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CIMA surveys, frozen assets reporting, the VASP regulatory forum, year-end reminders, and Cayman FSPs
Episode 24 • 14th November 2025 • The Regulatory 15/15 • Maples Group
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In this episode, we discuss CIMA surveys, frozen assets reporting, the VASP regulatory forum, year-end reminders, and Cayman FSPs – preparing for the FATF fifth-round review.

SPEAKERS:

Adam Huckle, Partner | +1 345 814 5318 | adam.huckle@maples.com | View bio

Anthony Mourginos, Partner | +1 345 814 5155 | anthony.mourginos@maples.com

| View bio

Jo Ottaway, Associate | +1 345 814 5511 | jo.ottaway@maples.com | View bio

RESOURCES:

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

RELATED SERVICES:

Maples Group Regulatory and Financial Services Advisory

With a depth of experience across all regulated sectors, the Maples Group Regulatory and Financial Services team is positioned to address client needs and sensitivities. We have the largest dedicated Cayman Islands Regulatory and Financial Services team in the offshore market.

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

Blog: https://maples.com/regulatory-round-up

Transcripts

Speaker:

Hello and welcome to the Regulatory

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15/15 podcast.

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My name is Adam Huckle,

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and I'm a partner

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in the Regulatory

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and Litigation teams here

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at Maples and Calder

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in the Cayman Islands.

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Joining me today

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is my fellow regulatory

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partner Don Mourginos,

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and one of our senior

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regulatory associates, Jo Ottaway.

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In this edition of the podcast,

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we will cover

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the latest developments

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in regulatory laws

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that have taken place

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in the Cayman Islands

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since the last 15/15 episode,

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which aired in October of this year.

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That will include

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CIMA surveys,

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a new sanctions

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reporting requirement,

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the VASP Regulatory Forum,

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plus year end reminders

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and a note on the FATF

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Fifth Round Review.

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A bit of housekeeping before we begin,

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please note

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that the contents of this podcast

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do not constitute legal advice

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and should be taken

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as a general update only.

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And also,

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please don't forget to subscribe

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and rate us on Apple Podcasts or Spotify.

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For timely regulatory

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updates across Cayman,

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the BVI, Luxembourg, Ireland and Jersey,

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visit our Regulatory Round-up

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blog at maples.com or click the link

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in this episode's description.

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And now over to you, Don.

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With, updates on

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two recent CIMA circulars.

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Thanks, Adam.

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Yeah, just a quick one.

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In October of this year,

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just a couple of days

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after our last 15/15

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podcast, CIMA

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published two interesting notices

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in relation

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to two separate sectoral service

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surveys,

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each of which had a

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31, October deadline.

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So they're all closed

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now, but it's worth mentioning

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that they occurred and talk about them,

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at at least at a high level.

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So the first survey,

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was the Cayman Islands Virtual Asset

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Sector Survey,

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which was conducted in collaboration

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with the office for Strategic Action

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on Illicit Finance.

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As part of the

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Cayman Islands National Risk

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Assessment for 2025 and 2026.

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This survey,

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sought to gather information

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from entities

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that are engaged in virtual asset,

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related activities,

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with the goal

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of improving the understanding

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of set

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the specific operations,

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exposures and associated risks.

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So I suspect that,

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quite a number of our clients,

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will have received this survey

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and hopefully completed the survey.

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So it will be interesting to see, once

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CIMA publishes

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some of their findings

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coming out of the survey

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and some of the results.

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So we wait to see for that.

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The second survey, was circulated

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by CIMA on behalf of the Ministry

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of Financial Services.

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Which is actually done in collaboration

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with the International Monetary Fund.

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In that survey,

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CIMA sought feedback on factors

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that may make

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the Cayman Islands

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vulnerable to money

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laundering and terrorist financing,

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through, legal persons

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and legal arrangements

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and the effectiveness of the measures

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that we currently have in place

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to mitigate these risks.

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This is all in the context of,

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the, the, the upcoming National Risk

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assessment for 2025 and 2026.

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So that's

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all I really wanted to say,

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on these surveys

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justified that they exist.

