Important note on Anti-Money Laundering Compliance Officer (“AMLCO”), Money Laundering Reporting Officer (“MLRO”) and Deputy Money Laundering Reporting Officer (“DMLRO”) Roles

Background

On 13th December 2017 the Cayman Islands Monetary Authority (“CIMA”) issued their updated Guidance Notes under the new Anti-Money Laundering Regulations, 2017 (“AML Regulations”) which came into force on 2nd October 2017.
CIMA issued further clarification on 29th March, 2018 confirming that all Cayman domiciled entities carrying out relevant financial business will be required to carry out risk assessments of its activities/investments and investors, as well as appoint a named AML Compliance Officer (“AMLCO”), Money Laundering Reporting Officer (“MLRO”) and a Deputy MLRO (“DMLRO”) (together the “AML Officers”).

The deadline to appoint AML Officers is 30th September 2018

Who is Affected?
The following entities are affected and must take action by September 30th:
• Regulated Investment Funds registered with CIMA;
• Non-regulated Investment Funds including Private Equity, Private Debt, Real Estate   and Infrastructure Funds and ‘Funds of One’, both closed and open ended; and
• other entities carrying out relevant financial business potentially including entities
such as Trading Subsidiaries, SPV’s and General Partners.

Next Steps
It is important that you take action now to ensure you remain compliant when the new regulatory requirements come into force on September 30th.

Carne has 11 AMLCO and MLRO experts globally supporting funds domiciled in the Cayman Islands, as well as other jurisdictions. We  can perform essential tasks on a Fund Board’s behalf to assist the Fund in complying with the new AML Regulations.

To find out more about the optimum solution for your specific requirements, contact your Carne Client Service and Relationship Manager