• Cayman Islands: Annual AML Return Requirement Introduced for RTCs and PTCs

Cayman Islands: Annual AML Return Requirement Introduced for RTCs and PTCs

THE CAYMAN ISLANDS MONETARY AUTHORITY (CIMA) HAS ANNOUNCED THAT CAYMAN ISLANDS RESTRICTED TRUST COMPANIES (RTCS) AND PRIVATE TRUST COMPANIES (PTCS) WILL BE REQUIRED TO COMPLETE AND SUBMIT AN ANNUAL ANTI-MONEY LAUNDERING (AML) RETURN.

The new requirement forms part of CIMA's ongoing risk-based supervisory approach to AML, countering the financing of terrorism (CFT), and countering proliferation financing (CPF). The AML Return will enable CIMA to collect and assess information from RTCs and PTCs as part of its supervision of the fiduciary sector.

INITIAL AML RETURN

The first AML Return for RTCs and PTCs will be made available through CIMA's Strix portal on 1 November 2026.

The initial filing will require entities to report information as of 31 December 2025, and completed returns must be submitted to CIMA by 31 December 2026. Given the breadth of information expected to be requested, RTCs and PTCs should ensure that they allow sufficient time to review the return, gather the relevant information, and complete the filing ahead of the deadline.

ONGOING ANNUAL FILING REQUIREMENT

Following the initial reporting exercise, RTCs and PTCs will become part of the standard AML Return reporting cycle applicable to the Trust and Corporate Service Provider sector.

Unless otherwise advised by CIMA, future AML Returns will be issued annually on 1 June, with completed returns due by 31 July.

HOW TRIDENT CAN ASSIST

Trident can support RTC and PTC clients with the completion and submission of the AML Return, including the upload of the required information to CIMA's Strix platform in advance of the filing deadline. The AML Return will be issued directly by CIMA through the Strix platform to the directors of the relevant RTC or PTC, as well as any other designated contacts, including the Principal Office contact and AML officers, where applicable.

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