The Cayman Islands has further bolstered its anti-money laundering (“AML”) and countering of terrorist financing (“CTF”) rules. The new AML/CTF rules become effective on May 31, 2018 and will affect, among others, unregulated investment entities—such as private equity firms—domiciled in the Cayman Islands. The deadline to appoint AML officers, however, is September 30, 2018 for existing funds and June 1, 2018 for new funds.
The new requirements include designating a Deputy Money Laundering Reporting Officer, adopting a risk-based approach towards client due diligence, conducting due diligence on new employees and using the correct sanctions list. The new rules also require the identification of beneficial owners so that the right level of due diligence can be conducted on them. Lastly, the penalties for non-compliance have been increased.
Currently, the Cayman Island Monetary Authority (“CIMA”) is developing a sector-specific Guidance Note for unregulated investment entities, but there is no indication as to when that guidance will be published. In the meantime, it would be prudent to designate a Deputy Money Laundering Reporting Officer and let Ascendant help update your policies and procedures. Click here to see if your fund is registered with CIMA.
Please contact Ascendant directly for further information.