Recent Cayman Islands legislative amendments introduce important
changes to the regulatory and supervisory framework applicable to
Cayman Islands fund managers registered as 'excluded
persons' under the Securities Investment Business Law. This
article considers the impact of these changes, including with
respect to the application of economic substance requirements to
such entities and some of the options available.
Background
In June this year, the Cayman Islands Government passed
amendments to the Securities Investment Business Law
("SIBL") introducing important changes
to the regulatory and supervisory framework applicable to persons
registered as "excluded persons" under SIBL
("Excluded Persons"). These amendments
replace the existing category of Excluded Persons with a new
category applicable to broadly the same group of entities who are
now instead required to apply for registration, or re-register, as
"registered persons" ("Registered
Persons") by 15