Mutual Fund (open-ended)
Regulated by Mutual Funds Act (2025 Revision). Continuous subscriptions and redemptions. Categories: Registered, Administered, Master, Limited Investor. Hedge funds, FoF, liquid strategies.
Hedge fundsMore than 60% of the world's hedge funds and 58% of all crypto funds are registered here. Mutual Funds Act, Private Funds Act and ELP Act provide a complete toolkit: from classic equity funds to tokenized strategies.
All Cayman funds fall into two main categories: open-ended (Mutual Funds) and closed-ended (Private Funds). The first — for liquid strategies with regular subscriptions, the second — for PE/VC/real estate.
Regulated by Mutual Funds Act (2025 Revision). Continuous subscriptions and redemptions. Categories: Registered, Administered, Master, Limited Investor. Hedge funds, FoF, liquid strategies.
Hedge fundsRegulated by Private Funds Act (2025 Revision). Closed-ended, no redemption on demand. Private equity, venture capital, real estate, infrastructure, secondaries.
PE / VC / REPrimary fund structure. General Partner manages, Limited Partners invest without liability. Tax-transparent, flexible distributions, strong case law precedent.
Hedge / PE standardMaster fund (Cayman) + Feeder funds (Cayman + Delaware/Luxembourg). US tax-exempt and non-US investors segregated — unified investment strategy in master fund.
Multi-jurisdictionSegregated Portfolio Company where each portfolio is a separate strategy with isolated assets and liabilities. One MLRO, one auditor, up to 30+ cells in one wrapper.
Multi-strategyPer 2026 legislative update — funds can issue tokens representing fund interests. Tokenized funds under MFA / PFA exempt from VASP registration (if custody incidental).
Web3-nativeMutual Funds Act (2025) divides open-ended funds into four registration categories. Fund size and investor type determine compliance requirements, minimum subscription and cost.
Minimum subscription $100,000 per investor. Most common option for hedge funds.
Has licensed administrator. Subscription can be below $100k. Standard for retail funds.
Master in master/feeder structure. Registered separately, has its own license but simplified requirements.
Up to 15 investors, majority can appoint or change operator. Family / club deals.
Realistic fund launch timeline — 3–5 months. Longest phases: PPM negotiation with investors and bank/administrator onboarding. We actively manage the project through all stages.
Strategy analysis, form selection (ELP / SPC / Foundation), feeder jurisdiction, tax transparency.
PPM (Private Placement Memorandum), Subscription Documents, Investment Management Agreement, NAV Policy.
Selection and onboarding of administrator, custodian, auditor (Big-4), MLRO/DMLRO/AMLCO. Banking introduction.
Submission via REEFS portal: M&A, PPM, director KYC, fit & proper, certified resolutions.
A regulated Cayman fund must appoint at least four service providers. We have direct relationships with the top-10 administrators, all Big-4 firms and five licensed MLRO firms.
NAV calculations, regular reporting, investor KYC, AML. CIMA-licensed. Partners: Apex, MUFG, IQ-EQ, Citco, Trident Trust, Maples.
Custody of fund assets. For hedge funds — prime broker (Goldman, JP Morgan). For crypto — Coinbase Custody, BitGo, Fireblocks, Anchorage.
Required for Registered Mutual Funds. Annual audit under IFRS / US GAAP. PwC, KPMG, EY and Deloitte have local offices in George Town.
Money Laundering Reporting Officer, deputy and compliance officer. All three positions must be appointed and approved by CIMA. Local providers.
Cayman counsel supporting the fund. Drafting the PPM, Side Letters with investors, handling CIMA inspections.
One or two independent directors with CIMA Director Registration. Best practice — 3 directors (2 independent).
Legally — none. Economically — for a Mutual Fund it makes sense at $10M+ AUM (covers $80–120k annual costs for administrator, audit, directors). For Private Fund — $5M+, no Big-4 audit requirement. For Limited Investor Fund (≤15 LP) — even $1–2M is viable.
CIMA registration after REEFS submission — 5–7 business days. The long part is document prep (PPM, IMA, AML policies), administrator and auditor onboarding, bank account opening. Realistic timeline for a fully operational fund — 3–5 months.
Yes, with caveats. Administrator must support crypto subscriptions (not all do). Requires enhanced KYC on crypto wallets (chain analysis, source of wealth). Most administrators convert crypto subscriptions to USD immediately. Self-custody usually forbidden — need third-party custodian.
Not the fund itself — crypto fund under MFA/PFA automatically exempt from VASP Act if crypto activity is incidental to fund operations. But if the fund provides custody to third parties or operates as exchange — VASP License Phase 2 required. See VASP/Crypto section.
Setup costs: $35–55k (legal prep + CIMA + first administrator setup). Annual operating: $80–150k for Mutual Fund (Big-4 audit + administrator + 3 directors + MLRO + CIMA fees). Private Fund — $50–90k (no audit). At $20M AUM this gives 0.5–0.8% TER, market-competitive.
Describe your strategy and target AUM — we will send an optimal structure with stages, timelines, and cost breakdown. Under NDA, no obligations.