The Cayman Islands’ Anti-Money Laundering (AML) Regulations 2017 (AML Regulations) which came into effect on 02 October 2017 introduced a number of new requirements for Cayman financial service providers, which includes Cayman investment funds. The primary aim of the new requirements is to bring Cayman in line with international best practices. One of the most significant changes introduced by the AML Regulations impacting Cayman funds is the requirement to appoint AML officers.
Centaur provides experienced professionals to perform the roles of AML Compliance Officer (AMLCO), Money Laundering Reporting Officer (MLRO) and Deputy Money Laundering Reporting Officer (DMLRO) for funds. These officers will be accountable to the board/governing body of the fund in respect of the following duties:
- Ensuring the fund has adequate procedures in place to comply with all aspects of the Regulations.
- Regularly requesting and reviewing information from the fund administrator and/or the investment manager to assess the money laundering and terrorist financing risks to which the fund may be exposed.
- Regularly requesting and reviewing information from the fund administrator and/or the investment manager to monitor anti-money laundering and anti-terrorist Financing compliance.
- Receiving and investigating suspicious activity reports (SARs) and where deemed necessary, reporting such to the Cayman Financial Reporting Authority.
- Reporting to the board/governing body on the fund at its scheduled meetings on compliance with the AML Regulations.
- Conducting annual reviews of the fund administrator’s and/or the investment manager’s anti-money laundering and anti-terrorist financing procedures and controls.
- Performing periodic testing to verify the fund’s compliance with the AML Regulations.