Extensions to deadline regarding AML officer appointments
The Cayman Islands Monetary Authority (CIMA) issued a notice on 24 September 2018 regarding deadlines for the appointment and notification of Anti-Money Laundering Compliance Officers (AMLCOs), Money Laundering Reporting Officers (MLROs) and Deputy Money Laundering Reporting Officers (DMLROs) (collectively, the AML Officers).
Marbury has received clarification on the content of this CIMA notice as per the following:
(a) Funds registered with or licensed by CIMA (Regulated Funds) are still required to appoint the AML Officers by 30 September 2018. However, such Regulated Funds will now have until 31 December 2018 to complete the relevant notification filing on CIMA’s Regulatory Enhanced Electronic Forms Submission (REEFS) portal. (See (3) below).
(b) Private equity funds, exempt mutual funds and other investment vehicles conducting relevant financial business that are not registered with or licensed by CIMA (Unregulated Investment Entities) have had the deadline for the appointment of AML Officers extended to 31 December 2018. There is currently no associated CIMA notification or filing requirement for Unregulated Investment Entities.
- UNCHANGED: Must appoint AML Officers by 30 September 2018
- EXTENDED: CIMA notification deadline is now 31 December 2018
Unregulated Investment Entities
- EXTENDED: appointment deadline is now 31 December 2018
- N/A: Currently no notification requirement
- The above is applicable only to Regulated Funds and Unregulated Investment Entities which were in existence prior to 1 June 2018. Any such entity which commenced operations on or after 1 June 2018 is required to have AML Officers in place upon launch.
- The extensions are to ‘grace periods’ only. The legal obligation to have AML Officers and relevant documentation in place is strictly already applicable to all such entities (whether Regulated Funds or Unregulated Investment Entities) and therefore we recommend that clients continue to attend to appointment and registration requirements as soon as possible.
- Access to CIMA’s REEFS portal is limited to local Cayman Islands service providers, such as the Registered Office.
- Cayman Islands: AML Compliance Officer, MLRO and DMLRO
- Notes on ‘Relevant Financial Business’
- REMINDER: 30 September Deadline for appointment of AML Officers under the Cayman Islands Anti-Money Laundering Regulations
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