New Reporting Requirement for Cayman Private and Restricted Trust Companies

At a glance

The Cayman Islands Monetary Authority (CIMA) introduces Anti-Money Laundering Return requirement for Private Trust Companies (PTCs) and Restricted Trust Companies (RTCs)
The first return will be issued on 1 November 2026 and must be submitted by 31 December 2026
Subsequent returns will be issued annually on 1 June and must be completed by year-end

The Cayman Islands Monetary Authority (CIMA) has announced that private trust companies (PTCs) will now be required to complete and submit an Anti-Money Laundering (AML) Return. PTCs were previously exempt from this requirement.

This change brings PTCs into CIMA’s existing AML reporting cycle and aligns their treatment with that of other trust entities, creating a more consistent reporting framework across the sector.

Initial return process and deadlines

CIMA will issue the first AML Return to PTCs on 1 November 2026. The return will be sent by email link to each entity’s registered contact and will be made available through CIMA’s Strix platform.

Entities will be required to complete the return using information based on the entity’s position as at 31 December 2025 and submit it by 31 December 2026.

CIMA has asked entities and operators to ensure that registered contact details are up to date ahead of the distribution date.

Future returns

After the initial filing, PTCs will be incorporated into the existing AML Return cycle for the trust and corporate services sector. Subsequent AML Returns will be issued on 1 June each year and must be completed by the end of that calendar year.

Penalties for non-compliance

Failure to submit the required information may result in administrative fines of up to:

US$100,000 for individuals
US$1 million for corporations

Conclusion

These latest changes are part of an accelerating global trend towards increasing regulatory oversight of PTCs.

FAQs

Which entities have been brought under CIMA’s anti-money laundering reporting return requirement?

Restricted trust companies and private trust companies.

What are the key dates for the first return?

The first return will be issued on 1 November 2026 and must be submitted by 31 December 2026.

What is the reporting cycle for subsequent returns?

Following the submission of the initial return, PTCs and RTCs will join the annual reporting cycle already in place for the trust and corporate services sector. Subsequent returns will be issued annually on 1 June and must be completed by the end of that calendar year.