The Cayman Islands Monetary Authority (CIMA)
has announced an 'amnesty' for certain directors whose
registration under the Directors Registration and Licensing Act
(DRLA) has not been properly maintained. This
amnesty will be available between 16 September and 15 October 2025
and will offer certain registered directors an opportunity to
return to good standing with CIMA.
Background
Since 2014, directors of Cayman-registered mutual funds and certain entities registered under the Securities Investment Business Act have been required to license or register themselves individually with CIMA before they are lawfully able to act as directors of these 'covered entities'. The Act does not apply to registered private funds, or to directors of general partners of funds established as partnerships (even where registered as mutual funds). There is a simplified registration regime for directors of fewer than 20 covered entities. Directors of more than 20 covered entities (unless they are employees of a regulated fund manager) are required to be licensed and subject to additional obligations.
In addition, CIMA requires directors who are no longer directors of any covered entities to undergo a de-registration process. This can cause issues for directors who overlook this at the end of their tenure, who may be unaware that they are obliged to de-register, and cannot simply leave their registration to lapse.
While the regime is straightforward to comply with, it imposes a personal obligation on the directors as individuals, and not on the fund entities they serve. In practice, it is also an obligation that CIMA expects directors to discharge themselves via CIMA's dedicated portal for directors, rather than rely on the fund's service providers. CIMA imposes penalties where fees are not settled by 15 January each year.
The amnesty
CIMA's amnesty is only available to registered directors of fewer than 20 covered entities who have more than two years of unpaid annual fees and penalties.
Any such directors will be able to settle their outstanding annual fees and penalties at a discounted rate. CIMA has not yet confirmed the exact terms of this discount and expects to release further details through their 'Director Gateway' portal on 16 September 2025. CIMA has contacted any directors in this position by email but have invited any directors who have not received an email but believe they may be in bad standing to contact them atamnesty@cima.ky.
Please get in touch with your Walkers team should you have any questions. You may also read CIMA's industry notice about the amnestyhere.
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.
