On 7 July 2020, the Private Funds Law, 2020 (PF Law) was amended to vary the definition of a “private fund” by clarifying the definitions of certain entity types and extending the scope of the PF Law to additional entities.

The deadline for registration under the PF Law remains 7 August 2020.  We recommend that all Cayman Island investment vehicles be re-assessed to ensure compliance particularly considering the new Administrative Fine regime. Open-ended mutual funds and hedge funds are unaffected.

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As referenced in our updater on new registration requirements for Cayman Islands investment funds, the Cayman Islands Monetary Authority (CIMA) has published new rules governing the segregation of assets and the contents of offering documents and marketing materials for regulated funds.

The new rules apply to mutual funds that are regulated under the Mutual Funds Law (as Revised) and private funds registered under the recently promulgated Private Funds Law 2020.

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In response to the COVID-19 global pandemic, the Cayman Islands Government has announced a number of measures to support the continuity, viability, and strength of the financial services industry and ensure business continuity to clients.

The measures have been announced through industry advisory notices and those of most interest to our clients are noted here as they are updated.

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CAYMAN ISLANDS – The definition of a beneficial owner in the Companies Law (Revised) and the Limited Liability Companies Law (Revised) will change on 15 May 2020 from “more than 25%” of the shares or voting rights in a company to “twenty-five per cent (25%) or more” of the shares or voting rights in a company.

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