Samuel Bulgin will retire as Attorney General in August 2027, ending almost a quarter-century in the Cayman Islands’ most senior legal office, the Cayman Islands Government (CIG) announced in a press release on 4 September 2026. The 11 months of notice gives the Governor and the Judicial and Legal Services Commission, which advises on the appointment, time to settle the succession. “I have chosen to give the Governor and my eventual successor the fullest possible notice of my intention to retire next year, so that this transition can be managed thoughtfully and without disruption to the important work of my Office,” Bulgin said in the release.

Bulgin became Attorney General in July 2003. By August 2027 he will have spent 24 years in the post, longer than any attorney general in the other British Overseas Territories, according to the release.

His tenure spans the 2009 Constitution, the international review of Cayman’s anti-money-laundering regime and a series of disputes over how far government must explain the legal basis of its decisions. One exchange sets the terms of any assessment. In Parliament on 5 November 2025, Bulgin answered a complaint by the outgoing chairman of the Anti-Corruption Commission that a confiscation order against Canover Watson made in 2018 remained unenforced by telling the House that “there is really no timeline within which to conclude these matters.” The court gave Watson six months to pay; the Proceeds of Crime Law allows no more than 12 months for payment in any case. The sum has been overdue, with interest accruing under the same Law, since August 2018.

The Caymanian Journal (TCJ) telephoned the Attorney General’s Chambers on multiple occasions seeking comment; the calls were not returned. On the Chambers’ instruction, TCJ emailed questions to the Attorney General’s executive secretary on 7 September 2026, covering the section 20 payment deadline, the Watson order, the Chambers’ role in enforcement, Operation Tempura, the 2019 evaluation, the licence-fee advice, his own assessment of his tenure and the Chambers’ expenditure. A second email on 14 September restated them and set a deadline of 16 September. No response was received by the date of publication.

Who Comes Next

The appointment belongs to the Governor, acting on the advice of the Judicial and Legal Services Commission. TCJ asked the Commission by email for its timetable, whether the search would go beyond the existing legal service, and whether Caymanian attorneys were in contention. On 8 September the Commissions Secretariat replied on the chairman’s behalf that the Commission “will conduct a competitive recruitment exercise for the next Attorney General in line with its published recruitment and appointment processes.” It gave no timetable and did not address Caymanian candidates. Its manual of 3 June 2025 requires an approved advertisement and contemplates recruitment from Cayman and overseas. The CIG release had gone further, promising “an open and competitive process” and “a rigorous and transparent process.” Asked whether the Governor had given the Commission any steer on transparency or enforcement effectiveness, the Governor’s Office said on 9 September that the process “will be led by the Judicial and Legal Services Commission, in accordance with the Constitution and relevant procedures.”

A 24-Year Run

At the Overseas Territories Attorneys General Conference in the British Virgin Islands on 13 to 17 April 2026, fellow delegates acknowledged Bulgin as the longest-serving attorney general among the UK Overseas Territories, according to the conference communiqué of 17 April. In the CIG release Governor Jane Owen said: “The Honourable Samuel Bulgin’s contribution to the Cayman Islands has been exceptional and enduring.” Asked by TCJ whether she wished to say more, the Governor’s Office replied by email on 9 September 2026 that her views “are reflected in the press release issued last week,” and that she “was informed of the Attorney General’s intention to retire in advance of the public announcement.”

Bulgin served as Crown Counsel and Senior Crown Counsel from 1992 to 1998 and as Solicitor General for six years before becoming Attorney General in July 2003. He took silk in 2004. His portfolio has included the Legal Department, legislative drafting, law reform, the Financial Reporting Authority and the Anti-Money Laundering Unit; he has chaired the Anti-Money Laundering Steering Group and was chairman of the Caribbean Financial Action Task Force (CFATF) in 2010-11 and 2022-23, according to FATF and CFATF plenary records. The Attorney General is the government’s principal legal adviser, represents public bodies and Parliament, and drafts Cayman’s laws; criminal prosecutions have belonged since 2009 to the independent Director of Public Prosecutions, a separation that bears on both Tempura and asset recovery below.

