{"kind":"expression","expression":{"expr_id":"302","doc_id":"302","label":"SL 42 of 2023","is_as_enacted":"t","commenced_on":null,"superseded_on":null,"valid_from":null,"valid_to":null,"is_current":"t","incorporating":null,"akn_expr_iri":"\/akn\/ky\/act\/sl\/2023\/42\/eng@2023-01-01","akn_envelope":"{\"_canary\": {\"iri\": {\"work\": \"\/akn\/ky\/act\/sl\/2023\/42\", \"expression\": \"\/akn\/ky\/act\/sl\/2023\/42\/eng@2023-01-01\", \"manifestation\": \"\/akn\/ky\/act\/sl\/2023\/42\/eng@2023-01-01.pdf\"}, \"pdf\": {\"md5\": \"462e688082ae373084894e89ab71389a\", \"path\": \"\/Users\/q\/kyleg-data\/working\/SUBORDINATE\/2023\/2023-0042\/2023-0042_SL 42 of 2023.pdf\", \"pages\": 12, \"filename\": \"2023-0042_SL 42 of 2023.pdf\"}, \"errors\": [], \"extraction\": {\"model\": null, \"stats\": {\"word_count\": 3722, \"paragraph_count\": 13, \"text_char_count\": 25898}, \"usage\": null, \"method\": \"pymupdf-text\", \"version\": \"kyleg-akn-1.0\", \"extracted_at\": \"2026-06-22\"}, \"classification\": \"text_layer\", \"validation_flags\": [], \"docai_processor_id\": null}, \"akomaNtoso\": {\"act\": {\"body\": [{\"eId\": \"sec_n1\", \"num\": null, \"text\": \"Cayman Islands Monetary Authority Page 1 of 12 RULE AND STATEMENT OF GUIDANCE Nature, Accessibility, and Retention of Records for Licensees Conducting the Business of Company Management AUGUST 2023 RULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR LICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT Cayman Islands Monetary Authority Page 2 of 12 Table of Contents 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_12\", \"num\": \"12.\", \"text\": \"RULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR LICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT Cayman Islands Monetary Authority Page 3 of 12 List of Acronyms AMLR Anti-Money Laundering Regulations (as amended) BTCA Banks and Trust Companies Act (as amended) CA Companies Act (as amended) CIMA Cayman Islands Monetary Authority CMA Companies Management Act (as amended) IA Insurance Act (as amended) LLCA Limited Liability Companies Act (as amended) LLPA Limited Liability Partnership Act (as amended) MAA Monetary Authority Act (as amended) MFA Mutual Funds Act (as amended) PA Partnership Act (as amended) POCA Proceeds of Crime Act (as amended) PTCR Private Trust Companies Regulations (as amended) Cayman Islands Monetary Authority Page 4 of 12 Rule and Statement of Guidance Nature, Accessibility, and Retention of Records for Licensees Conducting the Business of Company Management\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_1\", \"num\": \"1.\", \"text\": \"Introduction 1.1. This document (\u201cthe Rules and Guidance\u201d) establishes the Cayman Islands Monetary Authority\u2019s (the \u201cAuthority\u201d or \u201cCIMA\u201d) Rule and Statement of Guidance on Nature, Accessibility, and Retention of Records for Licensees Conducting the Business of Company Management. 1.2. Where applicable, any acts referred to in this document include related regulations as may be amended from time to time. 1.3. The Rules and Guidance should be read in conjunction with the relevant Acts and regulatory instruments issued by the Authority from time to time. 1.4. In order to highlight the Authority\u2019s rules within the compendium, a rule is written in light blue and designated with the letter \u201cR\u201d in the right margin.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_2\", \"num\": \"2.\", \"text\": \"Statement of Objectives 2.1. The Rules and Guidance establish minimum requirements and provide guidance to licensees under the Companies Management Act (as amended) (\u201cCMA\u201d), Banks and Trusts Companies Act (as amended) (\u201cBTCA\u201d), Mutual Funds Act (as amended) (\u201cMFA\u201d) and the Insurance Act (as amended) (\u201cIA\u201d), on the maintenance of records in a manner that promotes accessibility, retention, and appropriate security. The rules herein establish the minimum requirements whereas the guidance, not intended to be prescriptive or exhaustive, sets out the Authority\u2019s minimum expectations of a licensee\u2019s record keeping arrangements. 2.2. The Authority recognises that the arrangements for record keeping will vary according to the manner in which the business of the licensee is structured, organised, managed, its size, complexity, nature of business, and the risk profile of its operations. The overriding principle, however, is that the records and systems must be adequate to satisfy the requirements of the Authority and the relevant Acts and regulations. 2.3. All regulatory Acts allow the Authority to access and inspect records maintained by licensees. The Anti-Money Laundering Regulations (as amended) (\u201cAMLRs\u201d) also require the maintenance of certain records.  It is expected that record keeping arrangements drafted to comply with the regulatory Acts may be additional to the record keeping arrangements required under other Acts and regulations. 2.4. These Rules and Guidance are consistent with the Authority\u2019s statutory objectives as prescribed in the Monetary Authority Act (as amended) (\u201cMAA\u201d), in particular, Section 34 of the MAA which provides that the Authority may issue rules, statements of principles, or statements of guidance: \u201c(1) After private sector consultation and consultation with the Minister charged with responsibility for Financial Services, the Authority may\u2013 RULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR LICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT Cayman Islands Monetary Authority Page 5 of 12 (a) issue or amend rules or statements of principle or guidance concerning the conduct of licensees and their officers and employees and any other persons to whom and to the extent that the regulatory laws may apply;\u201d\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_3\", \"num\": \"3.