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Cayman Islands regulators increase focus on AML compliance

16 June 2021

The Cayman Islands Monetary Authority (“Authority”) has issued a reminder of the responsibilities of key AML compliance officers in regulated firms.

The Cayman Islands Monetary Authority (“Authority”) issued a General Industry Notice on 7 June 2021 to remind Licensees and Registrants that they are required to ensure their Anti-Money Laundering Compliance Officer (AMLCO) , Money Laundering Reporting Officer (MLRO) and Deputy Money Laundering Officer (“AML Officers”) are aware of their duties and responsibilities as set out in the Anti-Money Laundering Regulations (2020 Revision) (as amended) (“AMLRs”) and will act in accordance with them.

Licensees and Registrants are further required to ensure that appointments and the discharge of the day to day functions of these AML Officers are made or occur in accordance with Regulations 3, 4, 33 and 34 of the AMLRS.

The AML Officers must be suitably qualified and experienced individuals at managerial level who can act autonomously and report directly to the Board of Directors or equivalent.

In particular, the Authority reiterates that:

  1. AML Officers must be able to dedicate sufficient time for the efficient and effective discharge of their respective functions. Where an AML Officer has other professional roles and responsibilities, these should not compromise their independence or ability to carry out their AML functions.
  2. AML Officers must be versed in the different types of transactions that the business conducts which may give rise to opportunities for money-laundering, terrorist financing, proliferation financing and any direct or indirect activity with designated persons or entities.
  3. Where the AML Officer function is outsourced, the Licensee or Registrant retains ultimate responsibility for compliance with the AMLRs and must maintain adequate policies and procedures.

To read the Notice for more information.

How can we help?

Apex can provide suitably qualified and experienced AML Officers as an outsourced service for your Cayman fund. We can also provide additional AML services to ensure that your fund fully meets its regulatory obligations.

If you would like some more information about our outsourced Cayman AML Services, please contact us.


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