CIMA Guidance on The Appointment, Duties, and Responsibilities of Anti-Money Laundering Officers

      The Cayman Islands Monetary Authority recently issued a reminder regarding the duties and responsibilities of Anti-Money Laundering Compliance Officers (“AMLCOs”), Money Laundering Reporting Officers (“MLROs”) and their Deputies (collectively, “AML Officers”) as set out in the Anti-Money Laundering Regulations (2020 Revision). Among other things, like the base-level qualifications for AML Officers (e.g., management level, natural person, autonomous and with access to relevant information, etc.), CIMA reiterated that:

      1. AML Officers must be able to dedicate sufficient time for the efficient and effective discharge of their respective functions. Where an AML Officer has other professional roles and responsibilities, these should not compromise their independence or ability to carry out their AML functions;

      2. AML Officers must be versed in the different types of transactions that the business conducts which may give rise to opportunities for money-laundering, terrorist financing, proliferation financing and any direct or indirect activity with designated person or entities; and

      3. Where the AML Officer function is outsourced, the Licensee or Registrant retains ultimate responsibility for compliance with the AML Regulations and must maintain adequate policies and procedures.

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