Cayman Private Funds Law: Readiness Assessment
July 16, 2020
The registration and implementation deadline for the Cayman Private Funds Law is fast approaching. Prior to August 7th, fund managers and operators should have determined the following:
The registration and implementation deadline for the Cayman Private Funds Law is fast approaching. By August 7th, fund managers and operators should determine if:
- The entities within their fund structures are in-scope pursuant to the latest definitions.
- Relevant details, service provider consent and supporting documentation have been obtained to complete the CIMA Registration process.
- Each Fund or GP that is required to have two Directors or two natural persons named has made these appointments to satisfy the Four-Eyes Principle;
- Arrangements have been established within the firm of the Manager or via an Administrator or other third-party provider to ensure compliance with safe-keeping, cash-monitoring and valuation of securities requirements. Such arrangements are the statutory responsibility of the board of directors or GP with fines applicable for non-compliance; and
- Each entity has AML Officers to be named in the Registration to CIMA. AML Officers to be named in the Registration to CIMA. AML Officers must be named in the registration process and can expect to be the contact point for CIMA with respect to queries that relate to the Anti-Money Laundering, Combating the Financing of Terrorism and Anti-Proliferation control environment for the fund, as well as any ad hoc concerns.
We understand that you may still be in the process of making these determinations. Our team is positioned and ready to help you navigate these requirements ahead of the August 7th deadline.