New record-keeping rules for company management licensees came into full effect at the beginning of April, and now apply to established licensees as well as those licensed after the rules were published in August 2023.

The new rules were published last August with immediate effect for newly established licensees under the Companies Management Act, Banks and Trusts Companies Act, Mutual Funds Act and Insurance Act. They have now taken effect for existing licensees as well, though regulated mutual funds and private funds are exempt.

The guidance from the Cayman Islands Monetary Authority (CIMA) sets its minimum expectations for record-keeping, although without prescribing specific arrangements. The records must be legible, easily accessible and maintained using an appropriate system that addresses categorisation, retention periods and disposal of rcords. The system and procedures must also comply with the jurisdiction's Data Protection Act. Record-keeping should be reviewed arrangements annually and adjusted where necessary, especially where third parties are involved.........