How can 3Rock support your tax compliance obligations?
3Rock provides CRS, FATCA, CARF, and Economic Substance compliance services for Reporting Financial Institutions in the Cayman Islands and globally. Our team brings direct DITC and OECD expertise to every engagement — ensuring your filings are not just submitted, but defensible.
What compliance services does 3Rock provide?
Our founding team brings together Big 4 private sector compliance experience, former OECD Global Forum Secretariat expertise, and the former Cayman Islands Department for International Tac Cooperation (DITC) Head of Compliance — covering every dimension of the frameworks we advise on.
We work with FIs of all sizes — from single-entity funds with straightforward structures to fund administrators and corporate service providers managing complex books of business across multiple entities and Reportable Jurisdictions.
Tax Reporting
We prepare and submit your annual CRS and FATCA XML returns, CRS Filing Declaration, and CRS Compliance Form through the DITC Portal. Our team understands the technical requirements of each filing — including mandatory fields and other critical data points — and ensures your submissions are complete, accurate, consistent with your due diligence records and reconcile with the CRS Compliance Form. We also support CARF reporting for Cayman Reporting Crypto-Asset Service Providers (RCASPs) and Economic Substance (ES) filing for Relevant Entities carrying on a Relevant Activity under the ES Act.
Governance & Due Diligence
Accurate filings depend on accurate underlying data. We review your FI classification, assess your population of Reportable and Non-Reportable Accounts, verify the validity and completeness of self-certifications, identify Account Holders and Controlling Persons, and ensure policies and procedures are fit for purpose — and help you amend them if they aren't.
Remediation
If your entity has missed previous reporting periods, has historical filing errors, or has received DITC correspondence, 3Rock provides targeted remediation support. Voluntary identification and correction, handled correctly, produces significantly better outcomes than being identified through a DITC compliance review. We also have the DITC enforcement experience to help guide the FI if the situation arises.
DITC PPoC Services
The Principal Point of Contact is the FI's designated liaison with the DITC, with administrative functionality to submit reporting, manage portal users, update classification information, and file for deactivation. A lapsed, incorrect, or unregistered PPoC appointment is itself a compliance breach — separate from your reporting obligations — and the DITC now requires a Cayman Islands-based PPoC on file.
Does your entity have CRS, FATCA, CARF, or Economic Substance reporting obligations?
If your Entity meets the definition of a Reporting Financial Institution (FI) under the Common Reporting Standard (CRS) or a Foreign Financial Institution (FFI) under the US Foreign Account Tax Compliance Act (FATCA), you have annual reporting obligations to the Cayman Islands Department for International Tax Cooperation (DITC). This includes investment funds, trusts, private equity structures, banks, custodial institutions, holding companies, and Crypto-Asset Service Providers subject to the CARF.
For a comprehensive review of DITC reporting obligations for the CRS, FATCA, CARF and Economic Substance, read 3Rock’s insight.
What are the annual DITC reporting deadlines for Cayman Entities?
CRS & FATCA
CRS XML returns for Reportable Accounts — due 31 July 2026
CRS Filing Declaration — due 31 July 2026
CRS Compliance Form — due 15 September 2026
Economic Substance
ES Notification — due in conjunction with the Annual Return
ES Return — due within 12 months of the Entity’s financial year end
Tax Resident Outside the Islands (TRO) Form - due within 12 months of the Entity’s financial year end
CARF
Registration on the DITC Portal - due by 31 January 2027
First reporting due 30 June 2027
What does compliance support cost?
3Rock offers structured service levels with transparent starting prices for single Cayman FIs. For fund administrators, corporate service providers, and trustees managing multiple entities or complex books of business, engagements are scoped and quoted individually following the intake process.
Note that every Cayman FI and RCASP is required to have a Cayman-based Principal Point of Contact (PPoC) on file by 31 January 2027. 3Rock can either take over an existing PPoC appointment, or assist FIs in registering as a new FI on the DITC Portal. This service is available as a standalone engagement or is included in each of the three compliance packages below.
