Snapshot: Cayman Islands Anti-Money Laundering Regulations (2023 Revision)

Law FirmOgier
Subject MatterGovernment, Public Sector, Terrorism, Homeland Security & Defence, Money Laundering
AuthorMegan Mcluskie, Joanne Huckle and Martin Byers
Published date22 March 2023

A revised version of the Cayman Islands Anti-Money Laundering Regulations (AMLR) was published in January 2023, which consolidates three sets of prior amendments to the AMLR that were made further to their publication throughout 2020, namely:

  • the Anti-Money Laundering (Amendment) Regulations, 2020
  • the Anti-Money Laundering (Amendment) (No. 2) Regulations 2020
  • the Anti-Money Laundering (Amendment) (No. 3) Regulations 2020

Prior to this consolidation of the AMLR (2023 Revision), persons carrying on relevant financial business in the Cayman Islands will have had to refer to each of the above discrete amendment regulations in order to interpret certain regulatory requirements applicable under the AMLR. The 2023 Revision now consolidates all amendments made to the AMLR to date into one document.

In this snapshot, we recap some of the key amendments that were made to the AMLR throughout the course of 2020 and which have now been consolidated in the 2023 Revision.

Key amendments consolidated in the 2023 Revision

1. Removal of the Anti-Money Laundering Steering Group (AMLSG) list of countries

The AMLR were amended, in 2020, so that persons carrying on 'relevant financial business' as defined under the Proceeds of Crime Act (Revised) (RFB) could no longer rely on the list of countries deemed to have an equivalent anti-money laundering (AML) regime to the Cayman Islands (Equivalent Jurisdictions List) as published by the AMLSG.

Instead, persons carrying on RFB must conduct their own risk assessment of each country or geographic area in which their customers or applicants for business reside or operate. The effect of this is that persons carrying on RFB can no longer rely by default on the Equivalent Jurisdictions List for the purposes of carrying out simplified due diligence or other actions permitted (under the AMLR) in instances where a low risk of money laundering or terrorist financing exists.

2. Requirements for country risk assessments

Specific requirements for assessing the risk of money laundering or terrorist financing...

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