In this month's Cayman Islands Regulatory 15/15 episode, Adam Huckle, Daniel Moore and Lisa page discuss recent updates on Common Reporting Standard 2.0, share insights from Consensus Miami 2026 and review CIMA change of control requirements.

To read the 2026 Cayman Islands Regulatory Calendar, visit: https://maples.com/regulatory-round-up/2026-cayman-islands-regulatory-calendar.

To read the 2026 BVI Regulatory Calendar, visit: https://isu.pub/MgRPtyF

SPEAKERS:

Adam Huckle, Partner | +1 345 525 5377 | adam.huckle@maples.com | View bio

Daniel Moore, Of Counsel | +1 345 936 5429 | daniel.moore@maples.com | View bio

Lisa Page, Associate | +1 345 814 5590 | lisa.page@maples.com | View bio

The contents of this podcast do not constitute legal advice and need to be taken as a general update only.

Visit our Regulatory Round-Up Blog for the latest developments and insights in the regulatory landscape.

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Website: https://maples.com/podcasts/15-15

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Hi everyone, and

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welcome to the latest edition

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I'm Adam Huckle and I'm a Partner

in our Regulatory and Dispute

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Resolution teams here at Maples and Calder

in the Cayman Islands.

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And today on the podcast,

I am delighted to be joined by Dan Moore,

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who is of counsel in our regulatory

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team, and Lisa Page,

an associate in the same team.

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We will be talking today about all things

CRS 2.0,

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some interesting points

coming out of recent consensus

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Miami crypto conference and a reminder

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of change of control requirements.

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As always, the contents of today's podcast

do not constitute

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legal advice and you should take them

as a general update only.

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And for timely regulatory

updates from our Cayman Islands, BVI,

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Ireland, Luxembourg and Jersey offices,

please

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visit and subscribe to our Regulatory

Roundup blog on maples.com

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And please don't forget to subscribe

on Apple Podcasts or Spotify.

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So starting with you, Lisa,

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you have just returned to the office

after a week pounding the streets

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and speaking to clients

and onshore US counsel

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regarding the changes to the Common

Reporting Standard in the Cayman Islands,

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as well as attending a Bruce Springsteen

Bruce Springsteen concert.

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So I hear but first, can you tell us a

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what does The Boss think of CRS 2.0?

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And secondly, what are the key points

for our listeners to note?

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Thanks, Adam.

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So as you mentioned, CRS

2.0 has involved

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quite a few significant updates

to the Cayman Islands CRS regime.

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In terms of the backdrop,

this generally flux

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the OECD changes made in 2023, as well

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as some more Cayman specific changes.

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Most of the new CRS 2.0 rules

came into effect on the 1st of January

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earlier

this year, with the remaining changes

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scheduled to commence

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So we have a bit of time for those ones.

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But in summary,

these CRS changes introduced

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updated registration requirements

for Cayman Islands financial institutions,

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revised due diligence requirements

involving a new self-certification form

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that will include new data fields,

some streamlined CRS reporting dates

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for the filing of the CRS

return in the compliance form,

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which were previously separate

filing dates into a consolidated

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30th June filing date in 2027,

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also imposed a new, accurate,

adequate and current information

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standard on registration

and reporting information.

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Also introduced a new requirement

for there to be a Cayman Islands

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based principal point of contact

or a PPOC, it also brought

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digital currencies and crypto assets

into scope of the CRS regime.

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So that's kind of the bird's eye

view of those changes.

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And happy to to step thro

ugh some of those key changes

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and in further detail

if that would be helpful.

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And we'll try to limit the discussion

to CRS and try to avoid

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any sort of Bruce Springsteen chat.

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Okay, well,

that's a shame, but but on the CRS

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front, is the PPOC requirements

something that the Maples Group

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can help our listeners with

if that's something they require?

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Yeah. So that's certainly

something that we can assist with.

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So to the extent

that any entities have PPOCs

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that are based in other jurisdictions

and are not Cayman Islands based,

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our colleagues over at MFS

can assist with that.

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And again, entities will want to have

their ducks in a row and have that

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Cayman Islands based PPOC

lined up by the 31st of January next year,

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as this is a requirement for all F.I’s

and it has to be a natural person

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that's resident in the Cayman Islands

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or a legal person

with a physical Cayman office.

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So a mailing address,

unfortunately, would be insufficient to

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to meet that requirement.

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Yeah, that's a key

practical point isn't it?

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Okay. Well thank you very much.

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Lisa and Dan, over to you.

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You have similarly just returned

to the office.

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Everyone's been out

following your attendance at the Consensus

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Miami conference, at which none other

than Donald Trump Jr spoke, I believe.

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So what were the main crypto related

points relevant to our jurisdiction

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and our main key

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industries here in the Cayman Islands

coming out of that conference?

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Sure. Thanks, Adam.

