Totally new subject for me, before an account is opened (CD) what should I be looking for? US Citizen manages 2 trust accounts in the Cayman Islands. Those companies do not have EINs. They are a re-insurance company. They want to open 2 CDs that total $8 Million dollars. They money is currently in another bank and has been, they say, for a long time. No transactional accounts - for the moment. Am I justified in having concerns?

Any guidance would be appreciated.

Can the companies generate that type of revenue based on their financials? What the origin of funds and why do they need the CDs? It's hard to say if anything is suspicious without obtaining some additional information.

As stated above
but
FYI: Re-insurance is a big business in the Cayman Islands.
Also the Caymans got rid of the bearer share companies for more info see:

https://www.loebsmith.com/cayman-legal/abolition-of-bearer-shares-in-the-cayman-islands/41/

This may be an ignorant question since I do BSA and not tax or interest reporting, but would they not need EINs in order for you to pay interest on their $8MM CDs?

Whenever something like this shows up - I have all sorts of questions. The first is always - why my bank? Why not a bank that has an active international banking department and does this regularly and that knows actually how to handle this situation. Why are they moving from a long term relationship with another bank? I always suspect that they have been asked to leave - but that is just me.