Banking and Trust Businesses
Regulatory framework for conducting banking and trust services in the Cayman Islands.
Banks_and_Trust_Companies_Act_(2025_Revision).pdf, Banks_and_Trust_Companies_(License_Applications_and_Fees)Regulations(2021_Revision).pdf, Banks_and_Trust_Companies_(Licence_Applications_and_Fees)_(Amendment)_Regulations, 2025.pdf, Private_Trust_Companies_Regulations(2020_Revision).pdf
2026-04-27
Entities wishing to conduct banking or trust business must be licensed by cima under the Banks and Trust Companies Act.
Licensing Categories:
- "A" Licences: Permit banking business both within and outside the Islands.
- "B" Licences: Primarily for offshore banking, prohibiting the taking of deposits from Cayman residents (with limited exceptions).
- Trust Licences: Permit the carrying on of trust business. Restricted versions exist that limit business to specific named clients.
- Building Societies: While not banks, building-societies are specialized financial institutions that raise funds for member advances and are regulated by CIMA under a separate framework (source: building-societies-act-2020).
Private Trust Companies (PTCs)
A Private Trust Company is a specialized vehicle designed for high-net-worth families to manage their own trust structures (source: private-trust-companies-regulations-2020).
- Registration vs. Licensing: Unlike standard trust companies, PTCs do not require a full licence. They register with cima and are exempt from licensing if they only conduct "connected trust business" for a group of connected persons.
- Connected Persons: Defined broadly to include spouses, descendants, and extended family members.
- Registered Office: PTCs must maintain their registered office at the office of a company that holds a full Trust licence in Cayman.
Regulatory Requirements:
- Capital Adequacy: Banks must maintain a capital adequacy ratio of at least 10%.
- Net Worth: Minimum net worth requirements apply (typically $400,000 for standard "A", "B", or Trust licences, and $20,000 for restricted licences).
- Auditor Obligations: Auditors must report to CIMA if they suspect insolvency, fraud, or non-compliance with aml-compliance or other regulations.
- Approvals: Prior approval from CIMA is required to issue/transfer shares or appoint directors and senior officers.
Dormant Accounts
Banks and trust companies are considered "account providers" under the dormant-accounts-law-2011. They are required to identify accounts with no activity for seven years, notify the holders, and eventually transfer unclaimed funds to the Government. They must also maintain a register of such accounts and submit annual compliance certificates to cima.
Application and Fees
Applicants must submit a detailed business plan, audited financial statements, and personal questionnaires for all directors, officers, and major shareholders (holding >10%) (source: Banks_and_Trust_Companies_(License_Applications_and_Fees)Regulations(2021_Revision).pdf).
Fee Structure
Licence renewal fees are tiered based on the institution's total assets (calculated as a quarterly average):
- Category "B" Licences: Renewal fees range from CI$60,000 to CI$100,000 depending on asset size.
- Category "A" Licences: Under the 2025 amendment, fees for "A" licences will escalate significantly between 2026 and 2029. Institutions with over US$3.0 billion in assets will see their annual fee rise to CI$2,250,000 by 2029 (source: Banks_and_Trust_Companies_(Licence_Applications_and_Fees)_(Amendment)_Regulations,_2025.pdf).