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Super interesting conference.

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And just by way of background Consensus,

I would say, remains certainly

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one of the flagship

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gatherings, if not the flagship

gathering for the digital assets industry.

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So yeah, very happy to share

some reflections on what I observed

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and what it means for our practice

and our clients

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in the regulatory space generally.

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I think the overarching theme

this year is very much

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that the crypto environment

has in most major jurisdictions,

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be that the US, the EU,

Middle East, Hong Kong, Singapore,

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it really has shifted from this period

of regulatory uncertainty to one of more

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kind of structured engagement,

where the parameters are a bit clearer.

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And now the conversation

isn't so much about whether assets,

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digital assets would be regulated,

but how these competing regimes interact.

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And certainly from the offshore

perspective,

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that's now opening up some jurisdictional

arbitrage opportunities.

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And for those of us advising from

the Cayman Islands and the BVI as well,

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I think there's maturation of the global

landscape is quite significant because,

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I mean, it's worth remembering

that that both Cayman Islands

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and the BVI have had their own VASP

backed legislation in place

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for a number of years now.

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So so we're not new

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to the regulatory conversation

and we're well placed to assist.

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So I think we're now in a world

where our clients are building

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their projects within kind of more

well-defined parameters,

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and they expect us as offshore counsel

to understand the full picture.

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So that's certainly what it's helpful for

us to be involved in these conversations,

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to be attending these global conferences

and to understand, you know,

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what our client's needs are and where

the conversations are taking place.

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At the same time,

I think what we're seeing is

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the established

advantages of offshore jurisdictions.

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So we all know about the legal certainty,

the tax neutrality,

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the flexible corporate structures,

the creditor regimes and so on.

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And these are being

increasingly recognized by the crypto

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native operators because they tend to be

nimble and jurisdiction agnostic.

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So we're seeing founders and teams

who will move to the regime

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that best suits

their commercial objectives.

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And the Cayman Islands and BVI alike

offer compelling propositions.

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That's well understood

by not only these early stage projects,

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but by the institutional counterparties,

by the regulators and so on.

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A second team, aside

from the regulatory space,

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but on a product

level, was the rise of agenetic AI.

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And this is AI that kind of doesn't

really assist human decision making,

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but actually takes decisions

itself, acts autonomously.

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So we're talking about agentic AI,

executing trades, managing portfolios,

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deploying capital on chain,

even negotiating terms between protocols.

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So the legal implications of that

are going to be enormous globally.

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And there's obviously going to be ongoing

conversations around agency liability,

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fiduciary duties, regulatory compliance

and so on where you've got this autonomous

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system rather than a natural person

or a corporate entity making decisions.

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So we're seeing this intersection of AI

and blockchain technology.

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It's being built in production.

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And we need to be thinking

careful carefully about how

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our legal frameworks can accommodate

or as the case may be,

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fail to accommodate these developments

because it will continue, I think, to be,

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you know, this is

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this is something that is going to be

a mature technology in the future.

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And then I guess, thirdly,

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and maybe most directly relevant

to our day to day

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work is the acceleration of institutional

adoption of tokenization at scale.

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So at the at the conference, we saw

representative representation by the major

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asset managers, the global custodians,

the clearing systems, the tier one banks.

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And these are not

these are not pilot projects anymore.

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We're tokenizing money market funds,

Treasury and treasury instruments, credit

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products, real estate, real assets

with kind of now a level of scale

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I think wouldn't even have been imagined

even 12 months ago.

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And I think the really exciting thing is

that this infrastructure is now reaching

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a level of maturity

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in terms of the custody solutions,

settlement, compliance, interoperability

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that we're now seeing institutional

as being satisfied in terms

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of their risk appetite to get involved,

and they all want to be involved.

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So I think this is now the kind of

inflection point we were anticipating.

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But it came earlier to me, expected

and for the benefit of the industry.

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I think we're seeing tokenization

scaling to a level where the end investors

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are going to start seeing tangible

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benefits because it brings greater

transparency, faster settlement,

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reduce friction in terms of subscription,

redemption, mechanics and so on,

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and ultimately some lower costs that

will be passed through to the value chain.

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So I think that's

that's very exciting as well.

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And just to bring it back,

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because I could go on about this

and people people often remind me of that.

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But that brings me back to our own

jurisdiction or own jurisdictions

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and the Cayman Islands in particular,

which has responded with,

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I think, considerable foresight

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through the recent amendments

to the Mutual Funds Act

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and the Private Funds Act, which I think

recognizes the direction of travel.

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And we now have a legal framework

in the Cayman Islands

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that expressly contemplates

the issuance of tokenized fund interests.

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We now have a clear statutory basis

to accommodate these products, and

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there is now a level of legal certainty

around things like transfer mechanics,

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register of members, legal,

legal ownership, the role of the providers

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that really places us in a good position

to to help build out these products

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with our clients.

