the cyprus securities and exchange commission (cysec) recently issued circular e743, introducing significant updates to liquidity management requirements for alternative investment funds (aifs) and undertakings for collective investment in transferable securities (ucits). this circular addresses the implementation of directive (eu) 2024/927 (the aifmd ii), which amends directive 2011/61/eu (the aifmd) and directive 2009/65/ec (the ucitsd). these changes are not merely administrative, they represent a fundamental shift in how liquidity risk is managed across the european union. these amendments necessitate changes to national laws (law 56(i)/2013 and law 78(i)/2012 in cyprus), requiring fund managers to integrate specific liquidity management tools (lmts) into their constitutional documents. this post outlines the key changes, critical compliance deadlines, and the specific actionable steps fund managers must take to ensure alignment with the new regulatory framework. key lmts central to this directive is the introduction of a harmonised list of nine lmts. this list provides a toolkit for managers to handle redemption pressures effectively. the directive introduces the following tools: suspension of subscriptions, repurchases and redemptions: temporarily halting trading redemption gates: limiting the amount that can be redeemed on a single dealing day extension of notice periods: increasing the time between a redemption request and settlement redemption fee: charging a fee to redeeming investors to cover liquidity costs swing pricing: adjusting the net asset value (nav) to reflect dealing costs dual pricing: using bid and offer prices for subscriptions and redemptions contribution to prevent impairment (anti-dilution levy): applying a levy to subscriptions or redemptions to protect remaining investors redemption in kind: paying redemption proceeds in assets rather than cash side-pockets: segregating illiquid assets from the main portfolio selection requirements under the new rules, aifms managing open-ended aifs and ucits management companies must select at least two appropriate lmts from the list above (specifically from points 2 to 8). crucially, the selection cannot consist solely of swing pricing (5) and dual pricing (6). these tools must be included in the fund's rules or instruments of incorporation for potential use in the best interests of investors. compliance deadlines and requirements cysec has established a clear timeline for compliance. adherence to these dates is critical to avoid regulatory friction. action required deadline responsible entity submit applications/notifications 27 february 2026 aifms, ucits, self-managed funds transposition into national law 16 april 2026 member states full compliance and implementation 16 april 2026 all affected aifs and ucits submission details entities must submit applications or notifications to cysec to amend their fund rules or instruments of incorporation. these submissions must be accompanied by: a confirmation statement: declaring that the suitability of the selected tools has been assessed against the fund’s investment strategy, liquidity profile, and redemption policy. applicable fees: payment of the relevant fees as determined by current directives. exemptions and special cases while the directive applies broadly, specific nuances exist for certain fund types. money market funds (mmfs): if an open-ended aif or ucits qualifies as a money market fund under regulation (eu) 2017/1131, the manager is only required to select one liquidity management tool from the list (points 2 to 8), rather than two. exceptional activation: in extraordinary circumstances where it serves the investors' best interests, managers may activate suspension of redemptions (1) or side-pockets (9) even if these tools were not explicitly included in the fund's constitutional documents. next steps for fund managers ensure your fund is prepared for the upcoming changes. review your liquidity management strategy, update your governing documents. for comprehensive details, refer to circular e743 here (only in greek)

the jersey institute of directors (iod) introduced comprehensive ai adoption guidelines to assist directors and senior leaders in navigating the complexities of integrating artificial intelligence (ai) into their organisations. these guidelines aim to address hesitations around ai adoption and provide a structured framework for responsible and effective implementation. key highlights: strategic importance of ai: ai is no longer optional but a strategic priority for businesses, offering opportunities to enhance productivity, customer experiences, and competitive positioning. five-step framework for ai adoption: identify use cases aligned with business goals and return on investment (roi). address cultural and technical barriers to adoption. plan internal and external resources for implementation. establish governance structures for safe and ethical ai use. define metrics to measure success and impact. ai readiness assessment: a tool to evaluate organisational preparedness across data, talent, technology, culture and governance. ethical and responsible ai: emphasis on fairness, transparency, accountability, and compliance with data protection laws. governance and risk management: boards are encouraged to adopt robust oversight mechanisms, including ai governance policies, risk management frameworks and ethical principles. workforce transformation: ai adoption requires upskilling employees, fostering collaboration, and addressing concerns about job displacement. why ai matters: ai offers transformative potential by enabling data-driven decisions, automating routine tasks, and creating new business opportunities. however, its adoption must be guided by strategic alignment, ethical considerations and measurable outcomes. the iod jersey guidelines provide a roadmap for directors to confidently lead ai initiatives, ensuring alignment with organisational values and long-term goals. by fostering a culture of innovation and responsible use, businesses can harness ai as a tool for sustainable growth and competitive advantage. for more details, the press release can be found here and the guidelines here

