Welcome to the Q3 2025 funds newsletter.
This edition covers the topics below. We hope you will find this newsletter of interest.
- Establishing Your Cayman Fund, Investment Manager, Fintech Business or Web3 Venture
- Cayman Finalises VASP Cancellation Rules and Procedures
- Six Legal Pitfalls that can Impact Cayman Fintech Success
- Cayman Publishes Consultation on CARF Regulations
- 2025 Regulatory Filing Deadlines
- Latest Investments and Securities Figures
- AML & Compliance Training
- Stuarts Humphries Recognised in IFLR1000 2025 Rankings
- Funds Publications, Podcasts and Videos
- Events
Establishing Your Cayman Fund, Investment Manager, Fintech Business or Web3 Venture
First published in the 6th Edition of The Legal 500: Alternative Investment Funds Comparative Guide (September 2025), the Cayman Islands Hot Topic chapter underscores the jurisdiction's appeal for funds, fintech, and Web3 ventures, citing tax neutrality, flexible structuring, and modern regulation, including VASPA.
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Cayman Finalises VASP Cancellation Rules and Procedures
CIMA has issued final rules and procedures for Virtual Asset Service Providers ("VASPs") exiting or cancelling licences. The framework clarifies notification, compliance, client safeguarding and liquidation oversight, ensuring orderly exits while protecting stakeholders and preserving Cayman's regulatory reputation.
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VASP Amendment Act Simplifies Registration Scheme for Tokenized Funds in Cayman
This article outlines the Cayman Islands' proposed amendments to the Virtual Asset Service Provider regime, designed to streamline regulation of tokenised funds. The bill seeks to simplify compliance, provide greater clarity and offer enhanced flexibility for fund sponsors operating in the virtual asset space. It forms part of the GGI Global Alliance FYI Global Mobility Solutions Newsletter, published fall 2025.
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Six Legal Pitfalls that can Impact Cayman Fintech Success
Cayman fintech ventures face key legal hurdles, from licensing and AML compliance to data protection and governance. Funds engaging with fintech platforms or virtual assets should note these risks when structuring investments or selecting service providers.
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Cayman Publishes Consultation on CARF Regulations
The Cayman Islands have launched a consultation on CARF regulations, aligning with global tax transparency standards. Funds, managers and administrators should prepare for expanded reporting obligations and assess potential compliance impacts.
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2025 Regulatory Filing Deadlines
Please be aware of the 2025 regulatory filing deadlines for all Cayman-domiciled entities – including funds, registered companies, and financial institutions – under the CRS, FATCA, and Economic Substance regimes with the Cayman Islands' Department for International Tax Cooperation (DITC).
The deadline for Economic Substance Return filings (for entities with a financial year end of 31 December) and CIMA de-registrations is 31 December 2025.
The new beneficial ownership regime is now in effect, requiring immediate compliance to avoid penalties. Director registration renewals or cancellations must be completed via CIMA's online portal using existing credentials. Additionally, the CRS list of Reportable Jurisdictions has been updated. Regularly reviewing the DITC Updates Bulletin is advised.
For support, contact your usual Stuarts Humphries attorney or Jon McLean, Head of Banking & Regulatory.
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Latest Investments and Securities Figures
Most regulated sectors in the Cayman Islands have continued on a steady path over the past 12 months, with Private Funds up 3.5% and Mutual Funds up 1.5%. Funds may previously have been discouraged from establishing the investment manager in the Cayman Islands due to the new economic substance rules. However, there are practical solutions to meet the economic substance requirements.
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Stay Compliant with Our AML & Compliance Training
Stuarts offers CIMA-compliant AML and compliance training for financial services professionals in the Cayman Islands. This annual training covers Anti-Money Laundering (AML), Counter Terrorism Financing (CTF), Proliferation Financing (PF), and Sanctions, as required by CIMA for Directors, AML Officers, Senior Management, and relevant staff. Sessions are led by Reuben Foster, former CIMA Chief Analyst and now Head of Group Compliance at Stuarts. To book your training, contact Jon McLean or Reuben Foster today.
