On 7 September 2026, the Cayman Islands Monetary Authority (“CIMA“) issued a General Industry Notice confirming that Restricted Trust Companies (“RTCs“) and Private Trust Companies (“PTCs“) will now be required to complete and submit Anti-Money Laundering (“AML“) Returns. The move forms part of CIMA’s risk-based supervisory approach to AML, countering the financing of terrorism, and countering proliferation financing (“AML/CFT/CPF“), and is designed to strengthen oversight of the fiduciary sector through the collection of entity-level data.
Key Dates and Deadlines
The initial AML Return will be issued to RTCs and PTCs on 1 November 2026, requiring entities to report information as at 31 December 2025. Completed returns must be submitted to CIMA by 31 December 2026.
Distribution
The AML Return will be made available through CIMA’s Strix software and distributed to relevant contacts associated with each RTC and PTC, including Registered Office Contacts, Directors, Anti-Money Laundering Compliance Officers (“AMLCOs“), and Money Laundering Reporting Officers (“MLROs“), among others. Entities should verify that their contact details held with the Authority are accurate and up to date ahead of the distribution date, and may add additional contacts by emailing [email protected].
Future Reporting Cycle
Following the initial submission, RTCs and PTCs will be incorporated into the existing AML Return cycle for the Trust and Corporate Services Providers (“TCSP“) sector. Subsequent returns will be issued on 1 June each year, unless CIMA advises otherwise.
What Should RTCs and PTCs Do Now?
Maples would be pleased to assist with any questions in relation to the AML Return and/or ongoing regulatory compliance requirements for regulated trust companies.
