Published

MFA Submits Comments to Cayman Finance Ministry on Creation of a Centralized Platform of Beneficial Ownership Information

On January 5, MFA submitted a letter to the Cayman Ministry of Financial Services in response to its Public Consultation on Legislative Amendments to Enable the Creation of a Centralised Platform of Beneficial Ownership Information. In the letter we provided recommendations that would make the proposal more workable for managers, which include:

  • Seeking additional guidance as to the “reasonable steps” a company must take to identify beneficial owners
  • Requesting an extension for beneficial owners to provide information to a company to 60 or 90 days
  • Supporting the proposed 25% reporting threshold for beneficial ownership information
  • Recommending that, due to the risk of cyberattacks and the potential for illegal disclosure of confidential information, a beneficial owner be permitted to provide a business address as an alternative to a residential address
  • Supporting the proposed five year time period for maintaining beneficial ownership information for persons that are no longer registerable
  • Recommending other technical clarifications to simplify compliance with the requirements