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AMLCO – MLRO – DMLRO Service in Cayman Islands

The Requirement

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 that are in-scope and therefore subject to the above requirement are:

  • Regulated Investment Funds registered with CIMA;

  • 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.

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 Solution

IMS can provide AML Officers to act 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. CIMA has confirmed that a fund director may also act as CO and MLRO and/or DMLRO if they are fit and proper to conduct that role and are suitably qualified and experienced.

We are able to offer a tailored number of appointments (see below) to suit your requirements, and can arrange relevant documentation to effect the appointments.

Combinations of appointments offered
  • CO, MLRO and DMLRO

  • CO & MLRO

  • CO & DMLRO

  • MLRO and DMLRO

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 will provide a fee quote on request.

For more information on AML Officers please contact:

Ebony Myles Berry_edited (2).png

EBONY MYLES-BERRY

Fund Fiduciary

Tel: +1 (345) 526 5809

Email: emyles-berry@ims.ky

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