The Cayman Islands Monetary Authority (“CIMA”) recently re-emphasized that all persons carrying out relevant financial business (“Licensees and Registrants”) are expected and required to ensure that their Anti-Money Laundering Compliance Officers (“AMLCOs”), Money Laundering Reporting Officers (“MLROs”) and their Deputies (together, the “AML Officers”) are fully 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.
Licensees and Registrants are further required to ensure that appropriate appointments and the discharge of the day-to-day functions of these AML Officers are made or occur in compliance with Regulations 3, 4, 33 and 34 of the AMLRs.
Anti-Money Laundering Compliance Officers (AMLCOs)
Part II Section 2 (C) of the Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the Cayman Islands (the “CIMA Guidance Notes”) states, among other things, that AMLCOs must have the authority and ability to oversee the effectiveness of the Licensee’s and/or Registrant’s AML/CFT systems, compliance with applicable AML/CFT legislation and guidance and the day-to-day operation of the AML/CFT policies and procedures. An AMLCO must be a person who is fit and proper to assume the role and who:
(1) has sufficient skills and experience;
(2) reports directly to the Board of Directors (“Board”) or...
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