The BVI and Cayman light-touch manager regimes solve the same commercial problem — letting a fund manager operate without a full licence — through opposite regulatory logics: one caps you by size, the other by client type, and that difference should drive the jurisdiction choice.
Note: “SIBA” refers to two unrelated statutes that happen to share an acronym — the BVI's Securities and Investment Business Act, 2010, and the Cayman Islands' Securities Investment Business Act. Each reference below is jurisdiction-specific.
The BVI Approved Manager regime is fundamentally a size-gated carve-out: any qualifying BVI company or limited partnership can act as manager or adviser to eligible funds provided AUM stays under US$400 million (open-ended) or US$1 billion in aggregate commitments (closed-ended), regardless of how sophisticated the underlying investors are. The Cayman Registered Person regime is, by contrast, a client-type-gated carve-out: there is no AUM ceiling, but the manager must serve exclusively sophisticated persons, high-net-worth persons, group affiliates, or business already regulated overseas. Both regimes are administered by their respective apex regulator and both sit as an alternative to, not a replacement for, each jurisdiction's full investment business licence.
This structural difference has real consequences. A large, institutionally-backed closed-ended fund with only a handful of sophisticated investors but well over US$1 billion in commitments would outgrow BVI's Approved Manager cap quickly but could remain a Cayman Registered Person indefinitely. Fee levels are broadly comparable in the low-to-mid five figures annually, though Cayman's registration fee runs roughly three to four times the BVI Approved Manager annual fee, a point promoters weighing pure cost should note.
| Feature | BVI Approved Manager | Cayman Registered Person |
|---|---|---|
| AUM / commitment caps | US$400m (open-ended) / US$1bn commitments (closed-ended) | None — no AUM ceiling under this gateway |
| Application / annual fee | US$1,200 / US$1,800 (confirm current schedule) | ~US$6,098 (CI$5,000) / ~US$6,098 |
| Approval timeline | File ≥7 days pre-launch; provisional operation while FSC reviews | REEFS filing; can take several weeks (estimates vary) |
| Ongoing obligations | Unaudited financials within 6 months of FYE; annual and AML returns; no audit/PI insurance required | Annual declaration only; no audit required; mandatory AML/CFT officer appointments |
| Eligibility criteria | BVI company or LP only; manages BVI or recognised-jurisdiction funds | Sophisticated/HNW client business, group-only business, or overseas-regulated equivalent |
| Investor-count restriction | Indirect, via the underlying fund's own category | No fixed headcount cap — gated by investor quality, not count |
The BVI Approved Manager regime derives from subordinate legislation made under BVI SIBA, supplemented by FSC guidelines. The application runs through a BVI registered agent or legal advisor and is lodged with the FSC at least seven days before intended commencement, after which the applicant may trade provisionally for a defined period while the FSC completes review. Cayman's Registered Person pathway runs through CIMA's REEFS online portal, requiring client lists, director and shareholder questionnaires, an organisational chart, and AML compliance-officer details; directors must independently be registered under the Director Registration and Licensing Act 2014.
Ongoing supervision differs meaningfully in intensity even though both are light-touch relative to a full licence. The BVI regime requires annual unaudited financial statements and several calendar-driven filings but no audit, compliance officer, or capital and insurance requirements. Cayman's Registered Person track requires only an annual declaration and fee — no financial statements at all — but layers on more prescriptive AML/CFT governance, including a formally appointed compliance officer structure subject to periodic independent AML audit.
Berkley Fund Services works alongside BVI and Cayman investment managers and their legal counsel to keep the fund-level filings, investor records and administrator-facing obligations that accompany each manager regime running smoothly. Managers weighing up their licensing options are welcome to discuss a proposed structure with Berkley's team.
This article is provided for general information purposes only and does not constitute legal, regulatory or tax advice. Fund promoters and managers should seek independent professional advice before establishing or investing in any of the structures described.