on 17 march 2026, the european commission initiated a public consultation to revise the technical screening criteria (tsc) under the eu taxonomy regulation (regulation (eu) 2020/852). this framework aims to facilitate sustainable investment by defining criteria for economic activities that contribute to the eu's six environmental objectives: climate change mitigation, climate change adaptation, sustainable use of water and marine resources, circular economy, pollution prevention and control, and biodiversity protection. as part of this process, the european commission has published draft amendments to two key delegated acts: taxonomy climate delegated act((eu) 2021/2139) – enhancing usability of tsc for climate-related objectives. taxonomy environmental delegated act((eu) 2023/2486) – improving tsc usability for broader environmental goals. the proposed revisions aim to simplify and improve the framework's usability, reflecting stakeholder feedback and technological advancements. key sectors addressed include forestry, environmental protection, manufacturing, energy, transport, and construction. the amendments also refine the "do no significant harm" (dnsh) criteria. the consultation is open until 14 april 2026, with the commission planning to adopt the revised legislation in q2 2026. about the eu taxonomy regulation the eu taxonomy regulation, a cornerstone of the eu’s sustainable finance framework, establishes a unified classification system for environmentally sustainable economic activities. it aims to direct investments toward projects aligned with the european green deal and the eu’s 2030 climate and energy targets. by providing clear criteria, the taxonomy fosters market transparency, mitigates greenwashing, and supports companies and investors in identifying sustainable opportunities. the regulation defines six overarching environmental objectives and relies on technical screening criteria, developed through delegated acts, to assess activities' alignment with these goals. for more information, the news release can be found here

the european commission launched a targeted consultation on private equity exits, open from 2 march 2026 to 27 april 2026. this initiative aims to address challenges faced by private equity investors in the eu when exiting investments, such as limited liquidity and valuation issues, which hinder market activity and growth capital availability. the consultation explores potential solutions, including the creation of a multilateral platform for secondary trading of private company shares, which could enhance liquidity, reduce costs, and support private companies' transition to public markets. the initiative forms part of the european commission's broader efforts to deepen eu capital markets and improve access to financing for growth companies. key areas of focus include: identifying barriers to private equity exits and proposing regulatory or non-regulatory solutions. evaluating the design and regulatory framework for a secondary trading platform, ensuring efficient price discovery, investor protection, and market integrity. assessing the platform's potential to raise fresh equity capital for private companies. the consultation also highlights the need to balance transparency, disclosure and investor protection with the protection of commercially sensitive information held by private companies. stakeholders, including private equity funds, companies and public authorities, are invited to submit feedback through the commission's online questionnaire. for more information the official publication can be found here

on 9 february 2026, the eu’s anti-money laundering authority (amla) launched public consultations on three draft regulatory technical standards (rts) to harmonise anti-money laundering (aml) and counter-terrorist financing (cft) measures across the eu. these consultations invite input from stakeholders in both financial and non-financial sectors to ensure comprehensive and practical standards. key draft rts and objectives: business relationships (article 19(9) of regulation (eu) 2024/1624)defines criteria for identifying business relationships, occasional transactions, and linked transactions, forming the basis for customer due diligence obligations. customer due diligence (article 28(1) of regulation (eu) 2024/1624)outlines procedures for verifying customer identity and conducting ongoing monitoring in a risk-sensitive and proportionate manner. enforcement (article 53(10) of directive (eu) 2024/1640)establishes a unified supervisory approach for assessing and addressing breaches of aml/cft obligations. consultation details: deadlines for feedback: business relationships and customer due diligence: 8 may 2026 enforcement: 9 march 2026 public hearing: an online session for the draft rts on business relationships and customer due diligence was scheduled for 24 march 2026. cysec circular c755: the cyprus securities and exchange commission (cysec) issued circular c755 to inform regulated entities, including financial institutions, crypto asset service providers and crowdfunding platforms, about these consultations. cysec urges stakeholders to actively participate and provide feedback on the draft rts. importance of non-financial sector participation: amla highlights the significant role of the non-financial sector in combating financial crime and encourages their engagement in shaping these standards. resources, including an explainer on sector-specific obligations, are available on amla’s website. call to action: stakeholders are encouraged to review the draft rts and submit their input via amla’s public consultation platform. these efforts aim to establish a robust, risk-based, and proportionate aml/cft framework applicable across the eu. amla’s press release can be found here and cysec’s circular c755 here