\", \"text\": \"Scope of Application 3.1. These Rules and Guidance apply to all licensees under the CMA, BTCA, MFA, and IA conducting the business of company management pursuant to Section 3(1)(a) \u2013 (l) of the CMA, as follows: a) Acting as a company formation agent; b) Providing a Registered Office or business address for a company; ba) Establishing and maintaining beneficial ownership registers on behalf of companies and limited liability companies incorporated or formed in the Islands, offering an information technology solution to those companies and limited liability companies to make extracts of information on the beneficial ownership register searchable by the competent authority established under Part XVIIA of the Companies Act (as amended) (\u201cCA\u201d) and responding to requests from the competent authority about whether a company or a limited liability company or a subsidiary of the same is exempted from the application of that Part or of Part 12 of the Limited Liability Companies Act (as amended) (\u201cLLCA\u201d); c) Providing an accommodation, correspondence or administrative address for a company or for any other person; d) Filing statutory forms, resolutions, returns and notices; e) Acting as or fulfilling the function of or arranging for another person to act as or fulfil the function of a person authorised to accept service of process on behalf of a foreign company carrying on business in the Islands or to accept any notices required to be served on it; f) acting as or fulfilling the function of or arranging for another person to act as or fulfil the function of an officer of a company; g) acting as a nominee shareholder for a company; h) acting as or fulfilling the function of or arranging for another person to act as or fulfil the function of director or alternate director of a company; i) acting as or arranging for another person to act as secretary, alternate, assistant or deputy secretary of a company; j) acting as or fulfilling the function of or arranging for another person to act as or fulfil the function of an authorised custodian for the purposes of the CA (as amended); k) providing other corporate services involving the control of the whole or a substantial part of the assets of a company; and l) providing any additional corporate services as may be specified in regulations. 3.2. The Authority acknowledges that licensees conducting the business of company management that are part of a group may be subject to group-wide record keeping practices. However, the Authority considers it important for each entity in a group structure that is a separate legal entity to adopt record keeping practices that meet the objectives of these Rules and Guidance and that are appropriate for the particular operations of that legal entity. RULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR LICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT Cayman Islands Monetary Authority Page 6 of 12 3.3. Licensees conducting the business of company management must assess whether record keeping practices at the group-wide level meet the objective of these Rules and Guidance. If not, these licensees must adopt record keeping practices which align with these Rules and Guidance. Additionally, when records are kept by another member of the group, they must be accessible to the Authority. 3.4. These Rules and Guidance do not codify or amend any existing Act. Where these Rules and Guidance are incompatible with an existing Act, the Act takes precedence and prevails.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_4\", \"num\": \"4.\", \"text\": \"Definitions 4.1. The following definitions are provided for the purpose of these Rules and Guidance: a) \u201cBusiness of company management\u201d has the same meaning as that prescribed in the CMA. b) \u201cLicensee\u201d means a holder of a licence granted under the BTCA, CMA, IA or MFA who engages in the provision of previously specified corporate services. c) \u201cPhysical Presence\u201d involves maintaining operations at a physical location within the Islands which houses such resources, including staff and facilities, and such books and records, as the Authority considers appropriate, having regard to the nature and scale of the business. d) \u201cRecord\u201d for the purposes of this document includes, as applicable: i. \u201cElectronic record\u201d as defined in the Electronic Transactions Act (as amended); and\/or ii. \u201cDocument\u201d as defined in the MAA, which includes paper-based records. e) \u201cRegistered Office\u201d means the official address of an incorporated company to which all communications and notices may be addressed, pursuant to section 50 of the CA.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_5\", \"num\": \"5.\", \"text\": \"General 5.1. All records must be legible and easily accessible. 5.2. Personal data must be processed in accordance with the data protection principles as set out in the Data Protection Act (as amended). The main objective of these Rules and Guidance is to protect personal data against theft, accidental loss, unauthorised access, and accidental destruction of data. Licensees conducting the business of company management should therefore have appropriate personal data security measures, records retention policies, personal data breach response plans, and processes for data subjects to be able to exercise their rights. R R R RULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR LICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT Cayman Islands Monetary Authority Page 7 of 12 5.3. Records must be accessible and provided by licensees conducting the business of company management to the Authority within a reasonably short timeframe. The Authority expects that most records must be provided without delay, to the Authority, or within the timeframe determined from time to time by the Authority, whether stored within the Cayman Islands or in another jurisdiction, as applicable. 5.4. Licensees conducting the business of company management must keep, maintain, and administer records as required by relevant Acts such as the CA, LLCA, Limited Liability Partnership Act (as amended) (\u201cLLPA\u201d), Partnership Act (as amended) (\u201cPA\u201d), CMA, BTCA, Proceeds of Crime Act (as amended) (\u201cPOCA\u201d), Private Trust Companies Regulations (as amended) (\u201cPTCR\u201d), and any other relevant legislation. 5.5. Licensees conducting the business of company management must keep records of books of account and other financial affairs, as well as other records related to its company management business. Examples of such records include: a) corporate accounting records; b) organisational records such as insurance coverage records and cybersecurity framework records; c) employee and other administrative records; d) risk management policies; e) corporate records such as incorporation documents, shareholders and directors meeting minutes and board resolutions, and beneficial ownership information; f) client records such as client communication and complaints records; g) service provider records such as copies of contracts and agreements; h) due diligence records on its clients; i) trust deeds; j) annual returns due to the Authority; and k) any other records as required by relevant Acts and\/or regulations. 5.6. Record keeping must be sufficient to enable the Authority to monitor the licensee\u2019s compliance with regulatory and anti-money laundering\/counter terrorism financing\/counter proliferation financing obligations. 5.7. Licensees conducting the business of company management should ensure that their records, including accounting records, are maintained using an appropriate record management system and in a manner that allows the Authority to access records. Records may be kept in a form other than a paperbased document or copy of a document, as long as the integrity of the document remains intact. 