AML Return Requirement for Restricted Trust Companies and Private Trust Companies (2026-09-07)

Summary

This is a General Industry Notice from CIMA announcing that the existing Anti-Money Laundering (AML) Return requirement, previously applicable to Trust and Corporate Services Providers, will now also apply to Restricted Trust Companies (RTCs) and Private Trust Companies (PTCs). It sets out the timing, distribution method and future cycle for this new reporting obligation.

• Initial return: Issued to RTCs and PTCs on 1 November 2026, requiring information as at 31 December 2025, and must be submitted to CIMA by 31 December 2026.
• Distribution method: Issued via CIMA's Strix software to entity contacts including the Registered Office Contact, Principal Office Directors, AMLCO, MLRO, DMLRO, and any additional contacts the entity designates.
• Contact accuracy: RTCs and PTCs must ensure their contact information held by CIMA is accurate and up to date before the distribution date, and may email AMLReturns@cima.ky to add contacts.
• Future cycle: After the initial exercise, RTCs and PTCs join the existing TCSP sector AML Return cycle, with subsequent returns issued on 1 June each year unless otherwise advised.

Entities are advised to review the AML Return and applicable requirements promptly on receipt to allow sufficient time for accurate completion before the deadline, and to consult CIMA's Regulatory Forms Completion Guides for further guidance.

Key obligations

• RTCs and PTCs must complete and submit the initial AML Return (covering data as at 31 December 2025) to CIMA by 31 December 2026.
• RTCs and PTCs must ensure contact information and relevant details maintained with CIMA are accurate and up to date, particularly ahead of the AML Return distribution date.
• RTCs and PTCs must comply with the submission requirements and deadlines for subsequent AML Returns, to be issued annually on 1 June under the TCSP submission cycle unless otherwise advised by CIMA.

Applies to

Restricted Trust Companies, Private Trust Companies

Deadlines

• 1 November 2026: Initial AML Return issued to RTCs and PTCs, requiring information as at 31 December 2025.
• 31 December 2026: Deadline for RTCs and PTCs to complete and submit the initial AML Return to CIMA.
• 1 June of each year: Subsequent AML Returns will be issued annually to RTCs and PTCs as part of the TCSP submission cycle, unless otherwise advised.