Privacy Under Pressure: Cayman vs. Hong Kong vs. Singapore vs. U.S. LLCs
When clients ask me where to incorporate, the conversation often revolves around tax, banking, and credibility. But there’s another question that has become just as important in the age of CRS, OECD, and AML rules:
👉 If I form a company in Cayman, Hong Kong, Singapore, or the U.S., how private is it really?
The world of secrecy is long gone. Bearer shares have been abolished almost everywhere. Nominee structures are under pressure. Beneficial ownership registers now exist even in traditional offshore jurisdictions. But that doesn’t mean privacy has disappeared completely — it just means it looks very different than twenty years ago.
Here’s how the four key jurisdictions stack up.
Cayman Islands: Privacy for Serious Money
Cayman was once the poster child of secrecy. Today, it is still private, but in a more regulated way.
Directors: Companies must file a register of directors with the Registrar, and this database is publicly accessible. There is however a $60 fee to view it.
Shareholders: The register of members is maintained at the registered office, but it is not filed publicly. Outsiders cannot see who the shareholders are.
Beneficial Owners: Since 2017, Cayman has required companies to keep a Beneficial Ownership Register with their registered office provider. This register is accessible to Cayman authorities (and indirectly to certain foreign regulators), but not to the public or journalists.
Financials: Cayman companies must keep proper accounts but do not have to file them publicly. Audited accounts are only required for regulated entities like funds.
👉 Bottom line: Cayman remains one of the most private jurisdictions. Authorities can see beneficial owners, but nothing is visible to the public.
Hong Kong: Names on the Record
Hong Kong used to balance credibility with a degree of privacy. That balance has shifted toward transparency.
Directors: Always public. Anyone can search the Companies Registry and see the names of directors. Since 2021, personal addresses and parts of ID numbers are masked, but the identities remain visible.
Shareholders: Shareholder names are public as well. If the shareholder is an individual, their personal name is recorded and can be searched. If the shareholder is a company, only the company’s name appears — which is why many Hong Kong entrepreneurs use a corporate shareholder to keep their personal name off the registry.
Beneficial Owners: Since 2018, every Hong Kong company must maintain a Significant Controllers Register (SCR) at its registered office. This register reveals the individuals behind corporate shareholders, but it is only accessible to authorities, not the public.
Financials: All Hong Kong companies must prepare audited accounts, which are filed with the Inland Revenue Department (IRD). These accounts are not publicly available in full, but the audit requirement means that privacy over financial results is much weaker than in Cayman or the U.S.
👉 Bottom line: Hong Kong offers limited privacy. Directors and shareholders are public, although individuals can use corporate shareholders to shield their names. Beneficial owners are known to authorities, and audits are mandatory.
Singapore: Transparency with a Controlled Core
Singapore has built its global reputation on clean governance and credibility. Privacy exists, but it is secondary to transparency.
Directors: Public. The Accounting and Corporate Regulatory Authority (ACRA) publishes the names and service addresses of all directors. Anyone can search online.
Shareholders: Public as well. If an individual directly holds shares, their name appears on ACRA. If a company is the shareholder, only that company is shown publicly.
Beneficial Owners: Since 2017, Singapore requires all companies to maintain a Register of Registrable Controllers (RORC). This register identifies the ultimate individuals behind the corporate shareholders. It is filed with ACRA and accessible to regulators, but not to the public.
Financials: Many Singapore companies must file financial statements with ACRA. For small private companies under certain thresholds, exemptions exist, but larger firms must file, and these financial statements can be purchased by anyone online for a nominal fee.
👉 Bottom line: Singapore is transparent by design. Directors and shareholders are public, financials are often accessible, and beneficial owners are known to authorities. Privacy is available only if you use layering (corporate shareholders), but even then, the regulators see through it.
U.S. LLC: The Last Privacy Refuge?
The U.S. remains surprisingly private at the public level, though this is now changing under the Corporate Transparency Act (CTA).
Directors and Members: In many states (Delaware, Wyoming, New Mexico), LLCs do not have to disclose members or managers publicly. Only a registered agent is listed. In others (California, New York), some disclosure is required.
Beneficial Owners: From January 2024, nearly all U.S. companies must file beneficial ownership information with FinCEN under the CTA. This is not public; it is accessible only to U.S. authorities and financial institutions.
Financials: LLCs generally do not file financial statements publicly. There is no requirement for audits unless regulated. Annual reports in most states are minimal and reveal almost nothing.
👉 Bottom line: U.S. LLCs still offer strong public privacy. No public ownership details, no public BO register, and no public financials. Authorities see more under the CTA, but the public sees almost nothing.
The Nuance on Shareholders: HK vs. Singapore
This is where confusion often arises.
In Hong Kong, both individual and corporate shareholders are listed publicly. If you own shares personally, your name is visible. If you use a company, only the company name shows. But since 2018, the Significant Controllers Register (SCR) requires the company to record who really controls the shares — information available to authorities, not the public.
In Singapore, it is the same: both individual and corporate shareholders are on public record. If you hold shares directly, your name is there for anyone to find. If you hold shares through a corporate vehicle, that company’s name is shown. But the Register of Registrable Controllers (RORC) ensures regulators know who ultimately owns the company, even if the public doesn’t.
So in both Singapore and Hong Kong, individuals can reduce their exposure by holding shares through a corporate entity. But regulators still have full visibility behind the scenes.
Privacy vs. Credibility: The Trade-Off
Cayman: High privacy, little public disclosure, but credible as a long-standing offshore hub.
Hong Kong: Transparency has increased; directors and shareholders are public. Privacy is thin.
Singapore: Similar transparency to Hong Kong, but with even easier access via ACRA. High credibility, low privacy.
U.S. LLC: Maximum public privacy. No ownership or financials on record in most states, though FinCEN filings mean authorities now know the beneficial owners.
The trade-off is clear. The more a jurisdiction is seen as a serious, credible financial center (Singapore, Hong Kong), the less privacy it offers. The more it protects privacy (U.S. LLCs, Cayman), the more questions it can raise with banks and regulators about substance.
Final Thoughts
Privacy is no longer absolute anywhere. But it hasn’t disappeared — it has shifted behind closed registers, away from the public eye and into the hands of regulators.
If you want maximum discretion at the public level, Cayman and U.S. LLCs still lead. If you want maximum credibility, Singapore and Hong Kong deliver — but at the cost of your name being on the record.
👉 We help clients navigate this trade-off, setting up Cayman companies, U.S. LLCs, and Singapore or Hong Kong entities depending on whether privacy, credibility, or tax optimization is your highest priority.
Ready to Structure with Privacy in Mind?
Choosing the right jurisdiction isn’t just about tax rates. It’s about who can see your name, what regulators demand, and how your company will be perceived. Cayman, Hong Kong, Singapore, and the U.S. each strike a different balance between privacy and credibility.
That’s where we come in.
We help clients:
Set up companies in Cayman, Singapore, Hong Kong, or the U.S. (LLC or corporation).
Design ownership layers that protect your name from public records while keeping you fully compliant with beneficial ownership laws.
Handle filings and registers (directors, shareholders, beneficial owners) so you never miss a deadline or risk exposure.
Advise on financial statement obligations, audits, and what will or won’t end up on public record.
Integrate structures with your residency plan (Dubai, Malta, Philippines, etc.), so privacy and tax strategy align.
👉 Book a consultation with us today. In one call, we’ll map out your priorities, explain exactly what level of privacy each jurisdiction offers, and design a structure that keeps you compliant while minimizing what the world can see.
Your name, your company, your future — let’s keep them protected.
