Cayman Islands Defies UK Pressure on Public Beneficial ...

The Cayman Islands has a beneficial ownership register. It has had one since 2017. What it does not have, and will not create, is a public one. Premier Andre Ebanks said so explicitly in March 2026, calling a fully open register "probably unconstitutional" under Caymanian law. The UK disagrees. So does some of the international transparency lobby. But Cayman left the FATF grey list in October 2023 and does not appear interested in re-litigating the issue on anyone else's timeline.

What the register actually looks like

The Beneficial Ownership Transparency Act 2023 (BOT Act) and its implementing regulations took effect on July 31, 2024, replacing earlier piecemeal legislation with a consolidated framework. The register is centralized, maintained by the General Registry, and operates on a "legitimate interest" access model.

Law enforcement agencies get full access. Everyone else, journalists, NGOs, academic researchers, and people with business connections to a registered entity, must demonstrate legitimate interest and pay a fee. As of March 11, 2026, that fee jumped from USD 30 to USD 75 per query, with a new USD 250 annual subscription option for repeat users. The Legitimate Interest Access Amendment Regulations 2026 set the new pricing.

Separately, the January 2026 amendment to the BOT Regulations tightened compliance timelines. Entities that discover discrepancies between their filings and actual beneficial ownership must now report them within 5 days, down from 30. The previous 25% discount on penalties for timely self-correction was removed.

Why Cayman says no to public access

Premier Ebanks anchored his refusal in a specific legal precedent. The EU Court of Justice ruled on November 22, 2022 (Cases C-37/20 and C-601/20, WM and Sovim SA v Luxembourg Business Registers) that unrestricted public access to beneficial ownership data constitutes a "serious interference with fundamental rights to privacy and data protection." That ruling forced the EU to pull back its own public register requirements.

Ebanks used this directly: if the EU's highest court decided that a Google-style open register violates privacy rights, why would Cayman create one? The official opposition (PPM, led by Joey Hew) backed the government's position, which is unusual enough in Caymanian politics to signal genuine consensus.

UK Minister Stephen Doughty has been pushing all British Overseas Territories toward fully public registers. Cayman's response, covered by AML Intelligence in March 2026, was a flat refusal.

The FATF context

Cayman's leverage on this issue comes partly from timing. The islands were removed from the FATF grey list in October 2023 after completing 63 action items. They were also delisted by the EU. The 5th round mutual evaluation begins in 2026, which means Cayman needs its regime to be defensible, not necessarily public.

The contrast with the British Virgin Islands is instructive. BVI was added to the FATF grey list in June 2025, with its action plan specifically targeting beneficial ownership accuracy and enforcement. Jersey, which was never grey-listed, resumed its own consultation on legitimate interest access in November 2025 but has delayed implementation, choosing not to include changes in 2026 annual reporting.

The pattern across Crown Dependencies and Overseas Territories is consistent: centralized registers with restricted access, calibrated to satisfy FATF evaluators without creating the kind of open databases that the EU Court of Justice questioned. Whether this equilibrium holds depends on the 2026 FATF evaluation and whether the UK government decides to test its constitutional authority over the territories. Cayman is betting it will not.