Scenario A — Packages and pricing for simple administrative and reporting services
For straightforward administrative and reporting needs, 3Rock offers two standalone service options with fixed starting prices. These are designed for fund administrators and single FIs that have clean data, an established compliance framework, and need professional support for specific tasks — without the full scope of a compliance package.
DITC PPoC Appointment Only
From $500 USD
The Principal Point of Contact is the FI's designated liaison with the DITC, with administrative functionality to submit reporting, manage portal users, update classification information, and file for deactivation. A lapsed, incorrect, or unregistered PPoC appointment is itself a compliance breach — separate from your reporting obligations. Under the CRS and CARF Regulations, all Cayman FIs and RCASPs are required to have a Cayman-based PPoC on file by 31 January 2027.
This service includes:
General guidance on PPoC obligations and ongoing responsibilities
New Authorisation Letter and registration as PPoC on the DITC Portal
Secondary User management
Liaising with the DITC on regular communications
Escalating matters of targeted DITC compliance activities or enforcement actions
Submitting an FI/RCASP Deactivation Request to the DITC upon dissolution
This package does not include tax reporting, due diligence, or governance support. The DITC PPoC Appointment is offered as a standalone service, but is also included in all compliance packages
DITC Tax Reporting Only
From $1,500 USD
Annual CRS and FATCA filing support for a single Cayman Financial Institution (FI) where a current PPoC is already in place and the FI requires professional support for the submission of annual returns only. This service is designed for fund administrators who have clean account data, valid self-certifications, and confirmed entity classification — and need an experienced team to handle the technical preparation, submission of filings on the DITC Portal, and provide a filing confirmation report.
This service includes:
Acting as a Secondary User on the DITC Portal
Submission of CRS XML Returns (due 31 July 2026)
Submission of CRS Filing Declaration / NIL Return (due 31 July 2026)
Submission of CRS Compliance Form (due 15 September 2026)
Submission of CARF Registration (due 31 January 2027)
Submission of CARF XML Returns (due 30 June 2027)
This package does not include DITC PPoC Appointments, due diligence, or governance support. If your entity's classification, self-certifications, or account population have never been formally reviewed, please see the compliance packages below or book a free consultation.
Scenario B - Packages and pricing for Reporting, Due Diligence and Governance Services
For FIs requiring a more comprehensive compliance solution — or where the scope of work needs to be confirmed before a fee is agreed — 3Rock offers three structured compliance packages covering reporting, governance, due diligence, and advisory services. Starting prices reflect standard single-entity engagements. Multi-entity and complex structures are scoped and quoted individually following the intake process.
Compliant
The foundation. Core annual reporting obligations met correctly and on time. Designed for FIs with an established compliance framework and clean account data who need expert support with annual filing obligations. Includes PPoC Appointment, annual CRS & FATCA XML returns, CRS Filing Declaration, CRS Compliance Form, and a filing confirmation report.
Defensible
The complete compliance solution. Filings that stand up to scrutiny. Everything in COMPLIANT plus a thorough review of entity classification, reportable person population, self-certifications, and account records — ensuring what you file accurately reflects your actual compliance obligations. Also includes CARF registration and Economic Substance filing support as needed, and a tax filing report for the board or management.
Advisory
Full-service compliance management. For entities that need more than annual filing support. Everything in DEFENSIBLE plus historical reporting analysis, remediation planning, policies and procedures review, and active management of any DITC correspondence or penalty notices. For entities with complex structures, historical compliance gaps, or ongoing regulatory engagement with the DITC.
