Welcome to the Cayman Islands Regulatory Round Up: March 2025 – May 2025
The round-up provides a concise yet thorough summary of regulatory developments relevant to financial service providers (FSPs) and other stakeholders in the Cayman Islands. It highlights key legislative changes, publications by the Cayman Islands Monetary Authority (CIMA), updates on financial sanctions, and anticipates upcoming changes through "horizon scanning". Links to the underlying CIMA publications, as well as related Appleby published briefings and e-alerts are available throughout this document. The information provided is "as of" 28 May 2025.
In this edition we cover:
- RECENT FILINGS DEADLINES
- KEY LEGISLATIVE DEVELOPMENTS
- Cayman Islands Monetary Authority (CIMA) publications;
- FINANCIAL SANCTIONS
- 2025 HORIZON SCANNING
- PUBLISHED BRIEFINGS AND E-ALERTS
- HOW WE CAN HELP
Links to the underlying CIMA and DITC publications, as well as related Appleby published briefings and e-alerts are available throughout this document. The information provided is "as of" 30 May 2025.
Recent Filings Deadlines
30 April 2025: Deadline for DITC registration of new entities formed in 2024 that are financial institutions under CRS and FATCA.
Upcoming filing deadlines
30 June 2025: Filing due with CIMA for audited financial statements and FAR forms for mutual funds and private funds with a financial year-end of 31 December 2024.
31 July 2025: Deadline for CRS and FATCA reporting to the Department for International Tax Cooperation (DITC) for the reporting year ending 31 December 2024.
KEY legislative DEVELOPMENTS
Virtual Asset Service Providers Regime
Certain provisions of the Virtual Asset (Service Providers) Act, 2020 and the Virtual Asset (Service Providers) (Amendment) Act, 2024 were brought into force on 1 April, 2025. See our previous Regulatory Round Up (available here) and our publication – Snapshot of Recent Updates to the Virtual Assets Regime in the Cayman Islands for further information.
CIMA has made available a virtual asset service providers FAQs page on its website (available here).
Common Reporting Standard lists of Reportable and Participating Jurisdictions
On 31 March 2025 the list of reportable and participating jurisdictions were published in the Cayman Islands Gazette (available here). The list of participating jurisdictions now includes Armenia, Georgia, Kazakhstan, Moldova and Ukraine and the list of reportable jurisdictions such that Saint Kitts and Nevis has been added for reports due in 2025 onwards; Cameroon and Mongolia have been added for reports due in 2026 onwards and Tunisia has been included for reports due in 2026 onwards (as opposed to 2025 onwards).
CIMA publications
A series of notices and circulars were issued by CIMA between March 2025 and May 2025:
March 2025 – CIMA issued a notice (available here) urging the public to be vigilant against financial scams and fraudulent individuals falsely claiming to act on behalf of CIMA.
April 2025 – CIMA issued a notice (available here) clarifying that gate.io and Gate Global Corp are not, and have never been, registered, licensed, regulated or otherwise authorised by the Authority to conduct virtual asset service provider business in or from within the Cayman Islands.
April 2025 – CIMA issued a supervisory information circular (available here) regarding the licensing of new virtual asset service providers and those that are currently registered with CIMA to undertake virtual asset custody and virtual asset trading platform services in or from within the Cayman Islands and other amendments to the Virtual Asset (Service Providers) Act, that came into effect on 1 April 2025.
April 2025 – CIMA issued a revised list of Approved Stock Exchanges for the purposes of the Regulatory Acts, effective 22 April, 2025 (available here). Appleby was instrumental in obtaining approval for the Toronto TSX Venture Exchange to be added to this list.
May 2025 – CIMA issued a supervisory information circular (available here) setting out CIMA's findings from inspections conducted for registered persons under the Securities Investment Business Act conducted during the period 1 January 2022 to 31 March 2024.
Financial sanctions
General Licence 2025/0001 (Legal Services): The license permits an Attorney or Law Firm who has provided legal advice to a person designated under wither the Russia or Belarus regime to receive payment from that designated person without a specific licence issued by the Governor provided the terms of the licence are met. A copy of the license, which expires on 28 October 2025 is available here. The previous license in respect of legal fees GL/2024/0002 expired on 28 April 2025. The provisions of GL2025/0001 differ from the previous general licenses (GL/2023/0003, GL2024/0001 and GL/2024/0002); in particular the Attorney's fees and expenses caps have been reset and where an Attorney or Law firm has not received Attorney's fees from or on behalf of a designated person under this licence, expenses of up to US$60,000 may be paid in relation to a designated person per Attorney or Law Firm instructed for the duration of the general licence.
2025 Horizon SCANNING
In this section, we preview possible upcoming regulatory changes that we may see over the next few months for clients operating a regulated business.
1. Strengthening Oversight of Virtual Asset Service Providers (VASPs)
The Cayman Islands continues to develop its regulatory framework for VASPs. As of 1 April 2025, key provisions of the Virtual Asset (Service Providers) Act, 2020 (as amended), were brought into force. These key areas included:
- Licensing for custody and trading platform operations;
- Increased supervisory oversight and registration requirements;
- Ongoing compliance expectations as clarified in CIMA's latest circulars and guidance.
A revised version of CIMA's Regulatory Policy on Licensing and Registration of Virtual Asset Service Providers was gazetted in May 2025 (available here) (the "revised RP"). The revised RP replaces the 2024 version and, amongst other things, provides for circumstances in which CIMA may waive the requirement for a licence or registration for a "supervised person", meaning a person licensed or registered under another of the regulatory laws.
We expect continued regulatory focus and possible further legislative refinements to the virtual assets regime.
2. CIMA Supervision and Enforcement
CIMA is expected to maintain its emphasis on risk-based supervision and inspection programs, particularly in relation to:
- Investment services (as evidenced by CIMA's inspection findings issued in May 2025);
- Fund operators, whereby there is an ongoing expectation for timely filings of FAR forms and audited financials;
- Registered persons under the Securities Investment Business Act, including AML/CFT controls and governance frameworks.
- Deposit taking institutions being institutions authorised to accept deposits from the public including banks, cooperative societies, (including credit unions, building societies and similar financial institutions) and the Development Bank of the Cayman Islands. A Regulatory Policy on Domestic Systemically Important Deposit Taking Institutions was gazetted in May 2025 (available here) which supplements the Rule (available here) which became effective in May 2024.
3. Increased scrutiny of CRS and FATCA Reporting
International tax transparency remains a core priority of the DITC, with updates impacting:
- The expanded list of reportable and participating jurisdictions (with new inclusions for 2025 and 2026 reporting cycles);
- Greater emphasis on timely CRS & FATCA filings, including nil returns where applicable; and
- Ongoing submission of the CRS Compliance Form, due by 30 September 2025.
The DITC is also proposing to enhance its data quality review and audit processes, making documentation readiness and internal record-keeping more important than ever.
PUBLISHED briefings and e-alerts
Appleby published the following Briefings and E-alerts on our website.
These were also sent directly to client subscribers:
March: Overview of Fintech Laws and Regulations in Cayman 2024 (13 March 2025)
March: Snapshot of Recent Updates to the Virtual Assets Regime in the Cayman Islands (14 March 2025)
March: Rights and Liabilities of Limited Partners of Exempted Limited Partnerships in the Cayman Islands (25 March 2025)
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.
