All Cayman Islands entities that conduct "relevant financial business" 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”). This includes investment funds and registered person investment managers or advisers.
Whether acting as MLRO, DMLRO, or AMLCO, the named individuals must meet the below criteria:
Be a natural person at management level with the relevant knowledge, experience and expertise to act in the AML compliance capacity.
Have sufficient authority to be able to make recommendations to the Fund Board.
Have access to the necessary information and resources needed to appropriately perform the AML compliance function.
Be autonomous when carrying out their function.
The named AMLCO may also act as either the MLRO or the DMLRO; however the MLRO and the DMLRO must be two separate individuals.
Bell Rock provides the following compliance and regulatory support services to clients around the world from our offices in the Cayman Islands:
Provision of qualified and experienced individuals to accept appointments as Cayman MLRO, AMLCO and DMLRO
Provision of Cayman compliant and entity-specific AML policies and procedures
Acting as point of contact with the regulator – CIMA
Provide AML compliance oversight of the entity’s investment activity and investor-related AML activity
Establishing and maintaining appropriate systems and controls to ensure AML compliance
File Suspicious Activity Reports (SARs)
Maintain SAR registers
Train employees on AML reporting procedures
Facilitating and managing regular audits/testing of the entity’s AML program and KYC documentation
Ensuring procedures are in place and employees are aware of procedure for reporting of suspicious activity to Cayman MLRO / DMLRO
Maintaining AML logs relating to specified scenarios such as rejection of subscriptions, investor account freezes and enhanced due diligence on PEPs and other high risk investors
Advising the entity’s management (board/general partner) of AML compliance issues and periodically updating the board on the state of the entity’s AML programs and controls
Conducting risk assessments, adopting procedures to mitigate and monitor risks and reviewing periodically.
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