Anti Money Laundering Measures in the Cayman Islands

Anti-Money Laundering

Measures in the

Cayman Islands

ANTI-MONEY LAUNDERING MEASURES IN THE CAYMAN ISLANDS

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Preface

This publication has been prepared for the assistance of those who are considering the law of the

Cayman Islands (sometimes referred to as “Cayman”) as it pertains to anti-money laundering

measures. It deals in broad terms with the requirements of Cayman law. It is not intended to be

exhaustive but merely to provide brief details and information which we hope will be of use to our

clients. We recommend that our clients and prospective clients seek legal advice on Cayman law in

respect of any specific scenarios, matters or concerns.

Conyers Dill & Pearman


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TABLE OF CONTENTS

INTRODUCTION 4 1.

THE PROCEEDS OF CRIME LAW 4 2.

THE ANTI-MONEY LAUNDERING REGULATIONS (2020 REVISION) 7 3.

THE GUIDANCE NOTES ON THE PREVENTION AND DETECTION OF MONEY 4.

LAUNDERING AND TERRORIST FINANCING IN THE CAYMAN ISLANDS 12

ANTI-CORRUPTION LAW 13 5.

ANTI-TERRORISM 13 6.

RELATED LEGISLATION 14 7.

CONCLUSION 14 8.


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INTRODUCTION 1.

The Cayman Islands is a leading international financial centre with a robust anti-money laundering

regulatory structure. Cayman’s anti-money laundering legislation has been carefully crafted and

diligently upgraded to ensure that the jurisdiction remains in compliance with the highest of international

standards. Most importantly, the highly skilled professionals in the Cayman Islands, including lawyers,

accountants, auditors and fund managers and administrators, cultivate a strong culture of compliance,

taking very seriously the negative impact (both in terms of direct and reputational damage) that

regulatory failures would bring to the jurisdiction.

The Proceeds of Crime Law (2019 Revision) (as amended) (the “PCL”) is the primary legislation in the

Cayman Islands intended to combat the activity of money laundering. The PCL reflects the “forty plus

nine” recommendations formulated by the Financial Action Task Force (“FATF”), and has as its primary

objective the development and improvement of Cayman’s legal systems and mechanisms to counter

the laundering of drug trafficking money and other criminal proceeds.

The Anti-Money Laundering Regulations (2020 Revision) (as amended) (the “Regulations”) are

promulgated under the PCL. In addition, the Cayman Islands Monetary Authority (“CIMA”) has

published Guidance Notes on the Prevention and Detection of Money Laundering and Terrorist

Financing in the Cayman Islands (as amended) (the “Guidance Notes”). The PCL, the Regulations

and the Guidance Notes combine to create a comprehensive, robust and modern anti-money

laundering, anti-terrorist financing and counter proliferation financing legislative regime.

THE PROCEEDS OF CRIME LAW 2.

The PCL creates the core money laundering offences. It also contains provisions for the making and

enforcement of confiscation orders and establishes certain investigatory and co-operative powers to

enhance enforcement efforts. The PCL strives to reflect the approach advocated by the FATF and

other international agencies concerned with the prevention and detection of money laundering. The

PCL also creates and sets out the obligations and duties of the Financial Reporting Authority, the

financial intelligence unit established in the Cayman Islands to receive, analyse and take action with

respect to reports of suspicious activities.

The Money Laundering Offences 2.1.

Under the PCL, five primary offences are defined: (a) concealing, disguising, converting, transferring or

removing from the Islands, of criminal property; (b) entering into arrangements for the facilitation of the

acquisition, retention, use or control of criminal property; (c) acquisition, possession or use of criminal

property; (d) failure to disclose a suspicion of criminal conduct; and (e) tipping off.

“Criminal conduct” is defined as conduct which constitutes an offence in Cayman or would constitute an

offence in Cayman if it occurred there. Property is “criminal property” if it constitutes a person’s benefit

from criminal conduct or it represents such a benefit (in whole or in part and whether directly or

indirectly) and the alleged offender knows or suspects that it constitutes or represents such benefit.


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Concealing or Transferring Criminal Property (a)

A person commits an offence if he conceals, disguises, converts, transfers or removes

from Cayman criminal property (as defined above). Concealing or disguising criminal

property includes concealing or disguising its nature, source, location, disposition,

movement or ownership or any rights with respect to it.

Entering into Arrangements (b)

A person commits an offence if he enters into or becomes concerned in an arrangement

which he knows or suspects facilitates the acquisition, retention, use or control of

criminal property by or on behalf of another person.

