The on-going industry consultation with the Cayman Islands
Monetary Authority (CIMA) has resulted in further
clarification in respect of the Anti-Money Laundering Regulations
(2018 Revision) (AML Regulations) and the Guidance
Notes issued in December 2017. This clarification has been
issued in the form of the Guidance Notes (Amendment) 2018
(Amendment).
The Amendment will not impact the appointments, policies and
procedures Ogier has assisted its funds clients with in connection
with the recent appointments of Anti-Money Laundering Officers for
the 30 September 2018 deadline.
The key areas of clarification provided by the Amendment are as
follows:
- An explanation of the distinction between
"reliance on" an outsourced party and
"delegation to" an outsourced party with respect to
performance of functions required under the AML Regulations. In
particular, reliance is the process by which the person relied upon
applies its own policies and procedures, upon which
