Cayman Islands Issues General Sanctions Licence For Funds Industry

On 4 October 2022 the Governor of the Cayman Islands issued General Licence GL/2022/0001 for the Cayman Islands Funds Industry (the "General Licence") which provides relief from aspects of the financial sanctions imposed in the Cayman Islands by the Russia (Sanctions) (Overseas Territories) Order 2020 (the "Order"). The issue which the General Licence addresses is where a Designated Person owns more than 50% of an investment fund which has hitherto meant that the fund is paralysed and all of its assets are frozen. This affected minority non-designated investors in such funds who could not redeem their shares and also prohibited the frozen funds from complying with many of their statutory obligations such as the payment of registered office fees. This was clearly an unintended and unjust effect of the sanctions regime on the Cayman funds industry and we commend the Cayman Financial Reporting Authority for its painstaking work in delivering what is the Cayman Islands'