Category: Jurisdiction Profiles

The Cayman Islands is one of the world’s most established offshore financial centres – home to the majority of the world’s hedge funds and a significant PPLI ecosystem with 149 licensed Segregated Portfolio Companies holding approximately USD 11 billion in assets. Regulatory sophistication, however, is not the same as regulatory accountability. THE FRAMEWORK The Insurance Act 2010 (effective November 2012) modernised Cayman’s insurance framework, with the Cayman Islands Monetary Authority (CIMA) responsible for licensing, supervision, and enforcement. The Act establishes four main classes: Class A (domestic), Class B (captive), Class C (exempted reinsurance), and Class D (reinsurance). The Segregated Portfolio Company (SPC) structure provides statutory asset segregation, enabling captive insurers to include multiple partners without cross-liability — a structurally sound

The Bahamas is an established English common-law financial centre with Privy Council appellate access, a dedicated offshore insurance regime, and a long history of servicing international HNWI clients. It also carries a sub-investment-grade sovereign credit rating, has no dedicated PPLI legislation, and its most significant recent regulatory episode – the FTX Digital Markets collapse – followed a pattern that should concern any client evaluating where to domicile a long-term insurance wrapper. Measured against the full range of jurisdictions that compete for PPLI business – from the Crown Dependencies and EU centres to Singapore, Hong Kong, and Bermuda – the Bahamas’s structural position is weaker than its marketing profile suggests. THE FRAMEWORK The Bahamas regulates domestic insurance under the Insurance Act

Bermuda hosts more PPLI capital than any other single jurisdiction – an estimated USD 40 billion across 3,061 policies. If scale were the only measure of a PPLI domicile’s quality, Bermuda would win by default. It is not, and Bermuda does not. THE FRAMEWORK Bermuda’s Insurance Act 1978 (significantly amended through 2024) provides a mature legislative foundation, overseen by the Bermuda Monetary Authority (BMA). The jurisdiction achieved full Solvency II equivalence in March 2016 and NAIC Reciprocal Jurisdiction status in January 2020 — credible markers of regulatory alignment with global standards. The Segregated Accounts Companies Act 2000 enables statutory segregation of assets, and Bermuda’s capital framework centres on the Enhanced Capital Requirement (ECR), set at 120% of the Bermuda Solvency