Background
On 19 March 2019, the Caribbean Financial Action Task Force
("CFATF") issued its latest assessment
of the Cayman Islands' AML/CTF/CFP regime1 (the
"March Report"). The assessment
evaluated technical compliance (i.e. having legislation in place)
but also, for the first time for the Cayman Islands, evaluated the
effectiveness of Cayman Islands legislation.
Whilst the March Report acknowledged the Cayman Islands'
high level of commitment to ensure that the AML/CTF framework is
robust and capable of safeguarding the integrity of the
jurisdiction's financial sector, it also identified gaps in the
legislative framework regarding: availability and accuracy of
information; interagency coordination and cooperation;
international cooperation; and monitoring and enforcement, and
provided recommendations on how the regime could be
strengthened.