5.8. Licensees conducting the business of company management should establish and maintain a records management programme that addresses, inter alia, the categorisation of records; records retention periods for various categories of records; and the disposal of records. The records management programme should include a comprehensive records retention policy in accordance with all relevant regulatory acts, regulations and measures. 5.9. Records must be maintained in a manner that ensures that they are kept upto-date at all times as far as is reasonably practical. There should be no R R R R R RULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR LICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT Cayman Islands Monetary Authority Page 8 of 12 unjustifiably excessive delays in the adequate maintenance of records, including keeping relevant records up-to-date. 5.10. Licensees conducting the business of company management may accept and rely on records supplied by a third party as long as those records are capable of being, and are, reconciled with records held by the licensee. 5.11. Where it is impractical for a licensee conducting the business of company management to maintain its own records and records are retained by a third party, the licensee maintains ultimate responsibility for records retention and ensuring records can be retrieved in a timely manner. The licensee conducting the business of company management remains responsible for compliance with all record-keeping requirements and for accessibility of records by the Authority. 5.12. Licensees conducting the business of company management must ensure that all due diligence information on its clients and transaction records related to its company management business are available without delay upon request by the Authority.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_6\", \"num\": \"6.\", \"text\": \"Records Retention Timeframe 6.1. Licensees conducting the business of company management must maintain records for a minimum period of five years after each related transaction date or any other period as stipulated in the relevant Acts and\/or regulations. 6.2. This minimum retention period requirement is not intended to contravene other legal obligations. Licensees conducting the business of company management may have to keep records for periods longer than five years.  For example, where a fiduciary relationship has been formed with clients it may be necessary to keep records for longer periods of time.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_7\", \"num\": \"7.\", \"text\": \"Elements of Records Management Programme 7.1. Licensees conducting the business of company management must maintain adequate procedures for the availability, maintenance, security, privacy, and preservation of records, working papers, and documents of title belonging to the licensee, clients, or others so that they are reasonably safeguarded against loss, unauthorised access, alteration or destruction. This includes records retained electronically or by any other medium. 7.2. Records should be retained in the English language or be professionally translated (i.e., the translation is completed by an individual and\/or entity duly qualified to do so) into written English without delay at the request of the Authority. Where records are translated, the original language version must be retained. 7.3. Where licensees conducting the business of company management maintain records belonging to another licensee conducting the business of company management who is a client, it should ensure that the client\u2019s records are maintained in accordance with these Rules and Guidance. R R R RULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR LICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT Cayman Islands Monetary Authority Page 9 of 12 7.4. A licensee conducting the business of company management should review its record keeping arrangements at least once per year, including where third parties are involved, and make adjustments if necessary. 7.5. The Authority understands that in the normal course of doing business, there will be instances where there is a merger, transfer, or discontinuance of activities. Nonetheless, the Authority expects that licensees conducting the business of company management have a plan in place for the treatment of records once an entity ceases to carry on business. The Authority must be informed of where and how records may be accessed once a licensee conducting the business of company management ceases to carry on business. Notwithstanding, upon cessation of business, record keeping requirements should be met for the period required by the relevant Acts and\/or regulations.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_8\", \"num\": \"8.\", \"text\": \"Keeping of Accounting Records\/Books of Account 8.1. A licensee conducting the business of company management must record information necessary to give a true and fair view of the state of the licensee\u2019s affairs and to explain any transaction carried out on its behalf and\/or its client\u2019s. This information will be required by the Authority and must be maintained in such a way so as to enable a particular transaction to be identified at any time and appropriately traced, in particular, to enable early identification of balances and of the particular items which make up those balances. 8.2. A licensee conducting the business of company management must keep proper accounting records\/books of account in such a manner that they are sufficient to show and explain the transactions and commitments related to its company management business (whether effected on its own behalf or on behalf of others, including clients) and in particular so that these records: a) disclose with accuracy and completeness the financial position for a minimum of five years of operation or for a time period as required under the AMLRs; b) demonstrate whether or not the licensee conducting the business of company management is or was at that time complying with its financial resources\u2019 requirement, where applicable (e.g. capital requirements); and c) enable the licensee conducting the business of company management to prepare, within a time period specified by the Authority, any financial reporting required by the Authority as at the close of business for any date within the previous five years, and that the statement complies with the requirements of the Authority. 