What the Office Costs

The Appropriation (Financial Years 2026 and 2027) Act, 2025, assented to on 1 December 2025, appropriates CI$11,308,142 to the Attorney General for 2026 and CI$11,832,005 for 2027 across six output groups, with a further equity investment in the Portfolio of Legal Affairs. The Schedule carries no subtotal; the totals are TCJ’s arithmetic. The Office of the Director of Public Prosecutions, by comparison, is appropriated CI$7,703,342 for 2026.

TCJ asked the Portfolio of Legal Affairs by email on 8 September 2026 for its approved appropriation and year-to-date expenditure in the current financial year. The Portfolio replied the same day that the information was published online and pointed to the Act and to the government’s unaudited quarterly financial report for the six months to 30 June 2026. That report, stated in CI$ thousands, contains no operating-expenditure line for the Portfolio; its only entry is the equity investment, CI$73,000 spent against a full-year budget shown as CI$403,000, the Act’s CI$402,500 rounded. The Portfolio did not supply the year-to-date figure it was asked for, and none is published in the document it cited.

The Tempura Legacy

Operation Tempura began in 2007 as a UK-led investigation into alleged misconduct within the Royal Cayman Islands Police Service (RCIPS) and grew to involve senior officers, a judge and government officials. Grand Court Justice Alexander Henderson was arrested on 24 September 2008; on his judicial review, Cause 528 of 2008, heard before Sir Peter Cresswell on 23 December 2008 according to the Governor’s Office written reasons of 7 March 2011, the Attorney General conceded that the arrest was unlawful, and the government agreed a settlement of CI$1.275 million. The Auditor General’s special report of 7 October 2009 put the cost of Operations Tempura and Cealt at CI$5.7 million to January 2009 with a further CI$1.1 million estimated to June, and found the expenditure lacked adequate oversight. TCJ has not located an audited final total. Two Grand Court jury trials followed: former MLA Lyndon Martin was acquitted on 10 September 2009 and former Deputy Police Commissioner Rudolph Dixon on 7 October 2009. At the time, prosecutions were conducted by the Legal Department within the Attorney General’s portfolio and funded as an Attorney General output group; the Appropriation Law for July 2010 to June 2011 still listed Prosecution Services under the Attorney General.

His role is on the record. On 27 February 2008, following unsuccessful warrant applications against senior officers, he advised the Governor that disciplinary or other action would be unwise, according to paragraph 125 of the written reasons; Governor Stuart Jack nevertheless placed three senior officers on required leave on 27 March 2008. In January 2014, Martin Bridger, the former senior investigating officer, filed a complaint with the RCIPS alleging that Bulgin and other senior officials had misled the investigators about their involvement. Bulgin denied it, and on 1 August 2014 the RCIPS said the allegations had been fully investigated, no criminal conduct had been proved and no further action was warranted. Tempura originated in the Governor’s sphere, and responsibility for it was never the Attorney General’s alone.

Cayman’s Money-Laundering Reckoning

CFATF’s Mutual Evaluation Report on the Cayman Islands, published in March 2019 on a December 2017 on-site visit, found “major deficiencies” in the understanding of risk and said Financial Reporting Authority disclosures were used “to a negligible extent to initiate investigations.” It rated Cayman’s effectiveness on confiscation “moderate.” FATF placed Cayman under increased monitoring on 25 February 2021 and removed it on 27 October 2023, stating that the strategic deficiencies in its action plan had been addressed. Bulgin chaired the Anti-Money Laundering Steering Group that led the government’s response, and his second CFATF chairmanship coincided with the final stages. The establishment that had to answer the international findings was the one he had helped lead as Attorney General since 2003. FATF assessments examine not merely whether laws exist, but whether they work in practice, including whether money-laundering offences are successfully prosecuted and criminal assets are recovered.