Acquisition, possession or use of proceeds of criminal conduct (c)

A person commits an offence if he acquires uses or has possession of criminal property.

For the purpose of this offence, a person acquires property for inadequate consideration

if the value of the consideration is significantly less than the value of the property; a

person uses or has possession of property for inadequate consideration if the value of

the consideration is significantly less than the value of the use or possession; and the

provision by a person of goods or services which he knows or suspects may help

another to carry out criminal conduct is not consideration.

Failure to Disclose (d)

A person commits an offence if (a) he knows or suspects, or has reasonable grounds for

knowing or suspecting, that another person is engaged in criminal conduct (b) if the

information on which the knowledge or suspicion is based came to his attention in the

course of his business in the regulated sector or other trade, profession, business or

employment; (c) he does not disclose his suspicion as required by the law to a

nominated officer or the Financial Reporting Authority as soon as is practicable; and (d)

the required disclosure is a disclosure of (i) the identity of the person who may be

involved in money laundering, if he knows it; (ii) the whereabouts of the property with

respect to which the criminal conduct is committed, as far as he knows it; and (iii) the

information or other matter in the form and manner prescribed by the Regulations.

A disclosure to a nominated officer is a disclosure which is made to a person nominated

by the alleged offender’s employer to receive disclosures and is made in the course of

the alleged offender’s employment. In deciding whether a person committed the offence

of failure to disclose, the court will consider whether the person followed any relevant

guidance issued by the Cayman Islands Monetary Authority or any other appropriate

body (a body which regulates or is representative of a trade, profession, business or

employment), and published in a manner approved by the Monetary Authority as

appropriate in its opinion to bring the guidance to the attention of persons likely to be

affected by it. A person does not commit the offence of failure to disclose if he has a

reasonable excuse for not making the required disclosure.


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Tipping Off (e)

A person commits an offence if he knows or suspects that an activity in relation to which

a disclosure is required to be made is about to take place, is taking place or has taken

place (whether or not a disclosure has been or is likely to be made in relation thereto)

and he makes a disclosure which is likely to prejudice any investigation which might be

conducted following such disclosure (whether or not such investigation is conducted).

The offence of tipping off is not made out where the accused disclosed information in

accordance with information sharing obligations under a financial group’s group-wide

programmes against money laundering and terrorist financing or the disclosure is made

in carrying out a function he has relating to the enforcement of the law.

Defences 2.2.

A person does not commit any of the offences listed above it:

he makes a disclosure to the Financial Reporting Authority or a nominated officer, but (a)

this does not apply to the person who committed or was party to the act from which the

property derives;

he intended to make a disclosure to the Financial Reporting Authority or a nominated (b)

officer but had a reasonable excuse for not doing so; or

the act he does is done carrying out a function he has relating to the enforcement of any (c)

provision of the PCL or of any other enactment relating to criminal conduct or benefit

from criminal conduct.

Nor does a person commit an offence if:

he knows, or believes on reasonable grounds, that the relevant criminal conduct – the (a)

conduct by reference to which the property concerned is criminal property – occurred in

a particular country or territory outside the Cayman Islands; and

the relevant criminal conduct: (b)

was not, at the time it occurred, unlawful under the criminal law then applying in (i)

that country or territory; and

is not of a description prescribed by an order made by the Attorney General. (ii)

A person does not commit an offence if he is a professional legal adviser and does not disclose

information or other matter which came to him in privileged circumstances unless the information or

other matter is communicated or given with the intention of furthering a criminal purpose.


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Penalties and Enforcement 2.3.

A person guilty of concealing or transferring criminal property, making arrangements with respect to

criminal property, or acquiring, using or possessing criminal property is liable on summary conviction to

a fine of five thousand dollars or imprisonment for two years or both. On conviction on indictment for

such offences, the maximum penalty is imprisonment for a term of fourteen years or an unlimited fine,

or both.

A person guilty of failing to disclose or tipping off is liable on summary conviction to a fine of five

thousand dollars or to imprisonment for a term of two years or both. On conviction on indictment for

such offences the maximum penalty is a term of five years imprisonment or an unlimited fine or both.

Where any offence is proved to have been committed with the consent or connivance of, or to be

attributable to any neglect on the part of, any director, manager, secretary, partner or other similar

officer of the body corporate or partnership, the individual as well as the body corporate or partnership

is guilty of the offence and shall be liable to be proceeded against and punished accordingly.

