Financial Crime World

New Consolidated Anti-Money Laundering Regulations in Cayman Islands: Key Amendments and Implications

The Cayman Islands Government published an updated version of the Anti-Money Laundering Regulations (AMLR) in January 2023, consolidating various amendments made throughout 2020. The regulatory changes impact persons carrying out relevant financial business (RFB) in the Cayman Islands. This article outlines some of the essential amendments consolidated in the new revision.

Essential Amendments in the 2023 Revision

  1. Elimination of Equivalent Jurisdictions List :

    • Previously, the AMLR allowed RFB businesses to rely on the AMLSG’s Equivalent Jurisdictions List to simplify due diligence in lower-risk cases.
    • In the 2023 Revision, this list is removed, and RFB entities must now assess money laundering and terrorist financing risks of each country or geographic area individually.

  2. Enhanced Country Risk Assessments

    • The 2020 amendments introduced mandatory requirements for risk assessments regarding money laundering, terrorist financing, proliferation financing, corruption, and other criminal activities.
    • These assessments must be based on credible sources and must not overlook any specified risk factor.

  3. Virtual Assets Transfers

    • Starting from July 1, 2022, AMLR mandatory requirements for identification and record-keeping have extended to virtual assets transfers.
    • These regulations include collecting specified details about originators and beneficiaries in virtual asset transactions.

  4. Additional Amendments

    • The 2023 Revision contains other amendments, such as:
      • Additional prescribed content requirements for eligible introducer assurance letters
      • An expanded definition of “family member” (in the context of Politically Exposed Persons (PEPs)), which now includes civil partners.

Ogier’s Regulatory team, a leading provider of regulatory consulting services in the Cayman Islands, can help businesses navigate these changes by offering expert advice on the legal requirements’ operational implementation. For more information, please reach out to the authors or contact your usual Ogier representative.