The Cayman Islands Parliament has approved the Beneficial Ownership Transparency Act (BOT
Act), as a restatement and enhancement of Cayman's beneficial
ownership regime.
The BOT Act is not yet in force, pending a commencement order,
so for now Cayman's existing beneficial ownership transparency
obligations will remain in effect (see our full briefing on the Cayman Islands Beneficial Ownership
Regime).
However, all Cayman entities should assess how the BOT Act will
apply to them, as the regime will be extended to some types of
entity that were previously excluded – we outline the key
changes below.
Timing
Regulations and guidance notes to support the BOT Act are
expected to be developed in the first quarter of 2024; and
implementation of the BOT Act is expected to commence, on a phased
basis, through the second half of 2024. We will provide a further
update as to specific actions to be taken once the details of the
regulations and guidance notes have been