When Confiscation Takes Years

In an order reported on 1 February 2018, two years after Watson was jailed over the CarePay scheme, Grand Court Justice Marlene Carter ordered him to pay CI$925,995.58, with six months to pay and a six-month default sentence. In the Anti-Corruption Commission’s annual report to 30 June 2025, signed on 30 September 2025 and published on 22 October, outgoing chairman Charles Jennings wrote: “I regret to report that neither of those confiscation orders has yet been enforced, even (in the case of CarePay) after seven years.” He called the delay “unacceptable,” said such failures “make the jurisdiction and its judicial and enforcement processes appear incompetent,” and urged enforcement “with the same expedition as they did the substantive prosecution.” The second matter is Watson’s football-fraud conviction of October 2022, in which the DPP said in November 2025 confiscation proceedings had yet to conclude, so the record shows one final order, not two.

Asked by TCJ on 14 September for any update and for its response to the Attorney General’s answer to Parliament, the Commission replied by email on 16 September 2026 that the enforcement of confiscation “fall[s] outside the statutory remit of the ACC” and that “all such recovery matters are for the prosecutors and the courts.” Its concerns in the 2025 report “remain generally relevant,” it said, but reporting on the status of recovery “should be entirely directed to, and be received directly from, the offices of the DPP and / or the AG. Those offices will be best placed to advise you of what the current position is.”

Director of Public Prosecutions Simon Davis said, in comments published by the Cayman Compass on 3 November 2025, that prosecutors had made repeated applications to enforce the order, that the court had declined to activate the default sentence, and that nothing had been repaid. TCJ emailed the ODPP on 14 September asking whether an enforcement application had been issued against Watson and when, what had become of the assets restrained in June 2017, how much had been collected, whether any appeal or variation was pending, when the next hearing was listed, and how many confiscation orders had been made and how much collected since the Law came into force. No response was received by the date of publication.

Bulgin answered in Parliament on 5 November 2025, without naming Watson, referring to “the tardiness, if I might call it that, of enforcing some confiscation matter.” He told the House: “Suffice it to say, Mr. Speaker, that first of all, there is really no timeline within which to conclude these matters and they usually, by their nature, tend to be protracted.” It was “understandable that all efforts will be made by these people to resist the confiscation, including pursuing appeals.” He acknowledged that “the former chair clearly was unhappy about the pace at which this matter has been dealt with,” and that “it is true the matter is taking a while but, as we speak, the matter is still properly pending before the court, so it is not a lost cause.” Cayman was “quite aware of its obligation to the FATF,” and he concluded: “we are confident that at some stage there will be a resolution to the matter, Mr. Speaker.” (Official Hansard Report, Third Meeting of the 2025-2026 Session, Wednesday 5 November 2025, page 10.)

The statute sets a date for payment. Section 20 of the Proceeds of Crime Act (2025 Revision) makes a confiscation order payable on the day it is made; a court may allow up to six months, and in exceptional circumstances no more than 12 months from the order. Section 21 charges interest at the civil judgment rate from the day payment falls due. The Proceeds of Crime Law, 2008 was passed on 30 June 2008, five years into Bulgin’s tenure, drafted by the Legal Department he then headed, and came into force on 30 September 2008. On the court’s own terms the Watson sum fell due in August 2018; on the latest date section 20 allows, in February 2019.

Section 20 governs when the defendant must pay, not when the authorities must finish enforcing, and an order does not lapse after 12 months. The Attorney General’s answer is accurate as a description of enforcement litigation. What the statute his department drafted does fix is the date the money was owed, and the Commission’s question was why, seven years after it, none had been collected. Watson’s second trial, from August 2022 to sentence in April 2023, and his appeal, decided on 8 November 2024, may account for part of that period, and Bulgin’s point about “appeals” carries weight for it. TCJ has not identified an appeal against the 2018 order itself.

The Attorney General’s connection to the delay is not the drafting. He chairs the Anti-Money Laundering Steering Group that answers to FATF for whether Cayman’s system works in practice, including its “moderate” rating on confiscation in 2019. The Financial Reporting Authority sits in his portfolio. And when Parliament asked, he was the officer who answered, and his answer said nothing about what enforcement steps had been taken, by whom, or when.

Larger systems also struggle to collect: the Law Commission of England and Wales put outstanding confiscation debt at more than £2 billion at 31 March 2021. The Watson order is of a different kind: just under CI$1 million, against a man whose “assets of significant value” Chief Justice Anthony Smellie recorded as restrained pending confiscation on 16 June 2017.

