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Further to the notice issued by CIMA on 24 September 2018 relating to the requirement for all investment entities conducting relevant financial business to appoint natural persons to fulfil the roles of Anti-Money Laundering Compliance Officer, Money Laundering Officer and Deputy Money Laundering Officer, we can advise the following:

  • At present, in accordance with CIMA’s notice issued on 24th September 2018 all unregulated Cayman entities conducting investment business have until 31st December 2018 to appoint natural persons to fulfil the roles of Anti-Money Laundering Compliance Officer, Money Laundering Reporting Officer and Deputy Money Laundering Reporting Officer (collectively the “AML Officers”).
  • Regulated Cayman entities had to make such appointments by 30th September 2018 and have until 31st December 2018 to notify CIMA of the appointments via CIMA’s REEFS portal.
  • There is no current requirement for unregulated entities to notify CIMA of the appointment of AML Officers.
  • Unregulated investment entities include any Cayman domiciled entity which is “otherwise investing, administrating or managing funds or money on behalf of other persons”.
  • The amendments to the Guidance Notes on the Prevention and Detection of Money Laundering in the Cayman Islands mentioned in CIMA’s notice of 24th September 2018 have yet to be issued.

Further details of these roles and the responsibilities of each officer are outlined here.

It is important that the operators of Cayman Island investment entities consider these new requirements and whether or not they are subject to these new requirements.

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