The BOT Act will be brought into force through implementing regulations during 2024 and we anticipate that there will be a transition period for affected entities to comply with the new law. Important to note is that, whereas previously the Cayman Islands beneficial ownership reporting regime only applied to companies, it now applies to limited partnerships and limited liability partnerships and many of the previous exemptions have now been replaced with enhanced paths to compliance for vehicles such as investment funds.

In a Ministry of Financial Services and Commerce press release, the Hon. André Ebanks, emphasised the partnership with the UK and Overseas Territories to protect the global financial system in reaching this point.

The passing of the BOT Act highlights the Cayman Islands contribution to transparency and compliance with the UK's commitment and the Financial Action Task Force's (FATF) standards. The Cayman Islands' framework is acknowledged by both the FATF and the UK Government for its effectiveness.

In response to a previous European Court of Justice judgment, the Cayman Islands is progressing to provide access to the public, subject to a "legitimate interest test." A similar approach is also being taken in other UK Overseas Territories and Crown Dependencies.

The Beneficial Ownership Transparency Act 2023, can be found here.

Please get in touch with our Cayman Islands regulatory specialists if you have any questions.