Stuarts Humphries Recognised in IFLR1000 2025 Rankings
Stuarts Humphries has been named a Recommended Firm in the IFLR1000 2025 guide. Chris Humphries, Managing Director and Head of Funds, and Jonathan McLean, Head of Banking & Regulatory, were recognised as Highly Regarded Lawyers, while Megan Wright, Head of Corporate, was named a Rising Star Partner. IFLR1000 praised the firm's "excellence in sovereign finance, regulatory structuring, and fund formation throughout 2024."
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Funds Publications
- Legal500 Alternative Investment Funds Comparative Guide 2025 (Cayman Islands): Establishing Your Cayman Fund, Investment Manager, Fintech Business or Web3 Venture
- Chambers Global Guide 2025: In Depth Overview of Investment Funds in the Cayman Islands
- Chambers FinTech Guide 2025: Introduction to FinTech in the Cayman Islands
- Mondaq Comparative Guide 2025: Capital Markets in the Cayman Islands
- Legal500 Interview with Chris Humphries: 2024 Market Overview and Adapting to Clients' Needs
- Legal500 Fintech Country Comparative Guide 2024: Alternative Investments: Crypto Funds and Digital Assets Thrive Under Innovative Legislation
- Business Reporter 2024: Empowering Web3 through Innovative Legislation in the Cayman Islands
- Lexology Panoramic 2024 Chapters: Private Equity: Fund Formation in the Cayman Islands
- Lexology Panoramic 2024 Chapters: Private Equity: Transactions in the Cayman Islands
- Chambers Practice Guide 2023: Doing Business in the Cayman Islands: Digital Assets, Trends and Developments
- Mondaq Comparative Guide 2023: Securitisation in the Cayman Islands
- Hedge Week Cayman Report 2023: Powers of the Founder of Foundation Companies
- Legal500 Alternative Investments Guide 2022: Rise in Fintech Funds in the Cayman Islands
- ICLG Corporate Governance 2021: Corporate Governance in the Cayman Islands
- Cayman Structures for Crypto, Web3 and Blockchain Entities
Our Podcasts on Mutual Funds & Private Funds
Stuarts released podcasts on the Registration of Private Funds and Mutual Funds in the Cayman Islands. The podcasts include a brief summary on; the types of private funds (including non-fund arrangements) and mutual funds in the Cayman Islands and their registration requirements.
Podcast - Mutual Fund Registration in the Cayman Islands
Podcast - Private Fund Registration in the Cayman Islands (Part 1)
Podcast - Private Fund Registration in the Cayman Islands (Part 2)
Our Videos on Investment Funds
View our recently released videos on the registration of private funds, mutual funds and crypto funds in the Cayman Islands. The videos include a brief summary on the types of funds (including non-fund arrangements) and their registration requirements.
Video - Private Funds in the Cayman Islands
Video - Mutual Funds in the Cayman Islands
Video - Crypto Funds in the Cayman Islands
Video & Podcast Hub
Upcoming Events
- 6-9 October: Chris Humphries and Megan Wright will be in New York. Reach out if you would like to connect.
- 11 October: We are honoured to continue our Silver Sponsorship of the Cayman Islands Veterans Association's 12th Annual Veterans Benefit. Please let us know if you plan to attend.
- 1 November: We are proud to support the Central Caribbean Marine Institute's Festival of Seas gala as a Silver Sponsor. We would be delighted to connect with you if you are attending.
- Early November: Jonathan McLean and Richard Annette will be in Miami. Reach out if you would like to connect.
Recent Events
- 19-28 September: Chris Humphries and members of the Stuarts Humphries team were delighted to attend the Southampton International Boat Show in the UK as an exhibiting sponsor alongside the Central Caribbean Marine Institute.
Originally published 30 September 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.
