DESIGNATION/ APPOINTMENT OF MLRO, DMLRO AND AMLCO FOR FUNDS AND INVESTMENT ENTITIES
In late 2017 the Cayman Islands issued an amended Proceeds of Crime Law (“AML LAW”), Anti-Money Laundering Regulations and updated AML Guidance Notes (together “the Cayman AML
Under the Cayman AML Rules, the scope of entities that are captured as Relevant Financial Businesses (”RFBs”) increased to include not just Cayman Islands Monetary Authority (“CIMA”) registered and licensed funds, but other funds and investment entities falling into the definition of Relevant Financial Business, under the AML Law, Schedule 6.
In April 2018, CIMA in response to industry’s request for clarification on matters prescribed in the Cayman AML Rules confirmed the requirement for RFBs to designate natural persons, 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).
On July 19th, 2018 the Cayman Islands Monetary Authority (CIMA) released a list of FAQs focusing on the requirement for all relevant financial businesses (RFB) in the Cayman Islands to appoint an Anti-Money Laundering Compliance Officer, Money Laundering Reporting Officer, and Deputy Money Laundering Reporting Officer.