كتاب أصول الدين في اليمن: السير والجيوب

The fund's compliance policies, including its AML/CFT policy, its conflicts of interest policy, its valuation policy, and any other policies required by its regulatory framework or offering memorandum, must be reviewed and updated at defined intervals to ensure they remain current with applicable regulatory requirements and with the fund's actual operations. The compliance function must also ensure that relevant staff and directors receive appropriate training on the fund's compliance obligations at defined intervals, and that training records are maintained.

Board Reporting and Escalation

The compliance function must provide regular reports to the fund's board of directors on the fund's compliance position, including the status of the regulatory calendar, the results of the compliance monitoring programme, any regulatory correspondence received and the status of responses, any identified compliance breaches or near-misses, and the status of the AML/CFT programme. These reports must be substantive rather than formulaic and must give the board directors the information they need to satisfy their own oversight obligations.

The Annual Compliance Calendar: What Must Happen Every Year

Annual Compliance Obligations for CIMA-Registered Funds

CIMA annual return: Completion and submission of the fund's annual return to CIMA within six months of the financial year end. The annual return includes financial summary information, investor statistics, and regulatory compliance confirmations.
Audit engagement and completion: Coordination of the annual audit with the fund's CIMA-registered auditor, provision of required records, and review of the draft financial statements before submission to CIMA and distribution to investors.
CIMA registration renewal: Payment of the applicable CIMA annual registration or licensing fee to maintain the fund's good standing. Late payment results in the fund falling out of good standing, which is identified by any investor or counterparty who checks the fund's CIMA registration status.
FATCA/CRS reporting: Compilation and submission of annual FATCA and CRS reports to the Cayman Islands Department for International Tax Cooperation by the applicable deadline, typically the end of July for the prior calendar year.
Compliance programme review: Annual review and update of all compliance policies and procedures to confirm they remain current and consistent with applicable regulatory requirements.
AML/CFT training: Annual completion and documentation of AML/CFT training for relevant staff and directors, consistent with the fund's training obligations under the Anti-Money Laundering Regulations.
Director and officer confirmation: Annual confirmation with CIMA of the fund's current directors and officers, and notification of any changes to the fund's governing body that occurred during the year.
Material change review: Annual review of whether any changes to the fund's operations, investment strategy, service providers, or regulatory status require notification to CIMA as material changes under the applicable legislation.

How Compliance Differs for Digital Asset Funds

Digital asset fund compliance carries additional obligations beyond those applicable to traditional fund structures. The on-chain AML screening dimension, the custody architecture oversight, and the authority architecture monitoring described in the AML and investor onboarding overview all require compliance monitoring that has no equivalent in a traditional fund context. The compliance function for a digital asset fund must understand the specific regulatory treatment of virtual assets under the Cayman VASP Act framework and must track any regulatory developments affecting digital asset fund operations, including changes to CIMA's guidance notes and the evolving framework for tokenised fund structures.

For managers launching on the CV5 Capital digital asset fund platform or hedge fund platform, the compliance function is provided as part of the platform's operational infrastructure. The platform manages the annual regulatory calendar, coordinates the CIMA filings, maintains the compliance monitoring programme, and produces the quarterly compliance reports to the board that the fund's governance framework requires. The related regulatory compliance framework overview for CIMA-registered funds is addressed in the companion article on CIMA corporate governance obligations.

Key Takeaways

The compliance function for a Cayman fund is a regulatory requirement under CIMA's corporate governance guidance. It covers regulatory monitoring and calendar management, a compliance monitoring programme, regulatory correspondence management, policy maintenance, staff training, and board reporting.
The compliance function is distinct from, but overlapping with, the AML/CFT function. The MLRO manages the fund's AML obligations. The compliance function covers the fund's full range of regulatory obligations across the Mutual Funds Act or Private Funds Act, AML Regulations, FATCA/CRS, and CIMA guidance notes.
The annual compliance calendar requires systematic management of CIMA annual return filing, audit completion, registration renewal, FATCA/CRS reporting, policy review, training, and director confirmation obligations. Each of these has a defined deadline and consequences for late or absent completion.
Digital asset fund compliance carries additional obligations including on-chain AML screening oversight, custody architecture monitoring, and tracking of the digital asset-specific regulatory framework. These require compliance function resources with specific understanding of the virtual asset regulatory landscape.
For managers operating through a regulated platform, the platform operator's compliance infrastructure provides the compliance function as a shared service, ensuring that the regulatory calendar is managed, CIMA correspondence is handled, and board compliance reports are produced without the investment manager needing to resource this function independently.

Compliance Infrastructure Built Into the Platform

CV5 Capital's CIMA-regulated platform provides an operational compliance function for every platform fund, managing the Cayman regulatory calendar, CIMA filings, compliance monitoring, AML oversight, FATCA/CRS reporting, and board compliance reporting as standard components of the platform service.

Speak with our team about how the CV5 Capital platform delivers regulatory compliance management as a core service rather than an additional cost.

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This article is produced by CV5 Capital Limited for informational purposes only and does not constitute legal, regulatory, investment, tax, or financial advice. The regulatory analysis in this article reflects CV5 Capital's general understanding of CIMA's compliance function requirements as at the date of publication. Specific obligations vary based on fund structure, regulatory category, and the fund's activities. Managers should seek independent professional advice on their specific compliance obligations. CV5 Capital Limited is registered with the Cayman Islands Monetary Authority (CIMA Registration No. 1885380, LEI: 984500C44B2KFE900490).