AML & Compliance Services

The Cayman Islands Monetary Authority (“CIMA”) has noted that for a Cayman Islands investment entity to comply with the Anti-Money Laundering Regulations (2018 Revision) (“AML Regulations”), it must designate a natural person, 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”).
​

The AML Regulations apply to all Cayman entities carrying out "relevant financial business."

From 1 June 2018, new entities must be able to immediately demonstrate compliance with this requirement. Registered funds will need to designate the AMLCO, MLRO and DMLRO via the REEFS portal. 

The AMLCO is required to have AML oversight of an investment entity’s activities, going beyond investor related AML issues and compliance. The designated individual will be required to take measures to develop and maintain systems and controls, regularly reporting to and advising the Board of issues that should be addressed and liaising with and responding to requests from relevant regulatory bodies and authorities. The MLRO and DMLRO will serve as the key points of contact for all suspicious activity reports and will be responsible for reporting suspicious activity to the appropriate authorities.

The same person can act as the AMLCO and either the MLRO or DMLRO.  The MLRO and DMLRO must be separate persons. All persons appointed must have adequate and appropriate knowledge and expertise to perform the function and should demonstrate autonomy in their ability to carry out their designated function.