What are the Requirements for AML in Cayman?

The Cayman Islands anti-money laundering and countering terrorist financing (AML) regime requires mutual funds to maintain AML procedures as appropriate to the size of the fund.

The requirements include: 

• Adoption of a risk-based approach to monitoring investors and financial activities, together with adequate systems to identify risk (including checks against all applicable sanctions lists) in relation to persons, countries, and activities of the mutual fund; 
• Observance of the list of countries that are non-compliant, or do not sufficiently comply, with the recommendations of the Financial Action Task Force; 
• Procedures for: 
  • investor identification and verification 
  • risk-management;
    record-keeping; 
  • suspicious activity reporting;
    monitoring, and testing the systems for, compliance with AML and proliferation financing regulatory requirements; and 
  • Other internal control and communication procedures (eg a risk-based independent audit function)