8.3. A licensee conducting the business of company management should ensure that its accounting records\/books of account relating to its company management business shall as a minimum contain: a) a record of all assets and liabilities including any commitments or contingent liabilities; b) a record of all income and expenditure explaining its nature; c) a record of all investments or documents of title in the possession or control of the licensee conducting the business of company management, showing the physical location, the beneficial owner, the R R R R R R RULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR LICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT Cayman Islands Monetary Authority Page 10 of 12 purpose for which they are held and whether they are subject to any charge; d) entries from day to day of all sums of money received and expended whether on its behalf or on behalf of others (including clients), and the matters in respect of which the receipt and expenditure takes place; e) entries from day to day of all purchases and sales of investments distinguishing those which are made by the licensee conducting the business of company management on its own account or those which are made by or on behalf of others (including clients); and f) entries from day to day of the receipt and dispatch of documents of title, which are in the possession or control of the licensee conducting the business of company management.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_9\", \"num\": \"9.\", \"text\": \"Maintenance of Records Outside of the Cayman Islands 9.1. A licensee conducting the business of company management that maintains their accounting and other records in a jurisdiction other than the Cayman Islands, should also ensure that: a) the data is kept secure and operational risk is mitigated; and b) they are familiar with the Confidential Information Disclosure Act (as amended). 9.2. When records are held outside of the Cayman Islands, licensees conducting the business of company management must ensure that the Authority has access to records regarding the entity or its clients at all reasonable times in accordance with the relevant Acts and within the time stipulated in Rule 5.3. 9.3. Where records are maintained outside the Cayman Islands through outsourcing, storage, or other arrangements, the licensee conducting the business of company management remains ultimately responsible for record keeping requirements and accessibility to records by the Authority. 9.4. A licensee conducting the business of company management should not keep relevant records outside the Cayman Islands if access to those records by the Authority is likely to be restricted or delayed by laws and\/or regulations governing the jurisdiction outside of the Cayman Islands. Where such restrictions exist, it is expected that the licensee maintain the same records within the Cayman Islands.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_10\", \"num\": \"10.\", \"text\": \"Electronic Records 10.1. It is expected that a licensee conducting the business of company management applies to electronic records, the same requirements associated with paperbased records. The conversion of paper-based records to electronic records via scanning or otherwise, and the consequent creation, retention, storage, and disposal of such records (for example, using emerging technologies such as cloud-based services) should adhere to the same record-keeping standards as paper-based records. 10.2. The Authority understands that electronic records can be more practical than paper-based records for disaster preparedness and storage reasons. Records retention may be in the form of electronic records unless specified otherwise R RULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR LICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT Cayman Islands Monetary Authority Page 11 of 12 by relevant Acts and\/or regulations. Electronic records must be of good quality, an accurate reflection of the paper-based record (where one exists), complete and unaltered, easily accessible, and reproducible in hard copy. 10.3. The Authority expects that caution is used against the premature destruction of paper-based records which have been converted to electronic records. A licensee conducting the business of company management should be satisfied that, inter alia, there are safeguards in place for the conversion of paper-based records. Legal, regulatory, and organisational requirements and recommendations should be key determining factors in the retention of paperbased records. 10.4. The conversion of any paper-based record to an electronic record must not hinder the availability of such records to the Authority. The use of technology to handle records does not absolve a licensee conducting the business of company management from any record-keeping obligations under relevant Acts and\/or regulations. 10.5. The Authority expects that licensees conducting the business of company management will comply with the Electronic Transactions Act (as amended).\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_11\", \"num\": \"11.\", \"text\": \"Enforcement 11.1. Whenever there has been a breach of the Rules contained herein, the Authority\u2019s policies and procedures as contained in the Enforcement Manual will apply, in addition to any other powers provided in the regulatory Acts and the MAA. 12. Effective Date 12.1. For all new licence applicants, the Rules and Guidance will come into effect immediately on the date the measure is published in the Gazette. 12.2. For existing licensees, the Rules and Guidance will come into effect on 1 April 2024. 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AND RETENTION OF RECORDS FOR\nLICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT\n\nCayman Islands Monetary Authority\n\nPage 2 of 12\nTable of Contents\n\nList of Acronyms .................................................................................................................................................. 3\n1.\nIntroduction .............................................................................................................................................. 4\n2.\nStatement of Objectives .................................................................................................................... 4\n3.\nScope of Application ............................................................................................................................ 5\n4.\nDefinitions .................................................................................................................................................. 6\n5.\nGeneral ......................................................................................................................................................... 6\n6.\nRecords Retention Timeframe........................................................................................................ 