Update On EU AML List – Limited Impact For Cayman Islands

Summary

Last March we published an advisory on the Cayman Islands inclusion on the Financial Action Task Force's list of "jurisdictions under increased monitoring" (FATF Monitoring List), noting that the EU Commission maintains a list of "high-risk third countries" (EU AML List), which typically includes the countries on the FATF Monitoring List but may include others. The European Commission now proposes to update the EU AML List (see below for timing).

Proposal to update the EU AML List

On 7 January 2022, the European Commission adopted a delegated regulation proposing to update the existing EU AML List to add the Cayman Islands, along with a number of other jurisdictions. The inclusion of the Cayman Islands on the EU AML List would impact a small subset of securitisation vehicles but otherwise has no direct consequences for investors or clients using Cayman Islands structures.