Scope and applicability: The RSOG applies to all entities with Trust and Company Management Licences under the relevant Cayman Islands Acts. It allows for group-wide recruitment practices if they meet local regulatory requirements.

Recruitment policies: TCSPs and Company Managers must have documented recruitment policies approved by the governing body, emphasising transparency, competence, and adherence to legal requirements. This includes thorough assessments of candidates for “Key Persons” roles, such as Directors or Compliance Officers, and annual reviews of their qualifications and performance.

Post-recruitment oversight: Employers must ensure that Key Persons remain fit for their roles through annual reviews and immediate notifications to CIMA of any significant adverse changes. Updated job descriptions and clear reporting lines support ongoing supervision and role clarity.

Continuing professional development (CPD): Entities are required to implement CPD policies that facilitate ongoing training for employees. The CPD framework must address evolving legal and industry standards and may include internal and external training activities like workshops, conferences, or professional courses.

Record-keeping: Proper documentation of recruitment and CPD activities is essential, as outlined in the RSOG. These records support compliance and demonstrate that recruitment and development efforts align with regulatory expectations.

Enforcement: Any breaches of the RSOG will be managed according to CIMA’s enforcement policies, with potential penalties for non-compliance.

Effective date: The RSOG will become effective six months post-publication, allowing entities time to align their practices with the new standards.

The guidance can be found here.