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Appointment, Duties and Responsibilities of Anti-Money Laundering Officers


On 7th June 2021, the Cayman Islands Monetary Authority issued a reminder to all persons carrying on relevant financial business that they are expected to ensure their Anti-Money Laundering Compliance Officers (“AMLCOs”), Money Laundering Reporting Officers (“MLROs”) and their Deputies (together, the “AML Officers”) are aware of their respective duties and responsibilities as set out in the Anti-Money Laundering Regulations (2020 Revision) (as amended) (“AMLRs”) and will act in accordance with them.


AML Officers must be fit and proper to conduct their role and must be, inter alia:

  • suitably qualified and experienced;

  • persons at a management level who report directly to the Board of Directors or equivalent;

  • natural persons;

  • autonomous (meaning the AML Officer is the final decision maker as to whether to file a suspicious activity report); and

  • able to have access to all relevant material in order to make an assessment as to whether the activity is or is not suspicious.

They further reiterate 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, 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 person 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 circular in full, please click here.


Bell Rock Compliance & Regulatory Services

We routinely provide compliance and regulatory services to Cayman entities conducting relevant financial business including experienced AML Officers. For further information on our services, please feel free to contact us: compliance@bellrockgroup.com


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