Changes to Notification Regime for Cayman Companies & Amnesty Period for Late Filings

The Cayman Islands has extended the amount of time in which Cayman Companies have to report changes to directors and officers and reduced the penalties for late filing of these notifications. Cayman Companies have also been granted an amnesty period in which they can attend to any late filings without penalty. The amendments, which were made via the Companies (Amendment) Law 2015, are effective from 2 November 2015.

Key Changes

• The period of time in which companies must notify the Cayman Island Registrar of Companies (“the Registrar”) of changes to directors and officers has been extended from 30 to 60 days.
• The maximum penalty per company for late filing of notification of changes to
  directors and officers has been reduced to CI$500 (US$609.76) and the aggregate penalty for late filings for a group of five or more companies is now capped at CI$2,500 (US$3,048.78).

Amnesty Period
The Cayman Islands Registrar will not impose any penalty fees for the late filing of changes to directors and officers during an amnesty period which expires 30 October 2015. This amnesty applies regardless of when the changes being submitted were made, and how many late changes are submitted.

In addition, unpaid penalty notices issued prior to the start of the current amnesty period will be cancelled. Once the amnesty period expires, the Registrar will strictly enforce the new filing requirements and penalties.

Required Action
Companies that have outstanding notifications of changes to directors and officers should take advantage of the amnesty period and update the Registrar with the necessary information. We recommend that Cayman Islands companies verify that details of any changes in their directors or officers have been provided to their Cayman Registered Office as soon as possible, and before the end of the amnesty period on 30 October 2015.