8\n7.\nElements of Records Management Programme ................................................................... 8\n8.\nKeeping of Accounting Records\/Books of Account ........................................................... 9\n9.\nMaintenance of Records Outside of the Cayman Islands ............................................. 10\n10.\nElectronic Records............................................................................................................................... 10\n11.\nEnforcement............................................................................................................................................ 11\n12.\nEffective Date ......................................................................................................................................... 11\n\nRULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR\nLICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT\n\nCayman Islands Monetary Authority\n\nPage 3 of 12\nList of Acronyms\n\nAMLR\nAnti-Money Laundering Regulations (as amended)\nBTCA\nBanks and Trust Companies Act (as amended)\nCA\n\nCompanies Act (as amended)\nCIMA\nCayman Islands Monetary Authority\nCMA\n\nCompanies Management Act (as amended)\nIA\n\nInsurance Act (as amended)\nLLCA\nLimited Liability Companies Act (as amended)\nLLPA\nLimited Liability Partnership Act (as amended)\nMAA\nMonetary Authority Act (as amended)\nMFA\n\nMutual Funds Act (as amended)\nPA\n\nPartnership Act (as amended)\nPOCA\nProceeds of Crime Act (as amended)\nPTCR\nPrivate Trust Companies Regulations (as amended)\n\nCayman Islands Monetary Authority\n\nPage 4 of 12\n\nRule and Statement of Guidance\nNature, Accessibility, and Retention of Records for\nLicensees Conducting the Business of Company Management\n\n1.\nIntroduction\n\n1.1.\nThis document (\u201cthe Rules and Guidance\u201d) establishes the Cayman Islands\nMonetary Authority\u2019s (the \u201cAuthority\u201d or \u201cCIMA\u201d) Rule and Statement of\nGuidance on Nature, Accessibility, and Retention of Records for Licensees\nConducting the Business of Company Management.\n\n1.2.\nWhere applicable, any acts referred to in this document include related\nregulations as may be amended from time to time.\n\n1.3.\nThe Rules and Guidance should be read in conjunction with the relevant Acts\nand regulatory instruments issued by the Authority from time to time.\n\n1.4.\nIn order to highlight the Authority\u2019s rules within the compendium, a rule is\nwritten in light blue and designated with the letter \u201cR\u201d in the right margin.\n\n2.\nStatement of Objectives\n\n2.1.\nThe Rules and Guidance establish minimum requirements and provide guidance\nto licensees under the Companies Management Act (as amended) (\u201cCMA\u201d),\nBanks and Trusts Companies Act (as amended) (\u201cBTCA\u201d), Mutual Funds Act (as\namended) (\u201cMFA\u201d) and the Insurance Act (as amended) (\u201cIA\u201d), on the\nmaintenance of records in a manner that promotes accessibility, retention, and\nappropriate security. The rules herein establish the minimum requirements\nwhereas the guidance, not intended to be prescriptive or exhaustive, sets out\nthe Authority\u2019s minimum expectations of a licensee\u2019s record keeping\narrangements.\n\n2.2.\nThe Authority recognises that the arrangements for record keeping will vary\naccording to the manner in which the business of the licensee is structured,\norganised, managed, its size, complexity, nature of business, and the risk\nprofile of its operations. The overriding principle, however, is that the records\nand systems must be adequate to satisfy the requirements of the Authority and\nthe relevant Acts and regulations.\n\n2.3.\nAll regulatory Acts allow the Authority to access and inspect records maintained\nby licensees. The Anti-Money Laundering Regulations (as amended) (\u201cAMLRs\u201d)\nalso require the maintenance of certain records.  It is expected that record\nkeeping arrangements drafted to comply with the regulatory Acts may be\nadditional to the record keeping arrangements required under other Acts and\nregulations.\n\n2.4.\nThese Rules and Guidance are consistent with the Authority\u2019s statutory\nobjectives as prescribed in the Monetary Authority Act (as amended) (\u201cMAA\u201d),\nin particular, Section 34 of the MAA which provides that the Authority may issue\nrules, statements of principles, or statements of guidance:\n\n\u201c(1) After private sector consultation and consultation with the Minister\ncharged with responsibility for Financial Services, the Authority may\u2013\n\nRULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR\nLICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT\n\nCayman Islands Monetary Authority\n\nPage 5 of 12\n(a)\nissue or amend rules or statements of principle or guidance\nconcerning the conduct of licensees and their officers and\nemployees and any other persons to whom and to the extent\nthat the regulatory laws may apply;\u201d\n\n3.\nScope of Application\n\n3.1.\nThese Rules and Guidance apply to all licensees under the CMA, BTCA, MFA,\nand IA conducting the business of company management pursuant to Section\n3(1)(a) \u2013 (l) of the CMA, as follows:\n\na)\nActing as a company formation agent;\nb)\nProviding a Registered Office or business address for a company;\nba)\nEstablishing and maintaining beneficial ownership registers on behalf of\ncompanies and limited liability companies incorporated or formed in the\nIslands, offering an information technology solution to those companies\nand limited liability companies to make extracts of information on the\nbeneficial ownership register searchable by the competent authority\nestablished under Part XVIIA of the Companies Act (as amended) (\u201cCA\u201d)\nand responding to requests from the competent authority about whether\na company or a limited liability company or a subsidiary of the same is\nexempted from the application of that Part or of Part 12 of the Limited\nLiability Companies Act (as amended) (\u201cLLCA\u201d);\nc)\nProviding an accommodation, correspondence or administrative address\nfor a company or for any other person;\nd)\nFiling statutory forms, resolutions, returns and notices;\ne)\nActing as or fulfilling the function of or arranging for another person to\nact as or fulfil the function of a person authorised to accept service of\nprocess on behalf of a foreign company carrying on business in the\nIslands or to accept any notices required to be served on it;\nf)\nacting as or fulfilling the function of or arranging for another person to\nact as or fulfil the function of an officer of a company;\ng)\nacting as a nominee shareholder for a company;\nh)\nacting as or fulfilling the function of or arranging for another person to\nact as or fulfil the function of director or alternate director of a company;\ni)\nacting as or arranging for another person to act as secretary, alternate,\nassistant or deputy secretary of a company;\nj)\nacting as or fulfilling the function of or arranging for another person to\nact as or fulfil the function of an authorised custodian for the purposes\nof the CA (as amended);\nk)\nproviding other corporate services involving the control of the whole or\na substantial part of the assets of a company; and\nl)\nproviding any additional corporate services as may be specified in\nregulations.