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ARTICLE · 09 NOVEMBER 2022

Cayman De-Listings Update – Close But No (Grey List) Cigar!

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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Hogan Lovells Cadwalader

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While neither of these lists has any material relevance in the fund finance world, it's never nice to be included on one due to the connotations that they carry.

Cayman IslandsFinance and Banking
Derek Stenson
Derek Stenson
Michael O'Connor
Michael O'Connor
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Observers of the FATF and EU's many lists will be aware that Cayman currently sits on the FATF "Grey List" in respect of increased monitoring for AML and, as a direct result of this, the EU "Black List" for AML purposes (which mimics any FATF greylisting).

While neither of these lists has any material relevance in the fund finance world, it's never nice to be included on one due to the connotations that they carry. The listings are particularly unfair to Cayman − a jurisdiction that serves almost entirely institutional-level investors and has been making tireless and constant efforts over the past decade to meet all international requests. So it had been hoped that Cayman would be removed from the FATF Grey List in October 2022 and the EU AML list thereafter.

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