DMS Funds Update: New Private Funds Law Implementation and Timing

Further to our prior update, the Private Funds Law, 2020 (the “Law”) is now in force having commenced on 7th February 2020.

All Cayman domiciled entities, meeting the definition of private funds, who are doing business (have called investor capital) on or after 7th February 2020 have a transition period until 7th August 2020 to comply with the Law and, in particular with the registration requirements as a result of there being no separate timetable for existing funds.

Please note that once the transition period ends:

1. An application for registration must be submitted by a private fund to the Cayman Islands Monetary Authority within 21 days of accepting capital commitments from investors; and
2. A private fund must be registered prior to receiving capital contributions.

In view of the two points noted above, private fund managers/sponsors and directors/GPs should evaluate all existing Cayman based structures well in advance of 7th August 2020.

Please contact your usual DMS representative to find out more or contact us below.