Coming into line with other jurisdictions, Cayman Islands will now be requiring annual filings for those entities holding or controlling frozen assets, including private funds domiciled in Cayman Islands with shares that are frozen as a result of sanctions issued in the UK (many of which became frozen in March 2022 in conjunction with Russia’s invasion of Ukraine and the consequent listing of a number of Russian oligarchs on the UK OFSI list).
This first annual filing is required to be submitted by November 30, 2025, and the Financial Reporting Authority has provided a template on their website for completion and filing, inclusive of explicatory notes and additional guidance. Though the timeframe between template and guidance release and the initial annual filing deadline is relatively short, the filing is not complicated; with data from your administrator and assistance from the AMLCO for the private fund, or another service provider willing to assist with effectuating the filing on behalf of the fund, all should go smoothly. As with any regulatory filing, there may be a certain amount of nuance to resolve, but with limited fields in the template, the number of questions in need of resolution should be minimal. In sum, the annual filing is simply one more reasonable move on the part of Cayman Islands to standardize the system of frozen assets reporting by tracking these assets across the institutions holding them on an regular basis.