Cayman Islands Update: SIBA Registered Persons

SIBA Policies and Procedures

The recent Anti-Money Laundering ("AML") Surveys undertaken by the Cayman Islands Monetary Authority ("CIMA") have once again highlighted that entities regulated by CIMA are required to have comprehensive policies and procedures in place to ensure that they are operating in compliance with the requirements of applicable Cayman Islands laws and regulations, including CIMA's rules ("Rules") and statements of guidance ("SOGs").

For entities registered or licensed with CIMA under the Securities Investment Business Act (As Revised) ("SIBA"), the applicable Rules and SOGs issued by CIMA include, among others, those on:

• AML, Countering the Financing of Terrorism, Countering Proliferation Financing and Targeted Financial Sanctions;