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So we're now at a point,

I would say, where Cayman Islands

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has always been the domicile of choice

for institutional fund structures,

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and now it's also a natural home

for tokenized vehicles.

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So we've reduced the friction,

we've increased the legal certainty.

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And we already have several instructions

ongoing for these tokenized products.

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So it's all very exciting.

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And the direction of travel is here.

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We have the frameworks.

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Institutional capital is arriving

and the Cayman Islands is ensuring

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is at the forefront. So it's an exciting

time to be in this space.

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And I look forward

to helping our clients on their projects.

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That's really interesting

and good to hear you all across this.

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And our listeners should contact

an if they've got any sort of Crypto

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or VASP related issues

affecting the Cayman Islands and BVI.

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And Lisa,

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the final word from you on something

very different, but no less important.

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I know that you've been very busy recently

with a large uptick

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in often urgent change

of control applications,

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and you scored a major success recently

with your work for Desjardins Group

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on its acquisition of Guardian Capital

Group limited.

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Can you tell us more about that,

and what our listeners ought to be aware

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of about the very important change

of control rules in the Cayman Islands?

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Yeah, sure. Thanks, Adam.

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So as you mentioned, we are seeing quite

a bit of action on the change of control

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front and applications

being filed with CIMA.

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I know our team has been particularly busy

with that over the past

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few weeks

on on various mandates for clients.

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So simply put, these types of

applications involve a change of ownership

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or a change of control of a CIMA

regulated entities.

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So things like insurance

licensees, banking licensees,

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trust licensees or securities investment

business registered person, a SIB person

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that's

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either a regulated investment manager

or investment advisor.

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And these types of changes of control

require

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certain approvals

or notifications to CIMA.

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And then acquisitions involving

Cayman Islands financial services

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entities that are regulated by CIMA.

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These types of things

do require quite a careful analysis,

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because there are certain rules

that apply and impose

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a wide range of prior

approval or notification requirements,

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depending on the type of regulated entity

that it is.

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So I would say that

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these requirements broadly fall

into about three different categories,

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the first being a prior approval for any

shared transfer, regardless of the size,

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the second being a prior approval only

where a transfer crosses a 10% threshold,

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and then the third being a post change

notification only.

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So taking each of these in turn,

the first being prior written

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Seymour approval that's required

before any shares or interests

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or issued, transferred

or disposed of in banking

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trust licensees, company managers

and licensed mutual fund administrators.

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Now, in contrast,

insurers, insurance agents, insurance

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brokers and virtual asset

service providers generally require

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prior seam approval only where the share

is totaling more than 10%

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of the licensees share capital or voting

rights are issued or transferred.

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And then finally, in the case of a SIB

registered person,

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this is typically subject to a lighter

touch regime.

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There's no prior approval requirement,

but there's still a requirement to notify

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CIMA within 21 days

of any transfer or disposal.

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And then finally, CIMA does reserve

its discretion to grant certain exemptions

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from prior approvals

for certain publicly traded licensees.

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So that's kind of the the overarching

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prior approval and notification landscape

in terms of the mechanics

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for regulated entity, they have to file

a change of control application with CIMA.

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And there may be separate

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CIMA divisional approvals

that might be required, depending

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on whether the acquisition involves

multiple regulated licensees or entities.

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So as you can imagine, oftentimes

when there is an acquisition

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of a group of entities,

this does tend to involve

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a number of different types

of semi-regular entities.

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And so to streamline the process,

sometimes we'll prepare

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consolidated application

and then ask for a particular

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CIMA division to to lead the charge there

in terms of the review.

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And now if clients do require

any assistance with that, we do recommend

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that the application is filed quite

well in advance

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because this approval process, as you can

imagine, can take several weeks, up

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to several months just depending

on the complexity of the group

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structure, internal workflows at CIMA.

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And so that's something that our team

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can certainly assist

with preparing as needed.

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And then finally, as as

you noted as well too.

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So some members of our regulatory team,

including myself, we had recently advised

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Desjardins Group

a very involved due diligence process

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and a change of control application

that was filed with CIMA in connection

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with Desjardins acquisition

of Guardian Capital Group limited.

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This involved Desjardins

take private acquisition of Guardian,

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and it was a fairly comprehensive

submission that we had made

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to CIMA across several regulatory

categories.

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So again, to to the extent

that any of our clients do require

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any advice on the due diligence process

or with submissions to CIMA

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we're very happy to help and we're

very experienced in that respect.

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Well, thank you very much, Lisa.

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And yes, I would say it was a big, big

deal that Desjardins done.

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Matt. I say very well done.

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Well, thank you to Dan and to Lisa

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for your very insightful contributions

and to our listeners for listening.

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If anyone does have any further questions,

please do reach out to us

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or just have a look on our Regulatory

Roundup blog for more information.

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Thank you very much.