From 7 August 2020, the Cayman Islands Private Funds Law 2020 requires closed-ended investment funds domiciled in the Cayman Islands to register with the Cayman Islands Monetary Authority (CIMA). Funds are required to comply with the following operating conditions:

• Implementation of appropriate and consistent valuation procedures which must be carried out at least annually
• Safe keeping of fund assets including holding custodial assets in custody and verification of ownership and title of all other assets
• Monitoring of cash flows, including the checking of cash accounts and receipt of investor contributions
• Appointment of a Cayman Islands registered auditor.

These functions may be carried out by the manager of the private fund subject to independence from the investment management function as well as the identification, management, and disclosure of any conflicts to investors. Alternatively, they may be outsourced to a third party such as INDOS Financial.

We have significant fund oversight experience in each of the areas required by the Private Funds Law:

• Custody – we can provide custody solutions through our network of sub-custodians, or introduce firms to a suitable custodian for their needs
• Asset verification – we are skilled at the verification of the ownership and title of many types of fund assets across international markets
• Cash flow monitoring – we have established connections with many banks that enable us to independently obtain and monitor cash flows of a fund
• Valuation – we are experienced in oversight of the application of the valuation policy of the fund and we partner with a specialist firm should a full independent valuation be required

Our parent company, JTC, has an established Cayman team who offers international fund and incorporation services, as well as a wide variety of professional services to clients around the world. Find out more here.