on 24 february 2026, the bermuda ministry of justice issued aml-atf ministerial advisory 1/2026, emphasising the need for enhanced due diligence (edd) and enhanced ongoing monitoring on a risk-sensitive basis in business relationships involving jurisdictions identified as high-risk for money laundering and terrorist financing. this advisory aligns with the proceeds of crime (anti-money laundering and anti-terrorist financing) regulations 2008, which mandate risk-sensitive edd measures for transactions linked to such jurisdictions. key points include: high-risk jurisdictions: the financial action task force (fatf) has identified countries with strategic deficiencies in their aml/cft frameworks. these include the democratic people's republic of korea (dprk), iran, and myanmar, among others. specific countermeasures and edd are advised for these jurisdictions. fatf statements: on 13 february 2026, fatf released statements categorising jurisdictions into: high-risk jurisdictions (black list): countries requiring countermeasures, such as dprk and iran. jurisdictions under increased monitoring (grey list): countries working to address deficiencies, including algeria, kenya, and vietnam. regulatory compliance: entities and persons subject to bermuda’s aml/cft regulations, including financial institutions, independent professionals, and real estate agents, must implement robust systems to mitigate risks associated with these jurisdictions. sanctions and monitoring: some jurisdictions, like dprk and iran, are subject to international sanctions, necessitating additional compliance measures under the international sanctions regulations 2013. the advisory highlights the importance of consulting fatf publications and annexed statements for comprehensive risk assessments. it replaces previous advisories and reinforces bermuda’s commitment to combating financial crime in alignment with international standards. bermuda’s aml-atf advisory 1/2026 can be accessed here

effective 16 april 2026, luxembourg introduces enhanced liquidity management obligations for ucits and open-ended aifs under the law of 3 march 2026, aligning with eu directive 2024/927. key points include: liquidity management tools (lmts) funds must select at least two lmts (eg swing pricing, redemption gates) from specified legal annexes, ensuring alignment with their investment strategy and liquidity profile. these tools must be disclosed in fund documentation and communicated to the cssf. operational procedures detailed policies for activating/deactivating lmts are mandatory. notifications of lmt activations or deactivations must be submitted via the cssf’s new edesk platform. edesk modules lmt selection module(launching 23 march 2026): funds must report their chosen lmts and related policies by 16 april 2026. lmt activation module(launching 16 april 2026): funds must notify the cssf of any exceptional lmt activations. scope and compliance these rules apply to ucits, aifs, and other luxembourg-domiciled funds, with specific provisions for money market funds and side pockets. the cssf will notify relevant eu authorities of lmt activations. this regulatory update aims to enhance investor protection and financial stability by ensuring robust liquidity management practices. cssf’s communique can be found here.

effective from 18 march 2026, the government of jersey introduced significant amendments to the sanctions and asset-freezing (jersey) law 2019. these changes aim to align jersey’s sanctions framework more closely with international standards, particularly those of the uk and to strengthen jersey’s commitment to combating financial crime and ensuring compliance with global sanctions regimes. key changes include: expanded prohibitions: restrictions on providing economic resources, funds, or financial services to designated persons now explicitly extend to entities owned or controlled by such persons. broader reporting obligations: relevant financial institutions (rfis) must report to the minister for external relations if they know or suspect someone is a designated person or involved in an offence under the law. this obligation applies regardless of whether the institution has a direct connection (e.g., account or dealings) with the individual. enhanced disclosure powers: the minister may disclose information obtained under the law to competent authorities outside the uk and eu or to other parties if deemed appropriate. clarifications on indirect availability: new provisions define "indirectly making resources available" to include entities controlled by designated persons. rfis and other stakeholders are advised to review their compliance processes and submit reports promptly if required. for further details read the government of jersey’s update here the sanctions and asset-freezing law (jersey) amendment regulations 2026 can be found here