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They're closed now.

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So we wait to see some of the results.

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Adam,

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I think I'm throwing over to you

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to talk about the frozen

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asset reporting for 2025.

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That's right.

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Thanks, Don.

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There is a new sanctions

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reporting obligation

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for 2025 in the Cayman Islands.

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This is the first year of what's called

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the Annual Frozen Asset

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reporting exercise, or FAR.

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And that requires a Cayman Islands

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person that holds funds

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or economic resources

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that are owned, held

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or controlled

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by a designated person, i.e.,

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an individual entity sanctioned by the UK

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to file a report with the Financial

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Reporting Authority

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providing details of those frozen assets.

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Now the deadline for doing

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so is quite tight.

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It is on Sunday,

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the 30th of November of this year.

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And as I said,

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this will be an annual

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reporting obligation on the same date

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each year.

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That reporting obligation will,

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by way of non-exhaustive examples, apply

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to Cayman Islands banks

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that hold frozen cash,

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or to Cayman Islands investment

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funds that hold underlying assets

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that are frozen,

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either because the designated person

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has a legal or actual

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interest in those assets,

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or because the investment fund itself

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is deemed to be directly

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or indirectly owned by

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a designated person.

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Now, on the 6th

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of November of this year,

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the FRA published an explanatory note

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on the new FAR reporting regime,

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which is available on the FRA’s website,

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as well as the Cayman specific form

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which is in Excel format.

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And the reason I say

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Cayman specific form

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is this FAR

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reporting exercise

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is something that in the UK

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has been applicable to UK entities

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for several years.

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The reporting itself

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is relatively straightforward.

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The Excel includes

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details of the relevant frozen assets,

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including, importantly,

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confirmation of their value

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as at close of business

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on Tuesday, the 30th of September 2025.

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Other assets that you might hold

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that are frozen

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solely as a result of other jurisdictions

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sanctions laws.

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So US OFAC the EU, Canada, etc.

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do not form

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part of the FAR and of the FAR exercise,

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so don't need to be included

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and the completed report

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can be filed with the FRA

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simply by emailing it

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to financialsactions@gov.ky.

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If you would like, our

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expertise, we have significant experience

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in advising on Cayman Islands

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sanctions law.

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So please do reach out

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if you would like to check

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if you're in scope of this FAR exercise,

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or if we can be of any

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further assistance.

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Don, I'm hitting the ball back

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across the net to you.

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On your next topic.

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So another,

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kind of an industry update.

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Just a few days ago,

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CIMA hosted a VASP Regulatory Forum,

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for industry participants in person,

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as well as virtually.

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So, it's very interesting

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to see some of the topics

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being covered by CIMA

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they're very helpful indeed.

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So I thought useful

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just to cover off what,

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you know, our, our listeners,

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might find interesting

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coming out of that,

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there was a focus on

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the VASP registration

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application process itself.

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And CIMA,

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was was very helpful

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in identifying

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some of the recurring issues

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that they've noticed

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with, applicants filing

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registration applications.

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So,

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they highlighted that they've received

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some incomplete submissions.

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Some of the information

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they received didn't

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clearly show

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group structures

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and beneficial owners or,

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didn't include,

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some information

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that they necessarily need.

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So CIMA was,

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was very keen

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to make certain recommendations

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for applicants

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who are considering

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making an application.

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Engage

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early with CIMA. CIMA were very keen,

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in fact,

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it's it's a requirement

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of any registration application

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to engage with CIMA, discuss

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your plan, discuss your business.

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and it's only after CIMA,

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give it effectively

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giving you have given you the green light

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after that initial application

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or initial discussion with them

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that, a broader

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application should be made.

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When you are

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making your application for registration,

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be as transparent

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as you possibly can with respect to your,

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your group structures

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and any other jurisdictions

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that entities in your structure

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are regulated in.

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Ensure that you have three directors

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lined up.

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So at least one being independent,

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and having technical expertise

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in the area of virtual assets

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services

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that you are proposing

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to conduct yourself in.

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Ensure that your written policies,

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procedures are available, are in place

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and are provided to CIMA.