The government’s 2021 National Risk Assessment records six applications to confiscate assets following convictions between 2018 and 2020, involving defendants found to have benefited from their criminal conduct by US$10 million. The passage does not state the total value of the resulting orders or how much was collected. TCJ asked the Office of the Director of Public Prosecutions how many confiscation orders had been made and how much had been collected since the Proceeds of Crime Law came into force on 30 September 2008. No response had been received by publication.

Enforcement of the order is the ODPP’s; the statute it enforces, and the policy response to the 2019 evaluation, sit within the Attorney General’s portfolio.

Legal Advice and the Licence-Fee Dispute

In Finance Committee on 17 November 2025, Bulgin said there was a “presumption of legality” when legislation was enacted for the proposed two-tier driver’s licence fees, under which non-Caymanians were to pay roughly eight times the Caymanian rate. When TCJ asked the Chambers in July 2026 for the legal basis of the structure, the Chambers did not respond by the deadline; on a follow-up call a member of staff said TCJ could take it that the Attorney General had declined to comment. Jay Ebanks MP, Minister for Planning, Lands, Agriculture, Housing and Infrastructure, said the regulations had been developed with legal advice from the Chambers. On 31 August 2026 the government announced that the fees would be revised before taking effect, and from 1 September the differential fell to roughly three times the Caymanian rate. The reasoning behind the original structure was not published.

A New Framework for the Bar

The Legal Services Act, 2020 was brought fully into force on 1 January 2026 by a commencement order gazetted on 26 November 2025, with five sets of regulations. CIG said more than 1,200 attorneys worldwide practise Cayman law, and Bulgin said in the same release: “Commencing the LSA culminates a long journey, spanning more than two decades.” The Law Reform Commission’s 2007 report records that a draft bill was prepared in August 2003 on the Attorney General’s instructions, a month after he took office. Successive governments, legislators and the profession shared the timetable, but it is part of the record of an attorney general in office throughout.

The Ledger

The record includes 24 years of continuity, a constitutional transition, the modernisation of legal-services regulation and Cayman’s exit from FATF monitoring. It also includes the cost of Tempura and its two acquittals, the deficiencies found by international evaluators, a confiscation order unpaid more than eight years after it fell due, and episodes in which the public was given the conclusion that government action was lawful without the reasoning.

Peter Polack, who practised as a criminal lawyer in the Cayman Islands and now writes opinion pieces for TCJ and other titles in the region, commented to TCJ on 16 September 2026: “Prosecutions are led by the DPP but the legal system by the AG. To narrow the decades of failed leadership by the AG to the recent confiscation issue is a mistake. That is the most recent of a continuum of non-performance abetted by politicians over the decades.”

Chief Inspector Patrick Beersingh, who was approached by TCJ on 18 September and replied by email on 22 September in a personal capacity, said he first met Bulgin “when he served as a prosecutor in the Legal Department (now the Office of the DPP). He quickly distinguished himself as a calm, highly capable professional and a steadfast ally to law enforcement. He guided many investigators, including myself, contributing to numerous successes in bringing dangerous offenders to justice.” He added: “From a law enforcement perspective, the Cayman Islands has safely and successfully navigated many complex challenges thanks to the steady hand and wisdom of Sam Bulgin as AG.”

Asked by TCJ at a CIG media briefing on 10 July 2026, two months before the retirement was announced, whether he had confidence in the Attorney General, Premier André Ebanks MP said: “Legal drafting falls under his chambers and they do an excellent job all day, every day, producing legislation within our timelines.” He did not say whether he had confidence in the Attorney General.

The Succession Test

The successor inherits an office with an appropriation above CI$11 million and a portfolio spanning financial intelligence, drafting and law reform, and the question the FATF process left: whether convictions lead to recovery. In the 4 September release Bulgin said: “I remain wholly committed to every function under my portfolio for the remainder of my term.” Before he leaves, the Watson sum will have been overdue for nine years on the court’s own terms. Whether it is collected before August 2027 is a question the record leaves open.