\n\n3.2.\nThe Authority acknowledges that licensees conducting the business of company\nmanagement that are part of a group may be subject to group-wide record\nkeeping practices. However, the Authority considers it important for each entity\nin a group structure that is a separate legal entity to adopt record keeping\npractices that meet the objectives of these Rules and Guidance and that are\nappropriate for the particular operations of that legal entity.\n\nRULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR\nLICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT\n\nCayman Islands Monetary Authority\n\nPage 6 of 12\n3.3.\nLicensees conducting the business of company management must assess\nwhether record keeping practices at the group-wide level meet the objective of\nthese Rules and Guidance. If not, these licensees must adopt record keeping\npractices which align with these Rules and Guidance. Additionally, when records\nare kept by another member of the group, they must be accessible to the\nAuthority.\n\n3.4.\nThese Rules and Guidance do not codify or amend any existing Act. Where\nthese Rules and Guidance are incompatible with an existing Act, the Act takes\nprecedence and prevails.\n\n4.\nDefinitions\n\n4.1.\nThe following definitions are provided for the purpose of these Rules and\nGuidance:\n\na)\n\u201cBusiness of company management\u201d has the same meaning as that\nprescribed in the CMA.\n\nb)\n\u201cLicensee\u201d means a holder of a licence granted under the BTCA, CMA,\nIA or MFA who engages in the provision of previously specified corporate\nservices.\n\nc)\n\u201cPhysical Presence\u201d involves maintaining operations at a physical\nlocation within the Islands which houses such resources, including staff\nand facilities, and such books and records, as the Authority considers\nappropriate, having regard to the nature and scale of the business.\n\nd)\n\u201cRecord\u201d for the purposes of this document includes, as applicable:\n\ni.\n\u201cElectronic record\u201d as defined in the Electronic Transactions Act\n(as amended); and\/or\nii.\n\u201cDocument\u201d as defined in the MAA, which includes paper-based\nrecords.\n\ne)\n\u201cRegistered Office\u201d means the official address of an incorporated\ncompany to which all communications and notices may be addressed,\npursuant to section 50 of the CA.\n\n5.\nGeneral\n\n5.1.\nAll records must be legible and easily accessible.\n\n5.2.\nPersonal data must be processed in accordance with the data protection\nprinciples as set out in the Data Protection Act (as amended). The main\nobjective of these Rules and Guidance is to protect personal data against theft,\naccidental loss, unauthorised access, and accidental destruction of data.\nLicensees conducting the business of company management should therefore\nhave appropriate personal data security measures, records retention policies,\npersonal data breach response plans, and processes for data subjects to be\nable to exercise their rights.\n\nR\nR\nR\n\nRULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR\nLICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT\n\nCayman Islands Monetary Authority\n\nPage 7 of 12\n5.3.\nRecords must be accessible and provided by licensees conducting the business\nof company management to the Authority within a reasonably short timeframe.\nThe Authority expects that most records must be provided without delay, to\nthe Authority, or within the timeframe determined from time to time by the\nAuthority, whether stored within the Cayman Islands or in another jurisdiction,\nas applicable.\n\n5.4.\nLicensees conducting the business of company management must keep,\nmaintain, and administer records as required by relevant Acts such as the CA,\nLLCA, Limited Liability Partnership Act (as amended) (\u201cLLPA\u201d), Partnership Act\n(as amended) (\u201cPA\u201d), CMA, BTCA, Proceeds of Crime Act (as amended)\n(\u201cPOCA\u201d), Private Trust Companies Regulations (as amended) (\u201cPTCR\u201d), and\nany other relevant legislation.\n\n5.5.\nLicensees conducting the business of company management must keep records\nof books of account and other financial affairs, as well as other records related\nto its company management business. Examples of such records include:\n\na)\ncorporate accounting records;\nb)\norganisational records such as insurance coverage records and\ncybersecurity framework records;\nc)\nemployee and other administrative records;\nd)\nrisk management policies;\ne)\ncorporate records such as incorporation documents, shareholders and\ndirectors meeting minutes and board resolutions, and beneficial\nownership information;\nf)\nclient records such as client communication and complaints records;\ng)\nservice provider records such as copies of contracts and agreements;\nh)\ndue diligence records on its clients;\ni)\ntrust deeds;\nj)\nannual returns due to the Authority; and\nk)\nany other records as required by relevant Acts and\/or regulations.\n\n5.6.\nRecord keeping must be sufficient to enable the Authority to monitor the\nlicensee\u2019s compliance with regulatory and anti-money laundering\/counter\nterrorism financing\/counter proliferation financing obligations.\n\n5.7.\nLicensees conducting the business of company management should ensure that\ntheir records, including accounting records, are maintained using an\nappropriate record management system and in a manner that allows the\nAuthority to access records. Records may be kept in a form other than a paperbased document or copy of a document, as long as the integrity of the\ndocument remains intact.\n\n5.8.\nLicensees conducting the business of company management should establish\nand maintain a records management programme that addresses, inter alia, the\ncategorisation of records; records retention periods for various categories of\nrecords; and the disposal of records. The records management programme\nshould include a comprehensive records retention policy in accordance with all\nrelevant regulatory acts, regulations and measures.\n\n5.9.