Who will under take the PPoC role for the FATCA and CRS reporting obligations to the Cayman Islands Automatic Exchange of Information Portal. The have rules changed and were much wider. Will the new Administrator prepare the xml reports for CRS nor FATCA. The administrator usually undertakes this service. There is no fees paid for the filing although the administrator and Principal Point of Contact would customarily receive a fee.
The 2019 deadline is 31 May 2019 (extended to 31 July 2019 without penalty)
New requirement to have AML Officers 
The attached CIMA Guidance requires the AML Officer appointments, which applies to this fund even although its not registered with CIMA see the first section. If the administrator will not provide this service which sounds like they will not then a third party is required to provide these services. The deadline has passed (31 December 2018 for non-CIMA funds 30 September 2018)). CIMA 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.
A reminder on the ongoing fund obligations:
- 30 September 2018 / 31 December 2019 – Appoint 3 AML officers. This can be 2 persons for the 3 roles. – The fees for these service to third parties is usually $6,000 per year and if the administrator provides they usually do so at a discount.
-  30 September 2018 – The fund must adopt its own AML Policy – usually included with AML officers
- the fund must adopt its own CRS Policy
- January 2019 - Beneficial Ownership Declaration for the beneficial ownership register to registered office provider  – done?
- by 31 May 2019 – PPOC must File FATCA and CRS reportable persons or CRS nil declarations  (If not FACTA then no nil filing required) we need reports from the administrator
- twice per year the AML Officers should advise the director of the steps taken during the prior 6 months included in annual fee