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AML Return Requirement for Restricted Trust Companies and Private Trust Companies

General Industry Notices
Date: Mon, 07 September 2026

The Cayman Islands Monetary Authority (“CIMA” or “the Authority”) advises that the requirement to complete and submit an Anti-Money Laundering (“AML”) Return will be extended to Restricted Trust Companies (“RTCs”) and Private Trust Companies (“PTCs”).

This requirement forms part of the Authority’s risk-based supervisory approach to Anti-Money Laundering, Countering the Financing of Terrorism and Countering Proliferation Financing (“AML/CFT/CPF”) and will support CIMA’s ongoing supervision of the fiduciary sector through the collection and assessment of relevant entity-level data.

Initial AML Return

The initial AML Return will be issued to RTCs and PTCs on 1 November 2026 and will require entities to provide information as at 31 December 2025. RTCs and PTCs subject to this requirement must complete and submit the AML Return to the Authority by 31 December 2026.

Entities are encouraged to review the AML Return and the applicable requirements promptly upon receipt to ensure sufficient time for proper completion and submission by the prescribed deadline.

Distribution of the AML Return

The AML Return will be made available through the Authority’s Strix software and distributed to the relevant contacts associated with each RTC and PTC.

The AML Return will be distributed to the following entity contacts, where applicable:

  • Registered Office Contact
  • Principal Office
  • Directors
  • Anti-Money Laundering Compliance Officer (“AMLCO”)
  • Money Laundering Reporting Officer (“MLRO”)
  • Deputy Money Laundering Reporting Officer (“DMLRO”); and
  • Any additional contacts the entity deems necessary to complete the AML Return

RTCs and PTCs are responsible for ensuring that the contact information and relevant details maintained with the Authority are accurate and up to date. This information should be reviewed in advance of the distribution date to ensure that the appropriate persons receive the AML Return and related communications.

Representatives of the RTC or PTC are therefore encouraged to contact the Authority at AMLReturns@cima.ky to add any additional contacts.

Future AML Returns

Following the initial reporting exercise, RTCs and PTCs will be incorporated into the existing AML Return submission cycle applicable to the Trust and Corporate Services Providers (“TCSP”) sector. Subsequent AML Returns will therefore be issued on 1 June of each year, unless otherwise advised by the Authority.

RTCs and PTCs are expected to comply with the applicable submission requirements and deadlines communicated by the Authority for each reporting period.

Additional Information

RTCs and PTCs are encouraged to familiarise themselves with the applicable AML/CFT/CPF requirements and CIMA’s guidance relevant to the fiduciary sector. Further information and regulatory resources are available through the Authority’s Regulatory Forms Completion Guides.

Any questions regarding the AML Return or the requirements outlined in this Notice may be directed to AMLReturns@cima.ky. 

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