Cayman FRA sanctions reporting due 30 November

The Cayman Islands Financial Reporting Authority (FRA) published details on 6 November regarding a new annual sanctions reporting obligation for 2025 requiring a Cayman Islands person that holds funds or economic resources owned, held or controlled by a Designated Person (that is, an individual or entity sanctioned by the UK Government) to file a report with the FRA providing details of those frozen assets by Sunday 30 November 2025.

Key details of the new sanctions reporting obligation

The annual reporting obligation will be relevant to (among others) Cayman Islands funds holding underlying assets that are frozen either because the Designated Person owns those assets (for example by way of a legal or equitable interest in the assets), holds the assets (for example assets held on a settlement depository that is itself a Designated Person) or controls the assets, or because the investment fund itself is considered to be owned by a Designated Person (for example through majority ownership by a Designated Person). Impacted persons will need to complete the Cayman FRA form including details of the frozen assets and value as at 30 September 2025.

Next steps

As the first reporting deadline is just two weeks away, relevant entities should consider the FRA's published guidance and check if they are in scope of the reporting obligation as soon as possible. For assistance with assessing whether you are in scope of the requirements, please reach out to your usual Ogier contact or any of the key contacts below.

Similar reporting obligations and deadlines will apply with in scope BVI entities. For more information, contact your usual Ogier advisor in the BVI.