- with readers working within the Securities & Investment industries
Welcome to the Q4 2025 funds newsletter. This edition covers the topics below. We hope you will find this newsletter of interest.
- Cayman Considerations for Fund Secondary Transactions
- Guidance Note: Independent Directors in Cayman Funds
- Global Fund Structuring: Cayman and the UAE in Perspective
- CRS 2.0: Cayman implements updated reporting regime from 2026
- Cayman Sets CARF & CRS 2.0 Rules Ahead of 2026 Implementation
- Companies (Amendment) Act 2024 Now in Force
- CIMA Issues Desk-Based Review on VASPs
- 2026 Regulatory Filing Deadlines
- Latest Investments and Securities Figures
- AML & Compliance Training
- Stuarts Humphries Recognised in Legal 500 Caribbean 2026
- Stuarts Humphries Recognised in Chambers FinTech 2026
- Funds Publications, Podcasts and Videos
- Events
Cayman Considerations for Fund Secondary Transactions
As GP-led continuation vehicles become an increasingly common feature of the private equity secondaries market, this legal update examines the key Cayman Islands considerations for secondary and continuation transactions. It covers fund structures, transfer mechanics, regulatory and compliance requirements, governance and fiduciary duties, and practical execution issues relevant to sponsors and managers navigating these transactions.
Guidance Note: Independent Directors in Cayman Funds
Independent directors are now a core component of effective governance for Cayman funds, supporting investor confidence, regulatory resilience and long-term sustainability. This guidance note examines why their role has become increasingly important, outlines evolving regulatory and investor expectations, and explores practical considerations for appointing the right individuals to fund boards.
Global Fund Structuring: Cayman and the UAE in Perspective
This update compares global fund structuring in the Cayman Islands and the UAE, examining why Cayman continues to be the preferred jurisdiction for international fund sponsors. It highlights Cayman's tax-neutral framework, regulatory clarity, established legal infrastructure and broad investor acceptance, while also considering where the UAE may be appropriate for regional or specialist strategies. The article provides practical insight for managers assessing cross-border structuring options in an evolving global funds market.
CRS 2.0: Cayman implements updated reporting regime from 2026
The Cayman Islands has now implemented the OECD's "CRS 2.0" updates through the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025, which will apply from 1 January 2026, with key reporting changes taking effect from 2027. The amendments strengthen data quality expectations, accelerate registration and reporting timelines and expand the regime to cover electronic money products, central bank digital currencies and certain crypto-assets. Financial institutions must update governance and due diligence procedures, appoint a local Principal Point of Contact and meet new filing deadlines.
Cayman Sets CARF & CRS 2.0 Rules Ahead of 2026 Implementation
This update focuses on the Cayman Islands' implementation of the Crypto-Asset Reporting Framework (CARF) and how it operates alongside the revised CRS regime. It explains who falls within scope as a crypto-asset service provider, the types of transactions and users that must be reported, and the due diligence standards that apply. The article also outlines transitional timing and practical steps for entities preparing for the new reporting obligations ahead of 2026.
Companies (Amendment) Act 2024 Now in Force
On 1 January 2026, the Companies (Amendment) Act, 2024 came into force, introducing a series of updates to Cayman corporate law. Key changes include a new non-court process for reducing share capital, expanded continuation and conversion routes, and increased flexibility for corporate structuring. Companies should consider whether these amendments present opportunities to simplify or restructure their existing arrangements.
CIMA Issues Desk-Based Review on VASPs
The Cayman Islands Monetary Authority (CIMA) has published findings from a desk-based review of virtual asset service providers (VASPs), identifying common regulatory and compliance gaps. The review highlights areas such as governance, internal controls, anti-money-laundering and cybersecurity, offering insights that may be relevant to funds with virtual asset exposures or service arrangements.
2026 Regulatory Filing Deadlines
Please be aware of the 2026 regulatory filing deadlines and the 2026 FATCA and CRS Reporting Deadlines for 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 2026.
The beneficial ownership regime took effect on 1 January 2025, 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.
The Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2025 has been published. See our legal update on how CRS 2.0 may affect your organisation.
For support, contact your usual Stuarts Humphries attorney or Jon McLean, Head of Banking & Regulatory.
Latest Investments and Securities Figures
Most regulated sectors in the Cayman Islands have remained broadly stable over the past year, with Private Funds up approximately 3.7% and Mutual Funds up approximately 1.2% over the preceding 12 months. 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, and we encourage funds to discuss the available options with us.
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 Legal 500 Caribbean 2026
Stuarts Humphries has been recognised in The Legal 500 Caribbean 2026 for strong performance across key practice areas. The Investment Funds team, led by Chris Humphries, achieved an improved ranking, highlighting its reputation for fund structuring and regulatory advice. Clients said the practice is "thoughtful, strategic, commercial, and responsive" and described Megan Wright as "a valuable asset to our firm – thorough, responsive, and highly competent."
Stuarts Humphries Recognised in Chambers FinTech 2026
Stuarts Humphries has been recognised in the Chambers and Partners FinTech 2026 Guide for its strength in advising across financial technology, including investment funds matters. Chris Humphries and Jonathan McLean were individually ranked, with McLean advancing to Band 2. Clients said "Stuarts Humphries is very responsive to every request," highlighting the team's commercially focused advice.
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 Fintech Country Comparative Guide 2024: Alternative Investments: Crypto Funds and Digital Assets Thrive Under Innovative Legislation
- Mondaq Comparative Guide 2023: Securitisation in the Cayman Islands
- 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
- 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
Upcoming Events
- 31 January 2026: We are proud to support the upcoming Blue Tie Dinner in aid of the National Trust Cayman Islands' Blue Iguana Conservation Programme. Please reach out if you plan to attend.
- 9-13 February: Our team will attend Cayman Crypto Week, hosted by the Blockchain Association of the Cayman Islands.
- Megan Wright is planning a trip to Dubai. Reach out if you would like to connect.
Recent Events
- 8 October: We were delighted to attend the ACAMS Cayman Islands Chapter launch.
- 6-9 October: Chris Humphries and Megan Wright were in New York. Reach out if you would like to connect on their next trip.
- 11 October: We were honoured to continue our Silver Sponsorship of the Cayman Islands Veterans Association's 12th Annual Veterans Benefit.
- 1 November: We were proud to support the Central Caribbean Marine Institute's Festival of Seas gala as a Silver Sponsor.
- 6 November: We were glad to attend the IIA HQ & IIA Cayman Islands Meeting.
- 9-11 November: We were delighted to connect with the funds industry at Uncorrelated Cayman.
- 12 November: Our team attended the CIMA VASP Regulatory Forum.
- 22-26 November: Jonathan McLean was in Miami. Reach out if you would like to connect on his next trip.
Originally published 5 January 2026
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.
