CIMA Requires AML Audits Of SIBL Excluded Persons

As clients of this firm will be aware from our previous communications and updates, all persons registered with the Cayman Islands Monetary Authority ("CIMA") as "Excluded Persons" under the Securities Investment Business Law (2015 Revision) ("SIBL") are regarded as carrying on "securities investment business", and therefore remain within the scope of the Cayman Islands Anti-Money Laundering Regulations (the "AML Regulations") and must continue to ensure that they comply with the requirements of the AML Regulations. 

CIMA has recently contacted certain persons registered as Excluded Persons under SIBL requiring them to obtain and provide an audit report (the "Report") on the entity's AML procedures and compliance with the AML Regulations.