January– CIMA & Registrar of Companies Fees
CIMA fee January 15 of each yearAnnual Return Fee January 31 of each year Registered Office Fee Each CIMA Fund (and the SIBL Manager) must pay the annual fees to CIMA by 15th of January each year to avoid penalties and fines. The current fee for a fund is US$4,269 and a SIBL is $6,098.The Annual Return fees to Registrar of Companies are payable in January of each year to keep the entities in good standing.The Registered office fee is also due annually in advance.
March -  Registrar of Companies Penalties &/AML Officer Report
March 31 of each year Registrar applies penalties in March of each year for not making the Annual Return on time.
AML Officers reports For each fund at least twice per year the AML Officers should advise the director of the steps taken during the prior period.
May – AEOI Deadline
AEOI reports May 31 of each year The AEOI (FATCA & CRS reports) 2020 deadline is 31 May 2020 however for 2019 year the filing was extended to 31 July 2019 without penalty although the deadline remained the same.The Principal Point of Contact (PPoC) role is essential for the FATCA and CRS reporting obligations to the Cayman Islands Automatic Exchange of Information Portal. The CRS reporting obligations are now much wider and catch almost all investors. The best solution for reporting is to have the Administrator prepare the xml reports for CRS and FATCA. Where there is no FATCA reportable investors then a nil report is not required.
June – CIMA filing of audited financial statements
CIMA Audit Requirement – 30 June  The requirement is to file audited financial statements for each fund with CIMA within 6 months of year-end or to apply for an audit waiver in advance of the deadline. The audit requirement is very strict and CIMA have penalty and fine powers for late filings and therefore this must be a top priority for all funds.If an audit extension is required the fee is US$610 – similarly for an audit waiver (for no investors) the fee is US$610.
July – Final AEOI Reporting
AEOI reports for 2019 ONLY AEOI filing can be made up to 31 July 2019 without penalty.
AML Officers reports For each fund at least twice per year the AML Officers should advise the director of the steps taken during the prior period.
Director CIMA registration renewal – has to be made prior to the next year commencing Each director of the Fund must register as directors with CIMA and keep their registrations up to date. In practice this means renewing the registration of each December. Also when any entity or any personal information changes a director must login and updating the required information.Now that CIMA have penalty and fine powers this must be a top priority as they can bar the director from acting on an entity for failure to comply. Please also note this is a personal requirement and only the director themselves can login and pay and make the required representations. Also upon termination of a fund (or SIBL) they act for then they must also follow the de-registration process.The CIMA Director Gateway can be found:




Ongoing - Now required for Funds
CRS Policies and Procedures Each fund must adopt their own CRS Policies (MG has a template if required). The Tax Information Authority do audits to ensure that each registered entity has a CRS policy.
AML Training for Directors Each fund Director now has a compulsory AML CTF (Counter Terrorism Financing) training requirement on at least an annual basis. All Cayman Islands based Directors receive this by the applicable regulations already.
AML Officers appointed The CIMA Guidance requires all funds to have made the AML Officer appointments. The deadline has passed (31 December 2018; for non-CIMA funds 30 September 2018). CIMA require registered funds must file on the CIMA REEFs system via the registered office. Non-CIMA registered funds can simply notify the registered office for now. This applies to all news funds.
Beneficial Ownership Declaration – 2020 A Beneficial Ownership Declaration for the beneficial ownership is required by the registered office and to be notified of any changes. The registered office files this directly with the Cayman Islands Government. Basically, this means that the all funds registered with CIMA are out of scope and only management companies are in scope and the owners of those are reportable.
CIMA statement of Guidance for Directors of a fund – in effect The CIMA statement of guidance can be found HERE. It sets out basic minimum standards that Mutual Fund Directors must following including the requirement to hold at least 2 board meetings annually.
Economic Substance (funds)  Although the law is in effect the rules are likely to change during the summer of 2019 – however it is clear that all funds registered with CIMA will remain out of scope of the Economic Substance Law and requirements.
SIBL Management companies only:
January 2020
Changes to SIBL Structure – January 2020 (in effect December 2019 at the latest)  From January 2020 a SIBL Manager will no longer be an “Excluded Person” but requires to re-register with CIMA to become a “Registered Person”.See further information on MG’s site HERE
Economic Substance   The Economic Substance Law in the Cayman Islands is now in effect, but the guidance is currently being updated and no steps should be taken until those are released. In any event what will remain the same is that CIMA registered funds will be out of scope and the SIBL Managers will be in scope.See a brief overview of the probable steps on MG’s site HERE (subject to change).