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Part of the application

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CIMA do require them

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upfront as part of the application,

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so have them ready.

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And be prepared to answer any questions

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that Sema have about the business itself.

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Obviously, Maples, we

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we have,

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great experience in helping clients

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with registration applications.

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So if that is, on your mind,

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if you are the assistance

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with respect to an application,

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in the best context,

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feel free to reach out.

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Another aspect that, CIMA did

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focus on,

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is kind of

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what's coming up in the future.

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So they highlighted some of the forms

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and AML forms that they have updated,

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which enhance the question

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and the question that they ask

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as part of the application process,

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specifically with respect to AML.

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And they did ask that,

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entities that are registered

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under the VASP regime,

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remind themselves of the,

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ongoing obligations

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that apply to VASP, in particular,

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an obligation to notify

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CIMA or indeed get pre-approval from CIMA

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with respect to key officer appointments.

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So something to certainly be aware of.

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The other point,

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which I think is worth noting

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is that CIMA did confirm that all VASPs

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So all registered a licensed

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VASPs in the jurisdiction

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will be inspected

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before the next effect,

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the fifth round of FATF inspections.

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So, very useful to know

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that anyone

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who is registered or licensed as a VASP

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will be subject to senior inspection.

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So certainly worth

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preparing for that,

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making sure that all your policies

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and procedures are up to date.

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All your documentation is spick and span.

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Again, Maples can assist with,

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anything to do with that as well.

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So do feel free to reach out.

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So that's all I wanted to say about the,

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VASP Regulatory Forum.

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It's staying with me now

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because I think

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we wanted to just provide our listeners

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with a very quick reminder

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as we approach

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the end of the year,

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of all the various end

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of year obligations

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that come up in the regulatory space,

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in the Cayman Islands.

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So I'm sure our listeners are well aware,

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we're generally approaching,

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economic substance

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return filing

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for those entities

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that do have,

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or are relevant entities

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conducting a relevant activity

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that do have a, 31st

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December financial year end.

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We will be approaching the time

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for,

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filing your 2024

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Economic Substance Return.

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So be reminded of that.

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Don't forget, again, Maples can assist

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with filing that return

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or answering any questions

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you have with respect to it.

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And, we've now

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passed the,

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the general, filing dates

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for that currency year.

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But a reminder about them

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nonetheless, because we have seen,

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a heightened level of activity

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from the DITC in issuing breach

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notices and penalty

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notices to clients

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who have

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missed reporting obligations

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or missed compliance

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form filing obligations.

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So do keep that on the radar.

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Put that in the calendar.

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Make sure we don't miss it. Yeah.

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So a couple of things there

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just to be aware of

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as we approach the end of the year

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and to keep things in the diary

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for regulatory obligations,

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going forward,

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as our last topic, I'm

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going to throw over to,

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my colleague Jo, to talk about,

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all the various ways

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that we're preparing for the

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FATF Fifth Round Review.

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Jo, over to you.

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Thanks, Don.

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Yeah,

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So our final update

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concerns the upcoming fifth

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round FATF

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mutual evaluation to be held

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at the end of 2027.

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So, as you may or may not be aware of,

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the Cayman Islands is actively preparing

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for the mutual evaluation,

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which will focus on the effectiveness

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of the Cayman Islands

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implementation of laws,

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regulations and other measures

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relating to anti-money laundering,

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counter-terrorism financing,

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counter- proliferation

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financing and sanctions.

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Now, CIMA has recently

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reactivated its blog,

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and it's encouraging

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all financial service providers

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to prepare for the upcoming

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mutual evaluation.

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In particular, CIMA is encouraging

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financial service providers

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to ensure that they have documented

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AML policies and procedures in place,

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and, importantly,

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that they can demonstrate

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the effectiveness of those mechanisms.

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And this would generally be

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by way of an AML audit,

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which,

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of course is a requirement

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under the AML regulations.

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CIMA is also encouraging board level

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awareness of the upcoming FATF

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mutual evaluation process,

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as well as participation

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and natural, sorry,

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as well as participation

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in national pre-evaluation

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initiatives and risk assessments.

