Cayman Islands And The EU AML High-Risk Third Countries List

On 7 January 2022, the European Commission adopted a draft Delegated Regulation (the "Draft Regulation") updating its list of 'high-risk third countries' ("EU AML List") identified as having strategic deficiencies in their anti-money laundering/counter-terrorist financing ("AML/CFT") regimes¹.

The Draft Regulation proposes to add nine countries, (including the Cayman Islands) and to remove five countries from the EU AML List². It will be submitted to the Council of the EU and the Parliament for approval. If neither objects, it will be published in the Official Journal of the EU and will enter into force 20 days after publication.

This update briefly analyses the practical consequences of the Cayman Islands' potential addition to the EU AML List for clients using Cayman Islands vehicles.