The Directors Registration and Licensing Law, 2014 (the
"Law") came into force on 4 June
The Law requires that the directors (both natural persons and
corporate directors) of "covered entities"2 be
either registered or licensed with the Cayman Islands Monetary
Authority ("CIMA") in accordance with
Annual Fees and Information Update for Registration or
On or before 15 January 2015 each registered or licensed
director (whether they are a natural person or corporate director)
must provide CIMA with information in a prescribed form and pay
their annual fee for 2015. Failure to pay the annual fee by 15
January 2015 will give rise to a penalty surcharge of one-twelfth
of the annual fee for every month or part of a month that the fee
The annual fees are as follows:
In respect of a registered director, CI$700 (US$853.65);
In respect of a licensed professional director, CI$3,000
In respect of a licensed corporate director, CI$8,000
We understand that CIMA plans to send an email to all
registered/licensed directors in December 2014 reminding them of
the requirement to pay the annual fee and provide the required
information (we understand that CIMA will use the email addresses
provided by each director).
The payment of annual fees and the provision of information are
expected to be processed online through CIMA's
We understand that CIMA's website will be "open"
to allow the payment of annual fees once CIMA has sent out the
email alert to all directors reminding them of the annual fee
requirements. In any event, we recommend that registered and
licensed directors log on to CIMA's dedicated website early in
the new year to complete the annual requirements in advance of 15
This client update is intended primarily as a calendar reminder
to directors that are registered or licensed under the Law to
attend to the annual requirements. For a complete discussion of the
registration and licensing requirements of the Law please see our
previous update entitled
CIMA Requires the Registration or Licensing of Certain Types of
Directors dated 5 June 2014.
De-registration under the Law
Directors who do not pay the annual fee on or before 15 January
2015 will be charged a penalty surcharge of one-twelfth of the
annual fee for every month or part of a month that the fee remains
unpaid. Failure to pay the annual fee does not result in the
de-registration of a director under the Law. If a director wishes
to de-register he may surrender his registration upon application
to CIMA in the prescribed form and upon payment to CIMA of a
de-registration fee of CI$600 (approximately US$732). If a director
is considering de-registration and is able to do so prior to year
end, he will need to have completed the process prior to 31
December 2014 in order to avoid the 2015 fees becoming due and
1. With the exception of certain provisions of the Law
regarding "capacity" of directors, which remain to be
brought into force.
2. A "covered entity" is (i) a company
regulated by CIMA as mutual funds under the Mutual Funds Law (2013
Revision); or (ii) a company registered with CIMA as an
"excluded persons" under certain heads of the Securities
Investment Business Law (2011 Revision)
("SIBL") (specifically, paragraphs 1 and
4 of the Fourth Schedule to SIBL – essentially managers of
group companies and those under the "investment manager"
3. Note that the annual fee requirement is based on the
calendar year, but late payment penalties are not applied until 15
January each year.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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During a recent appearance on BBC, Cayman Finance CEO Jude Scott
highlighted the Cayman Islands' dedication to upholding the
standards and expectations of a premier financial jurisdiction
through transparency and a strong compliance culture.
Gibraltar implemented Protected Cell Company legislation in 2001 and was the first European jurisdiction to do so. Since then Malta has implemented a PCC Act and the UK itself has introduced its own regime for Open Ended Investment Funds.
Any copies of records provided by the firm must be provided in an unencrypted form so that they can be easily analysed when requested by the client, competent authority, or other competent third party.
Investment funds with high net worth individuals as investors will need to have a client agreement with their high net worth investors.
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