New Cayman Islands Monetary Authority Law Requires Directors to Register

The Cayman Islands Monetary Authority (CIMA) recently passed The Director’s Registration and Licensing Law, 2014 (Law 10 of 2014), which provides for the regulation of directors of certain entities in the Cayman Islands.

This new law requires directors of Cayman-regulated funds (including most master funds) and certain other Cayman-licensed companies (Covered Entities) to register with CIMA and pay an application and registration fees. In our discussions with Cayman counsel on this matter, it was noted that the law is intended for and will affect most Cayman feeder and master funds. Registration is required for the directors of these Covered Entities regardless of where the director resides. The law came into effect on June 4, 2014, and mandates that directors be registered with CIMA within three months from that date. An FAQ document on the new law can be found here.

Registration will be conducted via CIMA’s dedicated web portal. A unique identification number (Unique ID) will be issued by CIMA for each director. This Unique ID is needed to login to CIMA’s web portal and begin the registration application. A director may obtain their Unique ID by contacting CIMA directly at DirectorsRegistration@cimoney.com.ky or by contacting the Covered Entities’ Cayman Islands registered office provider. Each director should be issued only one Unique ID regardless of how many Covered Entities they serve as a director for.

The application fee will be $140 Cayman dollars (approx. $171 USD) and the registration fee for the first calendar year will be $560 Cayman dollars (approx. $683 USD). Thereafter the annual registration fee will be $700 Cayman dollars (approx. $854 USD). Only one registration fee is due per director regardless of the number of Covered Entities (as long as there are fewer than 20 CIMA-registered entities) the director acts as a director for.

Please note this alert only addresses natural persons that serve as directors for fewer than 20 Cayman Covered Entities. There is a separate licensing regime for corporate directors and natural persons who serve on more than 20 Covered Entity boards.

If you have any questions, please contact your Cayman counsel directly.