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Recent changes to the Cayman Islands Monetary Authority (“CIMA”) Guidance Notes on the Prevention and Detection of Money Laundering and Terrorist Financing in the Cayman Islands mean that CIMA regulated funds are now required to appoint a Compliance Officer as well as a Money Laundering Reporting Officer.
Accordingly, regulated funds may wish to consider undertaking an administrative/legal audit of their present AML/CFT programme to ensure that they have appropriate systems and expertise in place to support the Compliance Officer role. Each fund should appoint a Compliance Officer by resolution (or other appropriate executive action) and ensure that their role is clearly defined therein and in the AML/CFT procedures of the fund.
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Cayman Islands Anti-Money Laundering Update