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ARTICLE · 24 APRIL 2018

Cayman Islands AML Requirements

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The MLRO may be the same person as the AMLCO, so long as the individual is competent and is able to perform both roles efficiently.

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Further to our updates issued in October 2017 and February 2018, the Cayman Islands has updated and consolidated a number of its laws on the prevention of money laundering ("AML") and the countering of terrorist financing ("CTF").

The current Cayman Islands AML/ CTF legislative regime includes, amongst other things, the Proceeds of Crime Law (2018 Revision), the Anti-Money Laundering Regulations (2018 Revision) ("AML Regulations"), and the Guidance Notes on the Prevention and Detection of Money Laundering and Terrorist Financing in the Cayman Islands (the "Guidance Notes") dated December 2017.

The updated Guidance Notes have clarified that all financial services providers ("FSPs") must appoint natural persons at managerial level as follows: (i) Anti-Money Laundering Compliance Officer ("AMLCO") who would be the point of contact with the regulatory authorities; (ii) Money Laundering Reporting Officer ("MLRO") to whom suspicious activity reports must be made by

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