The PCL contains extensive and comprehensive provisions with respect to investigations into alleged

money laundering, as well as provisions pertaining to the seizure, detention, forfeiture and confiscation

of the proceeds of criminal conduct.

THE ANTI-MONEY LAUNDERING REGULATIONS (2020 REVISION) 3.

Anti-Money Laundering Compliance Officer 3.1.

The Regulations are promulgated under the PCL. The Regulations impose a requirement on any

person carrying out relevant financial business to designate a person at the managerial level as the

Anti-Money Laundering Compliance Officer (“Compliance Officer”). The Compliance Officer must

ensure that the measures set out in the Regulations are adopted by the person carrying out relevant

financial business and functions as the point of contact with competent authorities for the purpose of

the Regulations.

The PCL defines “relevant financial business” as meaning:

Banking or trust business carried on by a person who is licensed under the Banks and (a)

Trust Companies Law;

Acceptance by a building society of deposits made by any person (including the raising (b)

of money from members of the society by the issue of shares);

Business carried on by a co-operative society within the meaning of the Co-operative (c)

Societies Law;

Insurance business and the business of an insurance manager, an insurance agent, an (d)

insurance sub-agent or an insurance broker within the meaning of the Insurance Law;

Mutual fund administration or the business of a regulated mutual fund within the (e)

meaning of the Mutual Funds Law;


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The business of company management as defined by the Companies Management Law; (f)

Any of the activities set out in Schedule 6 of the PCL. (g)

Schedule 6 includes the following:

The acceptance of deposits and other repayable funds from the public; (a)

Lending; (b)

Financial leasing; (c)

Money transmission services; (d)

Issuing and managing means of payment (i.e. credit cards and debit cards, cheques, (e)

travellers’ cheques, money orders and bankers’ drafts, electronic money);

Financial guarantees and commitments; (f)

Trading in money market instruments, foreign exchange, interest rate and index (g)

instruments, transferable securities, or commodity futures trading;

Participating in securities issues and providing services related to such issues; (h)

Providing advice to undertakings on capital structure, industrial strategy and related (i)

questions, and advice and services relating to mergers and the purchase of

undertakings;

Money broking; (j)

Individual and collective portfolio management advice; (k)

Safekeeping and administration of cash or liquid securities; (l)

Safe custody services; (m)

Financial, estate agency (including real estate agency or real estate brokering), legal (n)

and accounting services provided in the course of business relating to the sale,

purchase or mortgage of land or interests in land on behalf of clients or customers;

management of client money, securities or other assets; organisation of contributions for

the creation, operation or management of companies; management of banks, savings or

securities accounts; and the creation, operation or management of legal persons or

arrangements, and buying and selling of business entities;

Undertaking property development within the meaning of section 2 of the Trade and (o)

Business Licensing Law and the subsequent sale of that property without using a real

estate agent or broker;

Undertaking property investment without using a real estate agent or broker; (p)


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The services of listing agents and broker members of the Cayman Islands Stock (q)

Exchange;

The conduct of securities investment business; (r)

Dealing in precious metals or previous stones, when engaging in a cash transaction that (s)

is equivalent to fifteen thousand United States dollars or more;

The provision of registered office services to a private trust company by a company that (t)

holds a Trust licence under the Banks and Trust Companies Law;

Otherwise investing, administering or managing funds or money on behalf of other (u)

persons;

Underwriting and placement of life insurance and other investment related insurance; (v)

Providing virtual asset services; and (w)

Operating a single family office. (x)

Systems and Training to Prevent Money Laundering 3.2.

In conducting relevant financial business, a person is required to maintain client identification and

verification procedures; adopt a risk-based approach to monitor financial activities, including categories

of activities that are considered to be high risk and the identification of assets subjected to targeted

financial sanctions; procedures to screen employees to ensure high standards when hiring; appropriate

record-keeping procedures; adequate systems to identify risk in relation to persons, countries and

activities which shall include checks against all applicable sanctions lists; adoption of risk-management

procedures concerning the conditions under which a customer may utilize the business relationship

prior to verification; observance of the list of countries, published by any competent authority, which are

non-compliant or do not sufficiently comply with the recommendations of the FATF; establish internal

reporting procedures for suspicious transactions; ensure ongoing monitoring of business relationships

or one-off transactions to prevent, counter and report money laundering, terrorist and proliferation

financing; and have in place internal controls and communication procedures which are appropriate for

the purposes of forestalling and preventing money laundering, terrorist financing and proliferation

financing. Such businesses are also required to have in place adequate training for staff on their

obligations under the law with respect to money laundering, terrorist financing, proliferation financing

and targeted financial sanctions. The Regulations describe in some detail the exact nature of these

requirements and the form that the procedures should take.