on 27 february 2026, published in the official journal of the european union, regulatory technical standards (rts) introducing harmonised rules for liquidity management tools (lmts) applicable to alternative investment fund managers (aifms) and undertakings for collective investment in transferable securities (ucits) across the eu. these rts aim to enhance financial stability and bolster investor protection, particularly during periods of market stress. these standards provide detailed specifications for the characteristics of various lmts, ensuring their consistent application and operation. moreover, they establish a clear and predictable legal structure for managing fund liquidity, empowering managers with a robust toolkit to handle redemption pressures while safeguarding the interests of all fund investors. the core objective of rts on lmts governing aifms and ucits is to provide them with a standardised set of instruments to manage liquidity risk effectively, thereby protecting investors and containing potential spillover effects in the market. these rts will apply from 16 april 2026. alternative investment funds (aifs) constituted before this date are granted a transitional period until 16 april 2027 to comply. key features of these rts on lmts include: suspension of subscriptions, repurchases and redemptions: an aifm or ucits must suspend subscriptions, repurchases, and redemptions simultaneously and for the same duration. this measure is intended to be temporary and is applied only in exceptional circumstances where it is in the best interests of investors. redemption gates: aifms or ucits are permitted to activate redemption gates once a predetermined activation threshold is met. extension of notice periods: the rts allows aifms or ucits to extend the notice period required for redemptions. redemption fees: redemption fees must consider the estimated explicit transaction costs and where appropriate the implicit ones and any important market impact of asset sales. swing pricing: the rts provide that swing pricing could be applied in case of a difference between redemption and subscription orders or in a case where the difference would exceed a predefined activation threshold. dual pricing: provides calculation methods in cases where the aifm or ucits activates dual pricing. anti-dilution levies: must include estimated explicit transaction costs and where relevant the implicit transaction costs and any significant market impact of asset sales or purchases. redemption in kind: corresponds to the transfer of assets that the aif or ucits holds for the purpose of redeeming investors instead of cash. side pockets: these new rts provide the forms that side pockets can take, input with respect to their share class and the activation of a side pocket. the new rts on lmts governing aifms can be found here the new rts on lmts governing ucits can be found here

on 24 february 2026, the european securities and markets authority (esma) issued a statement reminding firms of their obligations under the national product intervention measures for contracts for differences (cfds). this follows an increase in the offering of derivatives, such as perpetual futures or contracts, which provide leveraged exposure to assets, including cryptocurrencies like bitcoin. key points include: scope of measures: derivatives meeting the definition of cfds are subject to product intervention measures, including: leverage limits mandatory risk warnings margin close-out and negative balance protection prohibition of monetary and non-monetary benefits product governance: firms must ensure a narrow target market for these complex products, avoiding mass marketing or campaigns targeting inexperienced investors. appropriateness assessment: for non-advised services, firms must assess whether these products are suitable for retail clients. conflict of interest: firms must identify and manage conflicts of interest, particularly when derivatives are issued or traded within the same group. legal analysis: firms must conduct a thorough legal review of products, regardless of their commercial name, to determine if they fall under the scope of these measures. priips regulation: firms distributing these derivatives to retail clients must prepare a key information document (kid) as required under the priips regulation. esma emphasises the importance of acting in the best interests of clients and adhering to investor protection requirements under mifid ii. firms should align their practices with these obligations to ensure compliance and safeguard retail investors. esma’s news release can be found here and the public statement here

