Further to our update1 of 24 March 2020, the Cayman Islands Ministry of Financial Services and the Cayman Islands Monetary Authority ("CIMA") recently introduced additional policy concessions and filing extensions in light of COVID-19.

CIMA Filings

  • De-registrations:  CIMA has confirmed that it will accept uncertified resolutions confirming the de-registration / cancellation date of a fund.

  • Fund Annual Return ("FAR"):  The Mutual Funds (Annual Returns) (Amendment) Regulations (2020) (the "Regulations") are now in force and amend the FAR form required to be submitted to CIMA by registered mutual funds.  Notwithstanding the Regulations, CIMA has indicated that all mutual funds with a 31 December 2019 financial year end can submit the current form.

  • Extended Filing Dates:  CIMA has allowed a one month extension for filing deadlines 2 for some regulatory returns with due dates through 30 June 2020.  These related primarily to the banking and money services sector and not, generally, to investment funds.

Key Ministry of Finance Measures

  • Registrar of Companies (the "ROC") Filings:  The deadline after which penalties will apply in respect of annual return filings for Cayman Islands entities has been extended to 30 June 2020.  As the economic substance notification process was connected to annual return filings for companies, this deadline has also been extended to 30 June 2020.  Where fees / returns remain outstanding on 1 July 2020, penalties will be assessed at 33.33% of the annual fee, with penalties rising to 100% of the annual fee on 1 October 2020.  Please note the ROC continues to apply good standing to entities that completed its annual return filings by 31 January 2020.  Despite the extended deadline regarding the application of any penalties, entities will only be deemed to be in good standing by the ROC once all annual return filings and economic substance filings have been duly completed and associated fees paid.

  • FATCA / CRS Reporting:  As the FATCA / CRS filing portal remains closed and is not expected to open until June 2020, the FATCA / CRS reporting deadline has been extended to 18 September 2020 for this year only.


1.  COVID-19 Cayman Islands Update: Cayman Financial Services

2. CIMA List of Filing Extensions

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