A financial group or other person carrying out relevant financial business through a similar financial

group arrangement is required to implement group-wide programmes against money laundering,

terrorist financing and proliferation financing, which are applicable, and appropriate to, all branches and

majority-owned subsidiaries of the financial group. In addition, a person carrying out relevant financial

business must ensure that foreign branches and majority-owned subsidiaries apply anti-money

laundering, counter terrorist financing and proliferation financing measures consistent with those

required in Cayman.


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Assessing and applying a risk-based approach requires taking steps appropriate to the nature and size

of the business to identify, assess, and understand money laundering, terrorist and proliferation

financing risks in relation to customers, country or geographic area in which customers operate,

products, services and transactions and delivery channels. In answering whether there is a low or high

risk of money laundering, terrorist financing or proliferation financing, in relation to a country or

geographic area, risk factors to take into account include: whether the area has been identified by

credible sources as having effective systems in place; whether the country is a low or significant level of

corruption or other criminal activity; whether the area meets the requirements for countering money

laundering, terrorist financing or proliferation financing in accordance with the latest FATF

recommendations; whether it is subject to international sanctions and has organisations designated as

supporting terrorism.

The assessment of risk of a person should be documented and kept current. A person carrying out

relevant financial business must also maintain appropriate mechanisms to provide assessment of risk

information to competent authorities and self-regulatory bodies; must implement policies, controls and

procedures to enable management and mitigation of identified risks; identify and assess money

laundering, terrorist and proliferation financing risks in relation to new product development and new

business practices; monitor and, where necessary, enhance implementation of controls; and take

enhanced customer due diligence to manage and mitigate risks where higher risks are identified.

Due Diligence 3.3.

Due diligence measures must be undertaken when establishing a business relationship; when carrying

out a one-off transaction valued in excess of ten thousand dollars; when carrying out a wire transfer,

where there is a suspicion of money laundering, terrorist or proliferation financing; or there are doubts

about the veracity or adequacy of previously obtained customer identification data.

Due diligence must be conducted on an ongoing basis on a business relationship. In this context, due

diligence includes scrutinising transactions undertaken throughout the course of the relationship to

ensure that transactions are consistent with knowledge of the customer, the customer’s business and

risk profile, and, where applicable, the customer’s source of funds; and ensuring that documents, data

or information collected is kept current and relevant to customer due diligence. Due diligence in

relation to existing customers should be carried out on the basis of materiality and risk, taking into

account whether and when previous due diligence has been undertaken and the adequacy of the data

previously obtained.

Specific due diligence obligations apply for customers that are legal persons or legal arrangements and

for customers that are beneficiaries of life insurance. Enhanced due diligence obligations apply where

a higher risk of money laundering or terrorist financing has been identified; where a customer is from a

foreign country identified as having deficiencies in its anti-money laundering, counter terrorist financing

or counter proliferation financing regime or a prevalence of corruption; in relation to correspondent

banking relationships; where the customer is a politically exposed person; in the event of any unusual

or suspicious activity, or in relation to business relationships and transactions with persons and

financial institutions, from countries identified by FATF. For more information on these and other

specific obligations, please contact us.


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Customer due diligence procedures regarding verification of the identity of a customer or an applicant

for business are not required where:

the identity of the customer or applicant for business is known to the person carrying out (a)

relevant financial business;

the person carrying out relevant financial business knows the nature and intended (b)

purpose of the business relationship or one-off transaction;

the person carrying out relevant financial business has not identified any suspicious (c)

activity; and

the customer or applicant for business is a person who is: (d)

required to comply with the systems and training provisions of the Regulations or (i)

is a majority-owned subsidiary of the relevant financial business;

a central or local government organisation, statutory body or agency of (ii)

government, in a country specified in a list published by the Anti-Money

Laundering Steering Group;

acting in the course of a business or is a majority-owned subsidiary or the (iii)

business in relation to which an overseas regulatory authority exercises

regulatory functions and is based or incorporated in, or formed under the law of,

a country with a low degree of risk of money laundering, terrorist financing and

proliferation financing;

a company that is listed on a recognised stock exchange and subject to (iv)

disclosure requirements which impose requirements to ensure adequate

transparency of beneficial ownership, or majority-owned subsidiary of such a

company; or

a person fund for a professional association, trade union or is acting on behalf of (v)

employees of an entity referred to in sub-paragraphs (i) to (iv).

