Extension of Deadline for Cayman Islands Investment Funds

 

The Cayman Islands Monetary Authority (“CIMA”) issued a notice on 24 September 2018 advising that the deadline for the appointment and notification of Anti-Money Laundering Compliance Officers, Money Laundering Reporting Officers and Deputy Money Laundering Reporting Officers (collectively, the "AML Officers") had been extended.

To access the CIMA notice, please click on the following link - LINK TO CIMA NOTICE.

Regulated funds were still expected to have AML Officers appointed by 30 September 2018 – but the deadline for notification of these appointments to CIMA has been extended to 31 December 2018.  Unregulated funds have until 31 December 2018 to make the appointments and there is no notification or filing requirement.

To summarise:

Registered Funds

  • Must appoint AML Officers by 30 September 2018
  • The deadline for notifying CIMA of these appointments is 31 December 2018.

Unregistered Funds

  • Must appoint AML Officers by 31 December 2018
  • There is currently no notification requirement.

Regulated funds are required to complete the requisite form for each officer and submit it to CIMA via CIMA’s filing portal (REEFS) by the end of the year.  The REEFS portal is limited to local service providers, such as the Registered Office, who have completed the process to become authorized users of the portal.  

If you would like our assistance in ensuring that your fund is compliant with the Regulations, please do contact us as we are offering a fixed-fee service to our clients for the drafting of an AML & Compliance Manual for their use and reference.


This publication is for general guidance and is not intended to be a substitute for specific legal advice. Advice should be sought about specific circumstances. 

If you would like further information please contact: ​

Chris Humphries
Managing Director
Tel:(+1 345) 814 7911
chris.humphries@stuartslaw.com
 

James Smith
Senior Associate
Tel:(+1 345) 814 7932
james.smith@stuartslaw.com