Beneficial Ownership Transparency (Amendment) Act, 2025 (Act 3 of 2025)

Summary

This is an amendment act that makes technical and substantive changes to the Beneficial Ownership Transparency Act, 2023 (the principal Act) governing Cayman Islands beneficial ownership registers.

• Beneficial owner definition: Refines the definition of 'beneficial owner' as it applies to trusts, clarifying that a trustee is identified as the contact person where a trust meets a specified condition.
• Exemptions: Updates the exemption for certain companies, including those designated under section 80 of the Companies Act and non-profit organisations registered under the NPO Act.
• Corporate services providers: Adjusts the duties of corporate services providers regarding review, maintenance, and retention of beneficial ownership registers.
• Search platform access: Expands who may access the beneficial ownership search platform, adding the Customs and Border Control Service, certain government entities with Cabinet permission, and foreign beneficial ownership or AML/CFT competent authorities.
• Tiered access regime: Introduces a new tiered access regime for licensed financial institutions and designated non-financial businesses and professions (DNFBPs), limiting the specific particulars they may see for individuals and corporate entities.
• Records protection: A new provision (section 22A) protects records of searches and accessed information from disclosure under the Freedom of Information Act.

The Act applies to legal persons subject to the beneficial ownership regime, corporate services providers, licensed fund administrators, liquidators, licensed financial institutions, and designated non-financial businesses and professions.

• Liquidators and corporate services providers: New obligations regarding reporting of beneficial ownership details when a legal person is being wound up.
• Competent authority: Required to log access to the search platform.

Key obligations

• Where a legal person is being wound up, the corporate services provider or liquidator must provide the competent authority with the liquidator's details and the details of registrable beneficial owners (as held) as soon as reasonably practicable after the liquidator's appointment.
• A corporate services provider must remove a beneficial ownership register entry when a registrable beneficial owner, senior managing official, or trustee identified under section 4(3) ceases to hold that role, and must retain the related record for five years from the date that role ceased.
• A corporate services provider must establish and maintain a register containing adequate, accurate and current beneficial ownership information for each legal person that engaged it, per the required particulars in section 12.
• The legal person (rather than the fund administrator or contact person alone) is responsible for appointing the licensed fund administrator or contact person and ensuring they provide the required particulars.
• Licensed financial institutions and designated non-financial businesses and professions accessing the search platform are limited to specified particulars only (e.g., for individuals: name, country of residence, nationality, date of birth, ID document details, nature of control; for corporate entities: name, registered office, legal form, registration number, nature of control).
• The competent authority must keep a record of each access to the search platform, including date, time, and purpose of access.
• Information relating to access to the beneficial ownership register and the information accessed must be treated as an exempt matter under the Freedom of Information Act (2021 Revision).

Applies to

legal persons, corporate services providers, licensed fund administrators, liquidators (including provisional and joint liquidators), licensed financial institutions, designated non-financial businesses and professions, trusts/trustees, companies exempt under section 80 of the Companies Act, non-profit organisations registered under the Non-Profit Organisations Act

Deadlines

• five years from the date on which the registrable beneficial owner, senior managing official or trustee ceased to function in the role: Retention period for beneficial ownership register records after an entry is removed.
• as soon as may be reasonably practicable: Timeframe for a corporate services provider or liquidator to provide the competent authority with liquidator and registrable beneficial owner details when a legal person is being wound up.

Related documents

• This document amends Beneficial Ownership Transparency Act (2026 Revision)
• This document amends Beneficial Ownership Transparency Act, 2023 (Act 13 of 2023)
• Beneficial Ownership Transparency Act (2026 Revision) replaces this document