An “overseas regulatory authority” means an authority which, in a country outside the Cayman Islands,

exercises a function corresponding to a statutory function of a Supervisory Authority in relation to

relevant financial business in the Cayman Islands.

Record-Keeping 3.4.

The Regulations set out specific guidelines relating to the record-keeping procedures that must be

maintained by a person carrying out relevant financial business. Customer due diligence information

and transaction records must be available without delay upon request by competent authorities.

Records must be kept for at least five years.

Additional record-keeping provisions apply in the case of insolvent persons and wire transfers.


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Disclosure Requirements 3.5.

A person carrying out relevant financial business is obliged to provide documents, statements or other

information in response to a notice requesting such from a Supervisory Authority. A Supervisory

Authority, competent authority or government body may share such information with another authority

for the purposes of assessing money laundering or terrorist financing risks or discharging a legal

function or exercising its powers.

Offences and Punishment 3.6.

Failure to comply with the requirements of the Regulations constitutes an offence punishable on

summary conviction to a fine of five hundred thousand dollars or on indictment to imprisonment for two

years and a fine. It is a defence to show that a person took all reasonable steps and exercised all due

diligence to avoid committing the offence.

Where an offence under the Regulations is committed by a company or partnership and is proved to

have been committed with the consent or connivance of, or to be attributable to any neglect on the part

of, a director, manager, secretary, partner or controlling member, such person shall be guilty of that

offence and shall be liable to be proceeded against and punished accordingly, in addition to the

company or partnership.

CIMA may also impose administrative fines for breaches of the Regulations under The Administrative

Fines Regime. Breaches are punishable with a non-discretionary or discretionary fine, depending on

the severity of the breach, and fines range from US$5,000 to US$100,000 for individuals and up to

US$1,000,000 for corporate entities.

THE GUIDANCE NOTES ON THE PREVENTION AND DETECTION OF MONEY 4.

LAUNDERING AND TERRORIST FINANCING IN THE CAYMAN ISLANDS

The Guidance Notes are promulgated and regularly revised and updated by CIMA in the exercise of

powers granted to it under the PCL. The Guidance Notes provide guidelines that should be adopted by

those engaged in financial business in the Cayman Islands. Whilst failure to comply with the Guidance

Notes is not, in itself, an offence, the failure to follow the Guidance Notes will be taken into account in

assessing whether or not an offence under the PCL has occurred or whether a relevant financial

business has taken all reasonable steps to comply with the Regulations. Failure to comply with the

Guidance Notes may also result in sanctions being applied by CIMA to the business in question, and

may be a factor in obtaining or renewing a licence from CIMA to carry on a regulated business.

It is the Guidance Notes that provide the ‘nuts and bolts’ for relevant financial businesses to follow in

carrying out their mandate under the PCL and the Regulations. It addresses in great detail the

requirements of the law as they pertain to internal systems and controls in relation to the prevention

and detection of money laundering, terrorist financing and proliferation financing. For example, the

Guidance Notes specify the form of identification that ought to be provided by applicants for business,

and the timing and content of staff training programs. The Guidance Notes offer examples, tips and

suggestions in narrative form and favours a ‘risk based approach’ to establishing internal policies,

subject to certain minimal requirements enumerated with precision in the lengthy document. Certain

industry-specific guidance is included in the Guidance Notes, as are the necessary forms for filing


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suspicious activity reports. Any of our Cayman attorneys would be pleased to advise on the aspects of

the Guidance Notes relevant to any of our clients in particular.

ANTI-CORRUPTION LAW 5.

Overview 5.1.

The Anti-Corruption Law (2019 Revision) sets out extensive local and international corruption offences

and provides for the establishment of the Anti-Corruption Commission (the “Commission”). The

Commission has broad powers to receive information regarding and investigate suspected corruption

offences. The Commission’s power includes the ability, with the consent of the Grand Court, to freeze

bank accounts and other property for up to 21 days at the request of any anti-corruption authority if it

has reasonable cause to believe that the request or information relates to the proceeds of corruption.

Offences and punishment 5.2.