on 19 february 2026, the bermuda monetary authority (bma) announced a new initiative aimed at reducing regulatory burdens while enhancing policyholder outcomes. this effort focusses on streamlining insurance supervision by eliminating unnecessary costs, duplication and inefficiencies in reporting and compliance processes while maintaining robust prudential standards, strong governance expectations and effective risk-based supervision. key measures include: streamlined reporting: consolidating duplicative filings, aligning definitions and adopting a "collect once, reuse many times" approach to improve data reliability and reduce reconciliation efforts. implementing pre-submission validation to reduce avoidable rework. enhanced digital processes: leveraging the secure electronic portal for submissions, tracking and communication to improve efficiency and transparency. proportional supervision: tailoring regulatory expectations to insurers' specific risk profiles, ensuring resources are focused on material risks. the initiative does not compromise prudential standards or supervisory effectiveness. the bma encourages insurers and stakeholders to actively engage, provide feedback and collaborate on simplifying processes while ensuring strong policyholder protections. for more information bma’s notice can be found here

the european union (eu) and the united kingdom (uk) proceeded with the announced reduction in the price cap for russian-origin crude oil to us$44.10 per barrel, effective 1 february 2026. this measure, part of ongoing sanctions under regulation (eu) 833/2014, aims to curtail russia's revenue streams while ensuring global energy market stability. key updates: revised price cap: the new cap of us$44.10 per barrel is in effect from 1 february 2026. contracts concluded before 31 january 2026, with russian oil offloaded at the port of destination by 16 april 2026, will remain subject to the previous cap of us$47.60 per barrel. uk general licence amendment: the uk’s general licence int/2024/4423849, known as the ‘oil price cap’ licence, has been updated to reflect the new cap. the office of financial sanctions implementation (ofsi) has amended faqs 154-161 and its industry guidance to align with these changes. compliance requirements: operators must ensure oil is purchased at or below the cap. mandatory attestations and itemised cost documentation for transactions involving russian oil will apply from february 2024. eu operators are required to retain records for five years to demonstrate compliance. scope of application: the cap applies to russian seaborne crude oil and petroleum products. exemptions exist for specific projects critical to energy security, such as the sakhalin-2 project, valid until 28 june 2026. enforcement: national authorities will oversee compliance and address violations. red flags for circumvention include refusal to provide cost details or falsified attestations. this coordinated effort by the eu and uk underscores their commitment to enforcing sanctions while mitigating disruptions to global energy markets. european union’s publications can be found here, here and here. ofsi's faqs can be accessed here. the updated oil price cap general licence is here and the ofsi’s full oil price cap guidance, click here.

on 3 march 2026, luxembourg adopted a new law amending the legislation of 17 december 2010 on collective investment undertakings and 12 july 2013 on alternative investment fund managers. this update transposes the eu directive 2024/927 (aifmd ii), modernising the regulatory framework for investment funds. the law harmonises loan origination rules for funds, imposing risk retention requirements, introducing diversification limits, and restricting certain originate-to-distribute models. it also harmonises and formalises the availability and governance of liquidity management tools (lmt), such as side pockets, in line with aifmd ii. these measures aim to enhance investor protection while reinforcing luxembourg's appeal as a leading centre for alternative asset and private debt management. the law will come into effect on 16 april 2026, with certain provisions postponed until 16 april 2027. for more information (only in french) here

the uk parliament has a vested interest in ensuring compliance of sanctions in the overseas territories (ots) since the uk is responsible, under the un framework, for the application of sanctions in all places that the uk claims sovereignty. added to that, the uk sanctions and money laundering act 2018 (samla) formalised the post-brexit settlement on sanctions implementation in the ots (with the crown dependencies being subject to other equivalent arrangements). parliament has, on an ongoing basis, issued its views on compliance with these requirements in briefing papers issued by the house of commons, the most recent dated 31 october 2025. this details the application of uk sanctions against russia within the uk's 14 overseas territories (ots). it also evaluates the progress toward implementing public registers of beneficial ownership, but that is for another blog. this review offers essential insights into the legal framework and practical challenges of enforcing international sanctions and promoting financial transparency across the ots. in this blog we focus on the ots which we advise on: anguilla, bermuda, the british virgin islands and the cayman islands. sanctions framework in the ots the paper confirms what every ot sanctions lawyer already knows, that the primary legal instrument governing uk sanctions is samla. that uk government policy mandates that any sanctions regime, including the russia (sanctions) (eu exit) regulations 2019, must be given effect in the ots – which is formally extended through orders in council, such as the russia (sanctions) (overseas territories) order 2020. consequently, ots are legally required to apply the same sanctions as the uk. key observations on sanctions and legislative developments the document highlights several key findings and legislative actions: the full extent of russian assets located within the ots remains largely unknown. however, significant actions have been taken. as of 2024, the uk and ot governments reported that a total of £7 billion in accounts and assets had been frozen since 2022. in february 2022, transparency international uk identified approximately £830 million worth of property in the ots and crown dependencies linked to individuals close to the russian president or those accused of corruption. a november 2024 analysis suggested significant exports from ots to russia, valued at us$134 million in that year. for more information, the house of commons research briefing can be accessed here

