Cayman Islands Introduces The Mandatory Disclosure Rules For CRS Avoidance Arrangements And Opaque Offshore Structures

In January 2024, the Cayman Islands government published the responses to the 2^nd round of consultations on the Mandatory Disclosure Rules (MDR) for Common Reporting Standard (CRS) avoidance arrangements and opaque offshore structures. The introduction of the MDRs is part of the Cayman Islands' commitment to adopting OECD-style Model Rules.

Each of the Cayman International Reinsurance Companies Association (CIRCA), Maples Group, Alternative Investment Managers Association (AIMA), Insurance Managers Association Cayman (IMAC), and the Cayman Islands Monetary Authority (CIMA) provided feedback. Industry representatives focussed their responses on:

• Definitions: One of the primary concerns raised was the need for clarity on various terms, particularly "intermediary" and "client." Stakeholders sought guidance on the scope and interpretation of these terms within the context of the proposed regulations. In response, the Cayman Islands government acknowledged the