Beneficial Ownership Transparency (Amendment) Regulations, 2025 (SL 16 of 2025)

Summary

This is an amendment to the Cayman Islands' Beneficial Ownership Transparency Regulations, 2024, made under the Beneficial Ownership Transparency Act, 2023. It makes several targeted technical changes to how legal persons, corporate services providers, senior managing officials and trustees must handle beneficial ownership information and particulars.

• Notification of death: Extends the existing duty to notify a corporate services provider of a person's date of death (previously limited to registrable beneficial owners) to also cover senior managing officials and trustees identified under section 4(3) of the Act.
• Unconfirmed particulars: Extends the rules on providing additional matters where particulars are unconfirmed so they also apply to senior managing officials and trustees, not just beneficial owners.
• Direct interest test: Broadens the test for 'holding an interest in a legal person directly' to cover holding interests or voting rights, not just shares.
• Regulation 22 replacement: Replaces regulation 22 with new rules setting out the required particulars for senior managing officials, trustees (including corporate trustees) and persons treated as individuals under section 2(2) of the Act.
• Schedule 1 fines table: Adds a new item to Schedule 1's administrative fines table imposing a fine for a legal person's failure to provide requested beneficial ownership information under section 12(8) of the Act.

The changes apply to legal persons subject to the beneficial ownership regime, their corporate services providers, and to senior managing officials and trustees who are identified as reportable in place of beneficial owners.

Key obligations

• Where a registrable beneficial owner, senior managing official, or a trustee identified under section 4(3) of the Act has died, the legal person must provide the date of death in writing to its corporate services provider.
• Legal persons must provide additional required matters to their corporate services provider where particulars of a senior managing official or a trustee identified under section 4(3) of the Act (in addition to beneficial owners) are not confirmed.
• Where a person holds an interest or voting rights directly in a legal person, this must be recognised as 'holding an interest directly' for beneficial ownership determination purposes.
• Required particulars for senior managing officials, trustees (including corporate trustees), and persons considered individuals under section 2(2) of the Act must be entered in the beneficial ownership register in accordance with the specified provisions, including contact name, email address and telephone number where applicable.
• Legal persons must provide requested beneficial ownership information under section 12(8) of the Act or be subject to an administrative fine for failure to do so.

Applies to

legal persons, corporate services providers, trustees, senior managing officials

Related documents

• This document is made under Beneficial Ownership Transparency Act, 2023 (Act 13 of 2023)
• This document amends Beneficial Ownership Transparency Regulations, 2024 (SL 26 of 2024)
• Beneficial Ownership Transparency Regulations (2026 Revision) replaces this document