on 23 february 2026, esma clarified the application of mifid ii remuneration rules to tied agents under article 27 of regulation (eu) 2017/565. key points include: balance between fixed and variable remuneration: tied agents are classified as "relevant persons" under article 2(1) of delegated regulation 2017/565. consequently, firms must ensure a balance between fixed and variable remuneration. however, recital 41 allows flexibility, permitting a larger variable component for tied agents, provided it aligns with national laws and does not compromise client interests. national exemptions under article 3 of mifid ii: member states adopting the optional exemption under article 3 must impose analogous requirements, including remuneration rules, to ensure compliance with article 27 of regulation (eu) 2017/565. this guidance emphasises the need for firms to consider tied agents' unique status and national specificities while maintaining policies that prioritize client interests. esma’s response can be found here

on 22 december 2025, the european banking authority (eba) issued updated guidelines amending the existing framework (eba/gl/2022/04) on the equivalence of confidentiality regimes. these amendments aim to ensure that third-country confidentiality and professional secrecy frameworks align with eu standards, which is a prerequisite for sharing confidential information with third-country authorities. key highlights: scope expansion: the eba has expanded the scope of its equivalence guidelines to create a more consistent framework for how eu national regulators cooperate with supervisory authorities in non-eu countries, the guidelines now incorporate confidentiality and professional secrecy provisions under regulation (eu) 2023/1114 (micar), which governs markets in crypto-assets. this includes updated definitions and scope for competent authorities engaging with third-country authorities. equivalence assessments: the eba has evaluated and confirmed the equivalence of confidentiality regimes for several third-country authorities, including: australia: australian transaction reports and analysis centre (austrac) china: national financial regulatory administration (nfra) montenegro: central bank of montenegro peru: superintendency of bank, insurance, and pension fund administrators (sbs) serbia: national bank of serbia united kingdom: financial conduct authority (fca) and prudential regulation authority (pra) legal framework updates: the guidelines reflect changes in third-country legal frameworks and align with micar requirements. they also clarify that these assessments do not address the need for cooperation arrangements or participation in supervisory colleges. the guidelines will be translated into all official eu languages and published on the eba website. competent authorities must report compliance within two months of publication, with the guidelines becoming effective shortly thereafter. the press release can be found here and the final report here

on 21 january 2026, the cyprus securities and exchange commission (cysec) issued a press release highlighting its strengthened financial market oversight in 2025 and its strategic priorities for 2026, focussing on investor protection, transparency, and financial sector resilience, as cyprus assumes the eu presidency. key achievements include: eu presidency role: active participation in european legislative initiatives, including the market infrastructure package and sustainable finance disclosure regulation (sfdr), ahead of cyprus’ eu presidency in 2026. cysec will also host the esma management board and board of supervisors meetings in april 2026. supervisory actions: conducted 600 inspections, imposed eur 2.3 million in fines, and addressed compliance issues in over 170 cases. efforts targeted professional conduct, sustainability risks, and anti-money laundering (aml) measures. even more, cysec actively participates in the preparation of the new european aml authority (amla) and in implementing the new national sanctions framework through the national sanctions implementation unit (nsiu). development and digital transformation:47 new licenses were granted in 2025. assets under management in collective investment schemes rose to eur 11.4 billion, with a substantial share directed to the cypriot economy. investments in it systems, ai, and cybersecurity, alongside plans to enhance human resources are being prepared in 2026. investor protection: issued warnings against unauthorised entities and promoted financial literacy through educational campaigns to encourage safe participation in the digital financial landscape. the press release can be found here

