MLRO, DMLRO, AML Compliance Officer for Cayman Islands Funds
Following recent amendments to the Cayman Islands Anti-Money Laundering Regulations 2017 and Guidance Notes issued by CIMA pursuant thereto, there is now a requirement for all Cayman domiciled entities carrying out ‘relevant financial business’ (which includes funds) to appoint individual named persons as AML Compliance Officer (“CO”), Money Laundering Reporting Officer (“MLRO”) and Deputy MLRO (“DMLRO”).
A person acting as MLRO / DMLRO must (i) act autonomously; (ii) be independent (have no vested interest in the underlying activity); and (iii) have access to all relevant material in order to make an assessment as to whether an activity is or is not suspicious.
Entities captured and therefore subject to the above requirement are:
- Regulated Investment Funds registered with CIMA;
- Non-regulated Investment Funds, which include Private Equity/Debt, Real Estate Funds, Infrastructure Funds and ‘Funds of One’, whether closed or open ended;
- Any other entity carrying out ‘relevant financial business’.
The same person can be appointed as CO and either MLRO or DMLRO, but the MLRO and the DMLRO must be two separate individuals.
Funds registering as at June 1, 2018 are expected to register in full compliance. As are unregulated funds forming after 1 June 2018. Funds registered prior to 1 June 2018 and other entities in existence prior to that date which are newly subject to the requirements have until 30 September 2018 to become compliant.
Entities must therefore address these requirements as soon as practicable in order to comply with the requirement to appoint their CO, MLRO and DMLRO.
Our professional team at IMS have developed a solution for funds for which we currently provide independent directors.
One of the many benefits of our solution over other potential service providers is that our AML Officers will have face to face access to the director(s) we provide and access to fund documentation to which our directors obtain and review from all service providers to the funds we work with, giving them invaluable knowledge of the fund(s) operations and structures.
We are able to offer a tailored number of appointments (see below) to suit your requirements, and will arrange relevant documentation to effect the appointments.
Combinations of appointments offered
- CO, MLRO and DMLRO
- CO & MLRO
- CO & DMLRO
- MLRO and DMLRO
See the next page for details of the services provided in respect of the various appointments comprise.
Our pricing is dependent upon the specific appointments required and will reflect economies of scale where there are, for example, master feeder structures etc. We can provide a fee quote on request.