Cayman Islands Private Fund Update

The Cayman Islands has enacted Private Funds Law, 2020, and has released additional information regarding the specific requirements.

The new law, enacted Feb. 7, 2020, requires previously exempted private funds to register with the Cayman Islands Monetary Authority (CIMA). Funds that previously were subject to various CIMA exemptions have until Aug. 7, 2020, to register with CIMA.

Once a fund is registered with CIMA it then will become subject to certain CIMA regulations, including the annual audit requirement. In March CIMA issued further guidance, noting that the 2020 fiscal year-end will be the first year-end subject to the CIMA audit requirement. For example, if an existing fund’s fiscal year-end is Dec. 31, the CIMA audit requirement would go into effect for the year ended Dec. 31, 2020.

CIMA requires an annual audit performed by a CIMA-approved auditor. The audit must be issued no later than 180 days after the fund’s fiscal year-end.

Crowe LLP is excited to share that we have a wholly owned, CIMA-approved subsidiary based in the Cayman Islands, Crowe Cayman Ltd. Crowe Cayman Ltd. is 100% owned by Crowe LLP, so we are uniquely positioned to help make this transition as seamless as possible for both our current and future fund clients. Clients can rest comfortably knowing that they will have one dedicated and unified audit team, specialized in the investment company space, to complete their audits.