on 9 february 2026, the cayman islands government published three legislative instruments: the mutual funds (amendment) bill, private funds (amendment) bill, and virtual asset (service providers) (amendment) bill. these were created to answer a number of pressing questions arising from tokenised investment funds and to establish a clear and reliable regulatory framework for tokenised investment funds. ‘tokenisation’ means using blockchain or similar technology to digitally represent an investor's equity or interest in a fund, usually while maintaining a traditional position with respect to legal ownership and rights. the new framework created by the three proposed instruments aims to provide clear and unambiguous guidance and address previous uncertainties as to whether funds that are tokenised are still regulated under existing fund laws, such as the mutual funds act and private funds act, or whether they should be treated as regulated under the virtual asset (service providers) (vasp) act due to the tokenisation of interests in the funds. key updates include: definitions for digital equity and investment tokens. enhanced recordkeeping and transferability provisions. disclosure of technology-specific risks. expanded supervisory powers for the cayman islands monetary authority (cima). the virtual asset (service providers) (vasp) act has also been clarified to exclude regulated tokenised funds from being classified as virtual asset issuers, unless they provide virtual asset services like exchange or custody. these amendments reinforce the cayman islands' position as a leader in financial services innovation, ensuring technological advancements occur within a transparent and internationally credible regulatory environment. the official press release can be found here mutual funds (amendment) bill, 2026 can be accessed here the private funds (amendment) bill, 2026 can be accessed here the virtual asset (service providers) (amendment) bill, 2026 can be accessed here

on 15 december 2025, cyprus and vietnam signed a double tax treaty aimed at avoiding double taxation and preventing fiscal evasion concerning taxes on income (cyprus-vietnam dtt). the cyprus-vietnam dtt, aligns with international tax standards, including the organisation for economic co-operation and development (oecd) and united nations model conventions (un model). we provide below key articles included in the cyprus-vietnam dtt: key provisions permanent establishment (pe) key provisions on pe include: construction projects lasting at least 6 months. furnishing of services for at least 6 months within a 12-month period. exploration/exploitation of natural resources (no time threshold). dividends, interest, royalties key provisions on dividends, interest and royalties include: dividends - maximum 5 per cent tax if the beneficial owner (bo) is a company holding at least 70 per cent of the paying company’s capital or has invested at least usd 10 million. otherwise, capped at 10 per cent tax. interest - maximum 10 per cent tax on the gross amount of interest. royalties - maximum 10 per cent tax on gross amount of royalties. capital gains tax (cgt) key provisions on cgt include: the country of origin retains the right to tax gains from shares in property-rich companies. gains from shares representing over 15 per cent of a company’s capital may also be taxed by the country of origin. methods of eliminating double taxation the cyprus-vietnam dtt sets out specific provisions regarding the methods applied by each contracting state to eliminate double taxation. benefits for businesses and investors the cyprus-vietnam dtt provides clarity and stability in the tax treatment of transactions between the two countries, ensuring fair treatment while preventing tax evasion and double taxation. by safeguarding transparent tax practices, the cyprus-vietnam dtt enhances investor confidence and supports the development of stronger trade and economic ties between cyprus and vietnam. the official press release regarding the cyprus – vietnam dtt can be found here the cyprus-vietnam dtt (available in greek, vietnamese and english) can be found here