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CIMA is also

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encouraging financial service

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providers to ensure that they have access

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to information, data,

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statistics and case studies

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for up to five years

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before the onsite inspection,

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which can

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validate the effectiveness

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of their practices.

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CIMA is also requiring financial service

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providers to be able to evidence

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that an entity

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wide risk assessment,

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including, as regards proliferation

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financing risks, has been conducted.

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And as with all risk assessments,

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the risk assessment

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must remain up to date,

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consider current, and evolving

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threats and sanctions requirements.

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Financial

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service providers should also ensure

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that there are adequate mechanisms

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in place

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for the collection, verification

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and retention of accurate

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beneficial ownership information

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for legal persons and legal arrangements

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which can be easily accessible

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when requested by CIMA

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or other authorities.

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And CIMA is also,

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requiring financial service providers

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to make sure that all staff

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are aware of recent amendments

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to AML legislation.

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So, for example, as regards

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the recent DAML consent changes,

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and that they are trained on

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any subsequent

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revised AML policies,

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procedures and controls.

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And lastly, CIMA

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is encouraging

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financial service

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providers to take a proactive approach

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to the upcoming

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national risk

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assessment of money laundering,

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terrorism financing and proliferation

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financing risks

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that will be conducted

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prior to the on site assessment.

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As the findings of the National Risk

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Risk Assessment will assist

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financial service providers

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in conducting their own entity

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wide risk assessments.

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So if you have any questions

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regarding the practical steps

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that your business should be taking

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to prepare for the FATF’s

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Fifth Round Mutual Evaluation,

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please do feel free

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to get in touch with us.

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We're very happy to help,

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and we have a range of tools

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that could be of assistance to you.

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Thank you.

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So that concludes today's episode.

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Thank you to my colleagues, Don and Jo

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for their very helpful contributions.

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And to our listeners,

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thank you for listening.

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If you've enjoyed the episode,

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please do rate us and subscribe,

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and we'll be back next month

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for another round of 15/15.

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And the meantime,

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please

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make sure to visit our Regulatory

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:

Round-up blog

526

:

for timely regulatory

527

:

updates at maple.com,

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:

or click the link

529

:

in this episode's description.

530

:

Many thanks.

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12. Russia Sanctions - New Specific Licensing Ground (Divestment), DITC Bulletin and Ongoing Enforcement, New CSV Technical Guidance on Beneficial Ownership Filings, FATF Recommendations 15 and 24
00:18:03
11. Updates on CIMA, Tax Information Authority and Beneficial Ownership, also information on AML Guidance Notes and Consultations
00:16:25
10. EU AML Delisting, Proceeds of Crime Act Amendment, AML Amendment Regulations, Economic Substance Update
00:11:07
9. EU AML Delisting, Changes to Beneficial Ownership Transparency Act, 2023 and CIMA's Supervisory Information Circular on AML/CFT Remediation
00:09:35
8. FATF Grey List Removal and Overview and Comparison of Corporate Transparency Act with Cayman Islands' Beneficial Ownership Regime
00:24:47
7. CIMA's new rules and statements of guidance that come info effect 14 October
00:30:50
6. BOT Bill, Revised AML Guidance Notes, CIMA Governance and Internal Controls and the UK Sanctions Update
00:22:50
5. FATF, OECD and BOR Updates, DITC: CRS and ES Developments, Approved Stock Exchanges, CIMA Governance and Controls
00:16:21
4. CIMA AML Surveys, DITC FI Registration Audit, AEOI Reminders, SIBA PR Inspections and FAR Deadline
00:16:15
3. FATF Update, Corporate Governance & Internal Controls, Data Protection and Proposed New Bills
00:21:53
1. bonus BONUS EPISODE - Failure of Silicon Valley Bank. Background, issues and next steps.
00:11:50
2. Updates on Sanctions, CIMA, AEOI & Silicon Valley Bank. CIMA (Amendment) Bill, 2023
00:19:33
1. FATF Plenary Sessions, CIMA Letters, DITC Breach Letters, OECD Mandatory Disclosure Rules and Sanctions Licence
00:14:10