Packages & Pricing Levels
| Engagement Scope | COMPLIANT | DEFENSIBLE | ADVISORY |
|---|---|---|---|
| Single Financial Institution | from $3,500 USD | from $5,000 USD | from $7,500 USD |
| Multiple Financial Institutions | Contact us for a scoped quote | ||
| Service | COMPLIANT | DEFENSIBLE | ADVISORY |
|---|---|---|---|
| Core Filing | |||
| DITC PPoC Appointment | ✔ | ✔ | ✔ |
| Annual CRS XML Returns | ✔ | ✔ | ✔ |
| Annual FATCA XML Returns | ✔ | ✔ | ✔ |
| CRS Filing Declaration | ✔ | ✔ | ✔ |
| CRS Compliance Form | ✔ | ✔ | ✔ |
| Filing Confirmation Report | ✔ | ✔ | ✔ |
| Governance & Due Diligence | |||
| Entity Classification Review | ✖ | ✔ | ✔ |
| Reportable Persons Assessment | ✖ | ✔ | ✔ |
| Controlling Person Identification | ✖ | ✔ | ✔ |
| Self-Certification Verification | ✖ | ✔ | ✔ |
| Pre-existing Account Review | ✖ | ✔ | ✔ |
| Account Population Reconciliation | ✖ | ✔ | ✔ |
| CARF Returns | ✖ | ✔ | ✔ |
| Economic Substance Filing Support | ✖ | ✔ | ✔ |
| Tax Filing Report to Board/Management | ✖ | ✔ | ✔ |
| Remediation & Advisory | |||
| Policies & Procedures Review | ✖ | ✖ | ✔ |
| Historical Reporting Analysis | ✖ | ✖ | ✔ |
| Filing of XML Corrections | ✖ | ✖ | ✔ |
| Remediation Planning & Implementation | ✖ | ✖ | ✔ |
| DITC Correspondence Management | ✖ | ✖ | ✔ |
| Annual Compliance Health Check | ✖ | ✖ | ✔ |
| Penalty Notice Response Support | ✖ | ✖ | ✔ |
Scenario C - Bespoke Reporting, Due Diligence and Governance Services
Fund administrators, corporate service providers, trustees, and other entities managing CRS, FATCA, and CARF compliance across multiple FIs have needs that go beyond a standard package. 3Rock designs bespoke reporting, due diligence, and governance solutions that reflect the actual scope of the engagement — whether that means a book of ten entities or several hundred.
Bespoke engagements are scoped individually following a consultation and intake process. All fees are confirmed in writing before work begins. To discuss your specific situation contact us directly at info@3rock.ky or schedule a free consultation using the link below.
What does non-compliance actually cost?
The DITC Competent Authority has issued millions of dollars in penalties over the last 24 months. Under the current CRS Enforcement Guidelines:
A missed NIL Return carries a penalty of $12,000 USD;
Failure to submit a single Reportable Account attracts a fine of $6,000 USD per account, without a warning or Breach Notice, up to a maximum of $60,000 USD per FI; and
Once a Penalty Notice is issued for missed/late reporting the only avenue of appeal is through the Grand Court of the Cayman Islands
For a fund administrator managing multiple entities, missed filings across a book of business compound rapidly. The maximum penalty amount that can be applied under the CRS Regulations is $60,000 per Financial Institution. 3Rock's fees are therefore not a cost — they are insurance against consequences that are significantly more expensive.
DITC penalties are only one dimension of non-compliance risk. Tax administrations worldwide match the data in CRS XML returns against information submitted by their own taxpayers. Where a discrepancy arises, the competent authority of that jurisdiction may submit an Exchange of Information on Request (EOIR) to the Cayman Islands DITC — requesting all information held on that taxpayer. Inaccurate or incomplete CRS filings do not just create regulatory exposure in Cayman. They create tax investigation risk for your clients in their home jurisdictions.
Reach out to 3Rock
Ready to get started? Please click the link below to view our calendar and schedule a free consultation with a 3Rock advisor to discuss your situation. We respond to all enquiries within one business day.
For general enquiries contact us at info@3rock.ky.