effective date: 1 january 2026 this guide outlines the critical amendments to the cayman islands’ common reporting standard (crs) regulations, introduced by the tax information authority (international tax compliance) (common reporting standard) (amendment) regulations, 2025, here. these changes represent a significant shift in the compliance landscape, aligning the jurisdiction with global oecd standards and the new crypto-asset reporting framework (carf). as these amendments are directly relevant to our practice, it is essential that we understand the new timelines, expanded scope, and procedural requirements to advise our clients effectively. new deadlines for registration and reporting one of the most immediate impacts for our clients is the consolidation and advancement of compliance deadlines. the previous split deadlines for returns and compliance forms have been harmonised to streamline the process. registration for new fis new deadline: entities that become financial institutions (fis) on or after 1 january 2026 must register on the ditc portal by 31 january of the following year (i.e. 31 january 2027 onwards). annual reporting deadlines consolidated date: from the 2026 reporting year onwards, both the crs return and the crs compliance form are due by 30 june annually. impact: this replaces the previous separate deadlines (31 july for returns and 15 september for compliance forms). first filing: for the 2026 reporting period, both documents must be submitted by 30 june 2027. principal point of contact (ppoc) requirements a major procedural change is the stricter requirement regarding the ppoc. the ditc now mandates that the ppoc must have a physical presence within the jurisdiction. requirement: every cayman fi must appoint a ppoc person (natural or legal) located in the cayman islands. address: the ppoc must have a physical address in the cayman islands; a mailing address alone is insufficient. deadlines for compliance: new fis (from 1 jan 2026): must appoint a cayman-based ppoc immediately upon registration. existing fis (registered before 31 december 2025): have a transitional period until 31 january 2027 to appoint a local ppoc and update their details on the ditc portal. note: this deadline was extended from the original 1 january 2027 date. notification: any changes to the ppoc must be notified to the ditc within 30 days. expanded scope: crypto-assets and digital money to modernise the framework, the definition of "financial assets" has been significantly broadened. this change ensures that the cayman islands' regime captures digital assets, mirroring the oecd’s crypto-asset reporting framework (carf). new inclusions the regulations now formally include: crypto-assets: this covers payment tokens (e.g., bitcoin, stablecoins), utility tokens, certain nfts, and security tokens. specified electronic money products. central bank digital currencies. client impact entities dealing in these assets must re-evaluate their classification to consider whether they now fall under the definition of an fi or have new reporting obligations regarding account holders holding these assets. due diligence procedures for both new and existing fis must be updated to capture and report on these asset types effectively. enhanced data collection and enforcement the amendments introduce more granular data requirements and a stricter penalty regime. data requirements controlling persons: fis must collect and report additional information regarding controlling persons, i.e. any natural person who exercises control over an entity. account classifications: there is a requirement for more detailed account classification data. self-certifications: valid self-certifications are critical. they must be collected from users to determine tax residency by 1 january 2027 for pre-existing accounts, and prior to (or upon) establishing a relationship for new accounts. enforcement and penalties immediate penalties: the ditc has the authority to impose administrative penalties immediately for non-compliance, removing the previous "breach notice" buffer. penalty amounts: failure to file returns or update ppoc details can result in penalties of up to us$12,200 (ci$10,000) per breach. scope: penalties apply to missed filing deadlines, failure to maintain current registration details, and failure to establish valid self-certifications. transitional provisions summary to assist in managing client expectations, here is the timeline for the transition: milestone date effective date 1 january 2026 first consolidated filing (2026 data) 30 june 2027 ppoc appointment (existing fis) deadline extended to 31 january 2027 ppoc appointment (new fis) from date of registration (starting 1 jan 2026) new fi registration deadline 31 january of the following year (e.g., 31 jan 2027 for 2026 fis) cima prudential information survey for registered persons in addition to the crs amendments, registered persons should be aware of new regulatory obligations introduced by the cayman islands monetary authority (cima). the prudential information survey (adr-046-75-02) is now required for entities registered as registered persons and is a critical part of cima’s ongoing supervisory and risk assessment objectives. purpose and scope the survey aims to enhance cima’s oversight of the securities investment business sector, focussing on activities, exposures, and risk profiles across registered persons. it is separate from, and in addition to, existing requirements such as the annual declaration. key deadlines the first prudential information survey covers the reporting period from 1 january 2025 to 31 december 2025. submission is required via the reefs portal between 1 january 2026 and 31 march 2026. submission requirements registered persons must accurately complete and submit the survey within the specified window. the guidance for registered person prudential information survey is available and should be consulted for technical and procedural details. timely submission is mandatory. this obligation is in addition to the annual declaration (adr-046-75), which remains due from 1 january 2026 to 15 january 2026. failure to meet either obligation may result in regulatory follow-up and penalties. any queries are to be directed to the securities supervision division at cima. action points for the team review client portfolios: identify clients dealing in digital assets who may now fall under the expanded scope. audit ppoc appointments: ensure all existing fi clients have a plan to appoint a cayman-based ppoc before the january 2027 deadline. update compliance calendars: adjust internal tracking systems to reflect the new 30 june consolidated deadline for 2027.