Two new Cayman Islands Monetary Authority (“CIMA”) rules came into effect on September 18, 2026. They strengthen, but do not replace, the existing framework, and well-prepared financial service providers should need only limited enhancements.
The framework stays risk-based and proportionate, as the rules mainly clarify existing expectations under the Anti-Money Laundering Regulations (“AMLRs”).
This is for general information only. This is not legal or compliance advice. Please read this alongside the CIMA rules and the AMLRs.
What’s changing
Rule 1: Effective compliance programme
Governance and oversight: the updated rule reinforces the importance of appropriate board oversight of the anti-money laundering and countering the financing of terrorism (“AML/CFT”) compliance programme and clear documentation of key decisions.
Anti-money laundering compliance officer (“AMLCO”) role: further clarity is provided around the independence and authority of the AMLCO, while continuing to permit the role to be outsourced.
Risk-based approach: the rule provides additional guidance on documenting the risk-based approach, including consideration of customer, geographic, product, service, and distribution-channel risks.
AML/CFT training: the updated requirements reinforce the importance of ongoing, role-appropriate AML/CFT training and maintaining appropriate training records.
Independent AML/CFT audit: the rule introduces further requirements around independent, risk-based AML/CFT audits to periodically assess the effectiveness of the compliance programme.
Rule 2: Financial sanctions and targeted financial sanctions (“TFS”)
Sanctions framework: the new rule provides additional guidance on incorporating financial sanctions and TFS into the existing AML/CFT framework.
Sanctions screening: the rule provides further clarity around the screening of customers, beneficial owners, transactions, and relevant connected parties.
Ongoing screening: additional guidance is provided around re-screening following relevant sanctions-list updates and considering whether any related risk assessments require updating.
Asset-freezing requirements: the rule provides further clarity on procedures relating to applicable asset-freezing requirements.
Regulatory reporting: the updated requirements provide additional guidance around Financial Reporting Authority reporting obligations and maintaining appropriate supporting records.
How we can help
A single source partner across the full Cayman fund lifecycle:
Compliance and AML
Money laundering reporting officer (“MLRO”), Deputy MLRO, and AMLCO provision
Independent AML/CFT audits
Business risk assessments
Compliance programme gap reviews
Governance and corporate
Fund governance and CIMA-registered directors
Company formation and corporate secretarial
Registered office services
Fund and financial
Fund administration and fund-of-funds custody
Special purpose vehicle administration
Voluntary liquidation
Tax and trust
Common reporting standard 2.0
Cayman-resident principal point of contact
Trust services and family office services
