persons exempt from beneficial ownership requirements

Changes to the Cayman Islands beneficial ownership provisions will come into force on 29 June 2020 which directly impact Registered Persons.

Those companies that are registered as Registered Persons under the Securities Investment Business Law (Law) will no longer be required to comply with the beneficial ownership obligations under the Companies Law or the Limited Liability Companies Law, as applicable.

Although a Registered Person’s obligation to comply with beneficial ownership ceases, we take this opportunity to remind Registered Persons that they have the following ongoing obligations under the Law (which were not previously imposed on excluded persons):

  • To have at least two directors, managers, partners (as applicable), or one corporate director, that are fit and proper persons
  • To notify CIMA within 21 days of any material change to the information filed with CIMA, including any changes to its senior officers and any change to the ownership, direct and indirect, of the Registered Person
  • To maintain segregation of client funds from its funds and separately account for both

We also remind Registered Persons that CIMA now has substantial enforcement powers to ensure effective regulatory oversight of Registered Persons and their compliance with the obligations under the Law. These powers and oversight were not previously applicable to excluded persons.

Please contact your usual Harneys representative if you would like advice on ongoing compliance with the registered person regime in the Cayman Islands. If you have any other questions, visit