Apr 2026
This guide summarises the registration obligations of in-house counsel employed by insurance companies under the Anti-Money Laundering Regulations (2025 Revision) (AMLRs) and the Legal Services Act (2020 Revision) (LSA). The Legal Services Supervisory Authority (LSSA) administers the registration regime for all firms of attorneys-at-law, including in-house counsel. This guide is intended for in-house legal professionals working within insurance firms, including those based outside the Cayman Islands.
Does My Insurance Company Need to Register with the LSSA?
No. Insurance companies licensed in the Cayman Islands are regulated under the Insurance Act and supervised by the Cayman Islands Monetary Authority (CIMA). The LSSA has confirmed that insurers do not need to register as Designated Non-Financial Businesses and Professions (DNFBPs). No additional registration is required beyond compliance with the Insurance Act and ongoing CIMA supervision.
Do I Need to Register Individually as In-House Counsel?
Yes. Although an insurance company does not register with the LSSA in its own capacity, in-house counsel employed by an insurance firm must register individually. Pursuant to sections 53A, 53AA and 55F of the AMLRs, all firms of attorneys-at-law must register with the LSSA. This obligation extends to attorneys who provide legal services exclusively to their employer, other than the Cayman Islands Government (which includes a government company, an entity within the public service or a statutory authority). Registration is mandatory, forming part of the jurisdiction’s wider AML/CFT/CPF framework and is essential to maintaining the Cayman Islands’ high standards of professional and regulatory integrity.
This requirement applies irrespective of whether the employing insurance company is already regulated by CIMA.
What If I Am Based in the Cayman Islands but Not Admitted to Practise Cayman Islands Law?
The LSSA registration obligation applies to attorneys admitted to practice law in the Cayman Islands. In-house counsel who are physically present in the Cayman Islands but who are not Cayman-admitted are not permitted to practice Cayman Islands law and do not fall within the scope of the registration requirements. Such individuals must not hold themselves out as qualified to advise on Cayman Islands law, as doing so may constitute the unauthorised practice of law.
Any work touching upon Cayman Islands law should be reviewed and signed off by a Cayman-licensed attorney. Insurance companies should maintain clear internal protocols to ensure that matters requiring Cayman Islands legal advice are identified and appropriately referred to Cayman-admitted counsel or external Cayman Islands legal advisers.
What If I Am Not Physically Present in the Cayman Islands?
Whether in-house counsel are required to register with the LSSA depends on whether they are practising Cayman Islands law, regardless of whether they are doing so within the Cayman Islands or in another jurisdiction. Accordingly, entities would need to assess whether their in-house counsel are engaged in the practice of Cayman Islands law, if so, registration would be required.
As a matter of recommended best practice, any Cayman Islands legal work undertaken by such counsel should be reviewed and signed off by a Cayman-licensed attorney. Firms and in-house counsel are also encouraged to seek specific guidance where necessary regarding their particular organisational structure and obligations under the LSA.
Registration Process and Fees
Registration is administered by the LSSA. In-house counsel must complete and submit the prescribed declaration form. The declaration form and further details are available at: https://caymanlssa.ky/in-house-counsel/
Under Regulations 55E and 55F of the AMLRs, all registered firms and sole practitioners must ensure that accurate and up-to-date information is provided to the LSSA on an ongoing basis.
Consequences of Non-Compliance
Failure to register constitutes a breach of the AMLRs and may result in enforcement action.
Key Takeaways
There is no duplication of regulatory oversight for Cayman Islands insurers under the DNFBP regime; insurers continue to comply with AML/CFT obligations under the Insurance Act and CIMA supervision.
Insurance companies should ensure that any Cayman-admitted in-house legal counsel is aware of, and compliant with, their separate LSSA registration obligations. Proactive internal policies, training, and clear assignment of responsibilities can help insurers maintain compliance, mitigate regulatory risk, and ensure obligations are effectively managed.
For more information on the LSSA, please see: Legal Services Act Fully in Force: Implications for the Cayman Islands Insurance Market – Conyers.