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 (“AMLCO”), Money Laundering Officer (“MLRO”) and Deputy MLRO (together the “AML Officers”) we can advise the following:
- Funds licensed or regulated by CIMA must appoint AML Officers by 30 September 2018 and notify CIMA of the appointments by 31 December 2018 via CIMA’s REEFS portal;
- Unregulated investment entities must appoint AML Officers by 31 December 2018 but currently are not required to register the appointments with CIMA.
Further details of these roles and the responsibilities of each office are outlined here.
Clients should note that “unregulated investment entities” includes any entity established in the Cayman Islands which is ‘otherwise investing, administering or managing funds or money on behalf of other persons’.
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.
How can SMP assist?
SMP provides specialist Anti-Money Laundering and Countering Terrorism financing services to Cayman investment entities to ensure compliance with the requirements set out in the AML Legislation and Guidance Notes. These services include the provision of AML Officers.
For more information on these services please contact your SMP Relationship Manager or one of the individuals listed below, who will be happy to assist you with any queries you may have.
Tel: +1 345 814 4825
Tel: +1 345 814 4841
Tel: +1 345 914 4674