CIMA Issues Amendments To The AML Guidance Notes

The Cayman Islands Monetary Authority ("CIMA") has released updated Guidance Notes on the Prevention and Detection of Money Laundering and Terrorist Financing in the Cayman Islands (the "Guidance Notes"). 

The principal effect of the update is to bring the Guidance Notes into line both with various CIMA notices and FAQs released since the last iteration of full guidance (released in December 2017), and to resolve certain apparent ambiguities with regard to the Anti-Money Laundering Regulations (2018 Revision) (the "Regulations") and the December 2017 version of the Guidance Notes. 

In particular, in the service provider context, the Guidance Notes now articulate the difference between "delegation" and "reliance", where "delegation" represents an arrangement where the delegate applies the policies and procedures of the principal (i.e. the fund or other financial services provider) (the "Principal") and "reliance" represents an arrangement where the person upon