\nRecords must be maintained in a manner that ensures that they are kept upto-date at all times as far as is reasonably practical. There should be no\nR\nR\nR\nR\nR\n\nRULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR\nLICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT\n\nCayman Islands Monetary Authority\n\nPage 8 of 12\nunjustifiably excessive delays in the adequate maintenance of records,\nincluding keeping relevant records up-to-date.\n\n5.10. Licensees conducting the business of company management may accept and\nrely on records supplied by a third party as long as those records are capable\nof being, and are, reconciled with records held by the licensee.\n\n5.11. Where it is impractical for a licensee conducting the business of company\nmanagement to maintain its own records and records are retained by a third\nparty, the licensee maintains ultimate responsibility for records retention and\nensuring records can be retrieved in a timely manner. The licensee conducting\nthe business of company management remains responsible for compliance with\nall record-keeping requirements and for accessibility of records by the\nAuthority.\n\n5.12. Licensees conducting the business of company management must ensure that\nall due diligence information on its clients and transaction records related to its\ncompany management business are available without delay upon request by\nthe Authority.\n\n6.\nRecords Retention Timeframe\n\n6.1.\nLicensees conducting the business of company management must maintain\nrecords for a minimum period of five years after each related transaction date\nor any other period as stipulated in the relevant Acts and\/or regulations.\n\n6.2.\nThis minimum retention period requirement is not intended to contravene other\nlegal obligations. Licensees conducting the business of company management\nmay have to keep records for periods longer than five years.  For example,\nwhere a fiduciary relationship has been formed with clients it may be necessary\nto keep records for longer periods of time.\n\n7.\nElements of Records Management Programme\n\n7.1.\nLicensees conducting the business of company management must maintain\nadequate procedures for the availability, maintenance, security, privacy, and\npreservation of records, working papers, and documents of title belonging to\nthe licensee, clients, or others so that they are reasonably safeguarded against\nloss, unauthorised access, alteration or destruction. This includes records\nretained electronically or by any other medium.\n\n7.2.\nRecords should be retained in the English language or be professionally\ntranslated (i.e., the translation is completed by an individual and\/or entity duly\nqualified to do so) into written English without delay at the request of the\nAuthority. Where records are translated, the original language version must be\nretained.\n\n7.3.\nWhere licensees conducting the business of company management maintain\nrecords belonging to another licensee conducting the business of company\nmanagement who is a client, it should ensure that the client\u2019s records are\nmaintained in accordance with these Rules and Guidance.\n\nR\nR\nR\n\nRULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR\nLICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT\n\nCayman Islands Monetary Authority\n\nPage 9 of 12\n7.4.\nA licensee conducting the business of company management should review its\nrecord keeping arrangements at least once per year, including where third\nparties are involved, and make adjustments if necessary.\n\n7.5.\nThe Authority understands that in the normal course of doing business, there\nwill be instances where there is a merger, transfer, or discontinuance of\nactivities. Nonetheless, the Authority expects that licensees conducting the\nbusiness of company management have a plan in place for the treatment of\nrecords once an entity ceases to carry on business. The Authority must be\ninformed of where and how records may be accessed once a licensee\nconducting the business of company management ceases to carry on business.\nNotwithstanding, upon cessation of business, record keeping requirements\nshould be met for the period required by the relevant Acts and\/or regulations.\n\n8.\nKeeping of Accounting Records\/Books of Account\n\n8.1.\nA licensee conducting the business of company management must record\ninformation necessary to give a true and fair view of the state of the licensee\u2019s\naffairs and to explain any transaction carried out on its behalf and\/or its client\u2019s.\nThis information will be required by the Authority and must be maintained in\nsuch a way so as to enable a particular transaction to be identified at any time\nand appropriately traced, in particular, to enable early identification of balances\nand of the particular items which make up those balances.\n\n8.2.\nA licensee conducting the business of company management must keep proper\naccounting records\/books of account in such a manner that they are sufficient\nto show and explain the transactions and commitments related to its company\nmanagement business (whether effected on its own behalf or on behalf of\nothers, including clients) and in particular so that these records:\n\na)\ndisclose with accuracy and completeness the financial position for a\nminimum of five years of operation or for a time period as required\nunder the AMLRs;\nb)\ndemonstrate whether or not the licensee conducting the business of\ncompany management is or was at that time complying with its financial\nresources\u2019 requirement, where applicable (e.g. capital requirements);\nand\nc)\nenable the licensee conducting the business of company management\nto prepare, within a time period specified by the Authority, any financial\nreporting required by the Authority as at the close of business for any\ndate within the previous five years, and that the statement complies\nwith the requirements of the Authority.\n\n8.3.\nA licensee conducting the business of company management should ensure\nthat its accounting records\/books of account relating to its company\nmanagement business shall as a minimum contain:\n\na)\na record of all assets and liabilities including any commitments or\ncontingent liabilities;\nb)\na record of all income and expenditure explaining its nature;\nc)\na record of all investments or documents of title in the possession or\ncontrol of the licensee conducting the business of company\nmanagement, showing the physical location, the beneficial owner, the\nR\nR\nR\nR\nR\nR\n\nRULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR\nLICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT\n\nCayman Islands Monetary Authority\n\nPage 10 of 12\npurpose for which they are held and whether they are subject to any\ncharge;\nd)\nentries from day to day of all sums of money received and expended\nwhether on its behalf or on behalf of others (including clients), and the\nmatters in respect of which the receipt and expenditure takes place;\ne)\nentries from day to day of all purchases and sales of investments\ndistinguishing those which are made by the licensee conducting the\nbusiness of company management on its own account or those which\nare made by or on behalf of others (including clients); and\nf)\nentries from day to day of the receipt and dispatch of documents of title,\nwhich are in the possession or control of the licensee conducting the\nbusiness of company management.