Following an open and constructive dialogue with Cayman Finance members, the Cayman Islands Monetary Authority (CIMA) has issued further guidance relating to Anti-Money Laundering Regulations.
CIMA has confirmed that as per Schedule 6 of the Proceeds of Crime Law (2018 Revision), a fund – regulated or unregulated – which is doing business in or from within the Cayman Islands, must designate persons at managerial level to act as its Anti-Money Laundering Compliance Officer (AMLCO), Money Laundering Reporting Officer (MLRO), and Deputy Money Laundering Reporting Officer (DMLRO).
For funds in existence prior to 1 June 2018, these appointments must be made by 30 September 2018. Going forward, all new funds are required to have these roles in place. There is the provision for these roles to be based outside of the Cayman Islands, provided that they meet the suitability criteria as set out in the law.
It is important to note that there is no current intention to place a limit of the number of AML Officer appointments one person can take on. However, the over-riding requirement for a risk-based approach must be considered.
Much thanks must be given to the AML Working Group for their hard work done to advance the industry’s best interests in this area.
For more read the CIMA Guidance Notes here.