Over the course of the last year, amendments to the Cayman
Islands' Proceeds of Crime Law (2018 Revision) and Anti-Money
Laundering Regulations (2018 Revision) have grabbed the attention
of financial services stakeholders and, once again, thrust
regulatory compliance into the spotlight.
The amendments to the Cayman Islands' anti-money laundering
and countering the financing of terrorism (AML/CFT) regime have
generally made explicit what was previously implicit, and were
largely designed to bring the letter of the Cayman Islands'
regime into line with the Financial Action Task Force (FATF)
recommendations.
While much attention has been given to the extension of the
application of the AML/CFT framework to all "relevant
financial businesses", and in particular to entities that
conduct the business of "investing, administering or managing
funds or money on behalf of other persons" or "investment
related insurance" in or from the Cayman Islands, and to the
requirement