CIMA also expects each fund to disclose in its offering document the fact that the fund has designated AML Officers and details as to how investors may obtain further information in respect of these officers.

For further details on the functions and appointment requirements of the AML Officers, please see Cayman Islands’ Anti-Money Launders regime updated and Update: Cayman Islands Anti-Money Laundering Regulations, 2017.

CIMA issued a notification on 24 September 2018 regarding the AML Officer appointment and notification deadlines (CIMA Notification). The deadline for:

1. the appointment of AML Officers by an unregulated fund; and
2. notifying CIMA (via the REEFS portal) of the appointment of AML Officers by a regulated fund,
have both been extended from 30 September 2018 to 31 December 2018.

Despite the CIMA Notification being silent on this point, CIMA has subsequently confirmed that they still expect regulated funds to appoint AML Officers as soon as they can and, in any event, by 30 September 2018

The specific next steps applicable to you will depend on a number of factors regarding your business, its structure, the AML regime being applied (if not the Cayman Islands AML regime) and your role within the industry. Please speak to Sailaja Alla in Cayman or your usual Appleby contact to understand fully any expanded obligations, document updates or new contractual agreements that may be required.

Share
Twitter LinkedIn Email Save as PDF
Key Contacts

Sailaja Alla

Partner: Cayman Islands

T +1 345 814 2054
E Email Sailaja

Judy Lee

Asia Group Head | Partner: Hong Kong

T +852 2905 5737
E Email Judy

Paul Cheuk

Partner: Hong Kong, Shanghai

T +852 2905 5756
E Email Paul

More News
17 Nov 2020 | News

Appleby Cayman ranked in six categories in Legal 500

Appleby’s Caribbean offices in Bermuda, the British Virgin Islands and the Cayman Islands achieved...

12 Nov 2020 | News

Appleby lawyer named Private Client Lawyer of the Year

Appleby partner Carlos de Serpa Pimentel has been named Private Client ‘Lawyer of the Year’ in t...

5 Nov 2020 | News

Appleby Sponsors FFA Virtual Global Symposium

Appleby is proud to be a platinum sponsor of the Global Fund Finance Association (FFA) Symposium for...

Contributors: Fiona Chan
30 Oct 2020 | News

Offshore Business Update

This is an update for our clients on how the authorities in our core jurisdictions are responding to...

21 Oct 2020 | News

Safe Haven Found: The Cayman Islands introduces Global Citizen programme for digital nomads

On 16 October 2020, the Cayman Government gazetted regulations bringing into effect its Global Citiz...

Contributors: Esmond Brown
14 Oct 2020 | News

Sally Penrose and Jennifer Parsons speak on Regulatory webinar panel to New York State Bar Association members

The New York State Bar Association is hosting a virtual webinar entitled ‘Bermuda and Cayman Islan...

Contributors: Jennifer Parsons
6 Oct 2020 | News

The Cayman Islands removed from the EU’s blacklist

Appleby is pleased to advise that the Council of the European Union confirmed on 6 October 2020 that...

25 Sep 2020 | News

Appleby advises Chi Kan Holdings Limited on its HKD 130 million listing on the Main Board of the Hong Kong Stock Exchange

Appleby acted as Cayman counsel to Chi Kan Holdings Limited in relation to its listing on the Main B...

Contributors: Minnie Choi
23 Sep 2020 | News

Appleby shortlisted ‘Offshore Firm of the Year’ by The Lawyer

Leading offshore firm Appleby has been shortlisted in The Lawyer Awards 2020, ‘Offshore Firm of th...