\n\n9.\nMaintenance of Records Outside of the Cayman Islands\n\n9.1.\nA licensee conducting the business of company management that maintains\ntheir accounting and other records in a jurisdiction other than the Cayman\nIslands, should also ensure that:\n\na)\nthe data is kept secure and operational risk is mitigated; and\nb)\nthey are familiar with the Confidential Information Disclosure Act (as\namended).\n\n9.2.\nWhen records are held outside of the Cayman Islands, licensees conducting the\nbusiness of company management must ensure that the Authority has access\nto records regarding the entity or its clients at all reasonable times in\naccordance with the relevant Acts and within the time stipulated in Rule 5.3.\n\n9.3.\nWhere records are maintained outside the Cayman Islands through\noutsourcing, storage, or other arrangements, the licensee conducting the\nbusiness of company management remains ultimately responsible for record\nkeeping requirements and accessibility to records by the Authority.\n\n9.4.\nA licensee conducting the business of company management should not keep\nrelevant records outside the Cayman Islands if access to those records by the\nAuthority is likely to be restricted or delayed by laws and\/or regulations\ngoverning the jurisdiction outside of the Cayman Islands. Where such\nrestrictions exist, it is expected that the licensee maintain the same records\nwithin the Cayman Islands.\n\n10.\nElectronic Records\n\n10.1. It is expected that a licensee conducting the business of company management\napplies to electronic records, the same requirements associated with paperbased records. The conversion of paper-based records to electronic records via\nscanning or otherwise, and the consequent creation, retention, storage, and\ndisposal of such records (for example, using emerging technologies such as\ncloud-based services) should adhere to the same record-keeping standards as\npaper-based records.\n\n10.2. The Authority understands that electronic records can be more practical than\npaper-based records for disaster preparedness and storage reasons. Records\nretention may be in the form of electronic records unless specified otherwise\n\nR\n\nRULE AND STATEMENT OF GUIDANCE \u2013 NATURE, ACCESSIBILITY, AND RETENTION OF RECORDS FOR\nLICENSEES CONDUCTING THE BUSINESS OF COMPANY MANAGEMENT\n\nCayman Islands Monetary Authority\n\nPage 11 of 12\nby relevant Acts and\/or regulations. Electronic records must be of good quality,\nan accurate reflection of the paper-based record (where one exists), complete\nand unaltered, easily accessible, and reproducible in hard copy.\n\n10.3. The Authority expects that caution is used against the premature destruction\nof paper-based records which have been converted to electronic records. A\nlicensee conducting the business of company management should be satisfied\nthat, inter alia, there are safeguards in place for the conversion of paper-based\nrecords.\nLegal,\nregulatory,\nand\norganisational\nrequirements\nand\nrecommendations should be key determining factors in the retention of paperbased records.\n\n10.4. The conversion of any paper-based record to an electronic record must not\nhinder the availability of such records to the Authority. The use of technology\nto handle records does not absolve a licensee conducting the business of\ncompany management from any record-keeping obligations under relevant\nActs and\/or regulations.\n\n10.5. The Authority expects that licensees conducting the business of company\nmanagement will comply with the Electronic Transactions Act (as amended).\n\n11.\nEnforcement\n\n11.1. Whenever there has been a breach of the Rules contained herein, the\nAuthority\u2019s policies and procedures as contained in the Enforcement Manual will\napply, in addition to any other powers provided in the regulatory Acts and the\nMAA.\n\n12.\nEffective Date\n\n12.1. For all new licence applicants, the Rules and Guidance will come into effect\nimmediately on the date the measure is published in the Gazette.\n\n12.2. For existing licensees, the Rules and Guidance will come into effect on 1 April\n2024.\n\nR\n\nCayman Islands Monetary Authority\n\nPage 12 of 12","akn_extracted_at":"2026-06-22 15:40:07.788966+00","cms_id":"2023-0042","law_type":"subordinate","year":"2023","number":"42","title":"Rules and Statement of Guidance \u2013 Nature, Accessibility, and Retention of Records for Licensees Conducting the Business of Company Management","status":"in_force"},"provenance":{"files":[{"file_id":"5197","expr_id":"302","kind":"akn_xml","filename":"2023-0042_SL 42 of 2023.akn.xml","source_url":null,"storage_path":"\/Users\/q\/kyleg-data\/working\/SUBORDINATE\/2023\/2023-0042\/2023-0042_SL 42 of 2023.akn.xml","content_md5":"034a74bb970356f6b751bec41cd31327","byte_size":"28173","http_last_modified":null,"fetched_at":"2026-06-22 15:40:07.901299+00"},{"file_id":"603","expr_id":"302","kind":"pristine_pdf","filename":"2023-0042_SL 42 of 2023.pdf","source_url":"\/cms\/images\/LEGISLATION\/SUBORDINATE\/2023\/2023-0042\/2023-0042_SL 42 of 2023.pdf","storage_path":"\/Users\/q\/kyleg-data\/pristine\/SUBORDINATE\/2023\/2023-0042\/2023-0042_SL 42 of 2023.pdf","content_md5":"462e688082ae373084894e89ab71389a","byte_size":"504638","http_last_modified":null,"fetched_at":"2026-06-21 23:09:36.335169+00"},{"file_id":"604","expr_id":"302","kind":"working_pdf","filename":"2023-0042_SL 42 of 2023.pdf","source_url":"\/cms\/images\/LEGISLATION\/SUBORDINATE\/2023\/2023-0042\/2023-0042_SL 42 of 2023.pdf","storage_path":"\/Users\/q\/kyleg-data\/working\/SUBORDINATE\/2023\/2023-0042\/2023-0042_SL 42 of 2023.pdf","content_md5":"462e688082ae373084894e89ab71389a","byte_size":"504638","http_last_modified":null,"fetched_at":"2026-06-21 23:09:36.335169+00"}],"paragraph_count":92,"latest_history":null},"quality":{"expr_id":"302","doc_id":"302","quality_state":"known_issue","quality_score":"59","needs_human_review":"t","deterministic_categories":"{duplicate_text,page_header_footer_noise,title_mismatch}","llm_categories":"{truncated_text,other}","repair_actions":"{collapse_duplicate_text,manual_review,reextract_full_text,strip_page_furniture,verify_title_metadata}","finding_severity_counts":"{\"low\": 1, \"medium\": 1}","finding_summary":"Sample ends with an omission marker; likely missing later sections (e.g., enforcement details). 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