Regulatory Blog

The Sanctions Order 2025 was published on 12 December 2025 and came into force on 11 December 2025. This updates the sanctions framework that applies across UK Overseas Territories, including the British Virgin Islands, Cayman Islands. The changes are also relevant to, by local extension, to Bermuda.

On 3 December 2025, the Department for International Tax Cooperation announced the activation of the Country-by-Country Reporting functionality on the DITC Portal. This functionality is effective as of 3 December 2025. This update is critical for Multinational Enterprise Groups with Cayman Islands Constituent Entities.

The Cayman Islands Monetary Authority (CIMA) has officially implemented the Virtual Asset Service Providers (VASP) financial returns form, effective 1 December 2025. This form, accessible via the REEFS system under code VFR-051-84, standardises the submission of periodic financial data for entities registered or licensed under the Virtual Asset (Service Providers) Act (2024 Revision).

On 27 November 2025, the Cayman Islands published two pivotal regulations aimed at improving global tax transparency: the Crypto-Asset Reporting Framework and amendments to the Common Reporting Standard. Effective 1 January 2026, these regulations are designed to combat tax evasion and the misuse of virtual assets.

On 13 November 2025, the Cayman Islands Ministry of Financial Services and Commerce, following recent consultations on the amended Common Reporting Standard and the new Crypto-Asset Reporting Framework, published and acknowledged the valuable and constructive feedback provided by industry stakeholders.

Following the invasion of Ukraine by Russia, the UK Government, alongside the member states of the European Union, the United States of America and other global stakeholders issued significant new sanctions. View a table of all the sanctions here.

European Union has issued significant and far-reaching sanctions and restrictive measures on Russia and the Russian Economy. View a table of all the sanctions here.

The Cayman Islands Monetary Authority released a desk-based review of the Virtual Asset Service Providers to assess compliance with the Virtual Assets Act and related regulations in November 2025. The review, covering 11 entities, focused on corporate governance, internal controls, cybersecurity, financial stability, and virtual asset custody arrangements.

On 7 November 2025, the Cayman Islands Government announced fee adjustments across the financial services sector to ensure proportionality, align with international standards and improve administrative efficiency by simplifying compliance and reducing the administrative burden. These changes will take effect progressively from 1 January 2026.

On 15 October 2025, the UK intensified its sanctions against Russia, targeting key sectors of its economy in response to the ongoing conflict in Ukraine. These measures aim to undermine Russia's ability to fund its military operations while signalling the UK's commitment to global security and peace.

On 6 November 2025, the Cayman Islands Financial Reporting Authority published a notice requiring all entities holding frozen assets linked to Designated Persons under UK sanctions law to submit an annual report. This measure is part of global efforts to combat financial crime, terrorism financing and human rights abuses. Here is what you need to know:

The Cayman Islands Monetary Authority recently announced the withdrawal of the temporary allowance for operator letters in place of notarised affidavits for fund registration and licensing applications. This measure, introduced during the COVID-19 pandemic, ceased on 15 October 2025.