Cayman's Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) regime is heavily scrutinized by the Financial Action Task Force (FATF). Compliance is rigorously enforced.
The Three Pillars of AML
Every Cayman financial service provider, including unregulated investment entities, must appoint three dedicated officers:
- AMLCO (Anti-Money Laundering Compliance Officer): Responsible for the overall compliance function and reporting to the board.
- MLRO (Money Laundering Reporting Officer): The designated point of contact to receive internal suspicious activity reports and file SARs with the Financial Reporting Authority (FRA).
- DMLRO (Deputy MLRO): Acts in the absence of the MLRO.
Recent Enforcement Trends
CIMA has shifted from a guidance approach to an enforcement approach. Recent administrative fines emphasize that relying wholly on an overseas administrator is insufficient. The Cayman board must actively review AML reports, approve the AML manual, and document these actions in board minutes.
| Requirement | Frequency | Documentation |
|---|---|---|
| AML Audit | Periodic (typically annual) | Independent Report |
| Board Reporting | At least annually | Board Minutes |
| Risk Assessment | Ongoing | Formal Risk Register |