The range of local offences includes bribery of public officials and members of the Legislative

Assembly, election fraud, breach of trust by public officers or members of the Legislative Assembly,

selling or purchasing public officers, influencing or negotiating appointments of dealing in public

offences, false claims by public officers, abuse of office, false certificates by public officers or members

of the Legislative Assembly, non-disclosure of conflicts of interest, failure to report offers of bribes to or

solicitations of bribes by public officials and members of the Legislative Assembly, frauds on the

government, bribing a foreign public officer, illegal secret commissions and making false statements to

the Commission. Conspiracy, attempts and incitement to commit an offence as well as aiding, abetting,

counselling and procuring the commission of an offence are also crimes.

Penalties range from fines of CI$5,000 / US$6,098 up to CI$50,000 / US$60,975 and/or two years’

imprisonment on summary conviction and fines of CI$10,000 / US$12,195 up to CI$50,000 /

US$60,975 or up to fourteen years’ imprisonment on indictment.

ANTI-TERRORISM 6.

The Terrorism Law (2018 Revision) makes it an offence to provide or receive instruction or training (or

invite others to do the same) in the making or use of firearms, explosives or chemical, biological or

nuclear weapons; direct activities of a terrorist organisation; possess an article for the purpose of

committing, preparing or instigating an act of terrorism; collect, record or possess information likely to

be useful to a person committing or preparing an act of terrorism; use, solicit or possess “terrorist

property”; and organise or participate in an act of terrorism or contribute to a group in furtherance of

terrorism. “Terrorist property” is defined as property that is the proceeds of, or used in, or intended or

allocated for use in, the financing of acts of terrorism. The offence of failing to disclose under the

Terrorism Act arises where a person has information which may be of assistance in preventing the

commission of terrorism or securing the arrest or prosecution of a person for an offence under the law,

or where a person believes or suspects that another has committed a terrorism offence, and that

knowledge or suspicion comes to his attention in the course of his trade, profession, business or

employment and the person fails to report it as soon as is reasonably practicable. Schedule 1 of the

Law also prescribes an offence where a person fails to disclose information that came to him in the

course of a business in the regulated sector.


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RELATED LEGISLATION 7.

Industry Specific Regulation 7.1.

The activities of banks and trust companies in Cayman are regulated generally by the Banks and Trust

Companies Law (2020 Revision) and the regulations promulgated thereunder. This legislation requires

that entities proposing to carry out banking or trust business be licensed by CIMA. Similarly, insurance

companies fall under the Insurance Law, 2010 (as amended), mutual funds operate under the Mutual

Funds Law (2020 Revision) and companies carrying on registered office or corporate administration

services fall under the Companies Management Law (2018 Revision). Entities licensed under these

and other similar laws operate under the oversight and regulation of CIMA and must comply with

detailed regulations and standards that reflect industry best practice. In certain respects, these

obligations overlap with and reinforce the jurisdiction’s generally applicable anti-money laundering

measures.

A detailed discussion of the regulation of these types of entities is beyond the scope of this publication.

Clients and interested persons should be aware, however, that this additional layer of regulation may

impact on anti-money laundering and compliance issues for these types of entities. Please feel free to

consult any of our Cayman attorneys for specific advice on these matters.

The Mutual Legal Assistance Treaty 7.2.

Mutual Legal Assistance Treaties allow generally for the exchange of evidence and information in

criminal and ancillary matters. The Mutual Legal Assistance Treaty of 1986 facilitates the provision, on

a reciprocal basis, of legal assistance in criminal matters between the USA and Cayman. The objective

of the treaty is to enhance the ability of law enforcement agencies to investigate, prosecute and

suppress criminal offences. Virtually identical legislation is in place in the other British Overseas

Territories in the Caribbean.

CONCLUSION 8.

As is noted on CIMA’s website, The Cayman Islands Monetary Authority has a central role in the fight

against money laundering and the preservation of financial stability. Through the prevention and

detection of money laundering, the Authority is able to assist in preserving the integrity of the Cayman

Islands financial services industry whilst protecting the interests of stakeholders and maintaining the

competitiveness of the Cayman Islands as a leading world financial centre.

In addition, the private sector of the Cayman Islands, particularly those persons engaged in the

provision of offshore legal, administration and management services, understand the need to combat,

on an international level and in a co-operative way, money laundering and terrorist financing. Persons

who would seek to use the jurisdiction to further their criminal endeavours are unwelcome in the

Cayman Islands.


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This publication should not be construed as legal advice and is not intended to be relied upon in relation to any

specific matter. It deals in broad terms only and is intended merely to provide a brief overview and give general

information.

© Conyers January 2020

Documents

Anti Money Laundering Measures in the Cayman Islands