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ARTICLE · 17 SEPTEMBER 2026

New CIMA AML Rule And Sanctions Rule: What Regulated Funds Need To Consider

Carey Olsen
Carey Olsen
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Carey Olsen

Carey Olsen

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New CIMA Rules effective September 2026 will transform anti-money laundering and sanctions compliance for Cayman Islands investment funds, elevating previous guidance to directly enforceable requirements. Fund governing bodies face enhanced responsibilities including mandatory annual AML training, independent audit requirements, and stricter AMLCO independence standards. Understanding these practical implications and preparing appropriate compliance frameworks will be essential for funds and their service p

Cayman IslandsFinance and Banking

Key implications for Funds 

On 18 September 2026, new Rules published by the Cayman Islands Monetary Authority ("CIMA") relating to anti-money laundering ("AML") and sanctions compliance ("Rules") will come into force. CIMA has also published FAQs on its website concerning the application of the new Rules. These new Rules are not intended to significantly extend the substantive obligations in this area, but there is now greater clarity around their enforceability and the extent to which they apply to regulated investment funds ("Funds").

In particular, each Fund's governing body ("Governing Body"), whether directors, general partner or trustee (or the governing body of any of the foregoing, as applicable) should take note of the following:

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