The Cayman Islands Monetary Authority still requires regulated and unregulated Funds to appoint an Anti-Money Laundering Compliance Officer, Money Laundering Reporting Officer (“MLRO”) and Deputy MLRO but released a Notice on 24 September stating that the previous deadline of 30 September 2018 has been replaced with a new deadline of 31 December 2018.
It is important to note that the situation for regulated funds differs slightly to that for unregulated funds.
Regulated funds must appoint the various individuals and complete the appropriate form for each, submitting the forms via CIMA’s REEFs portal by 31 December 2018.
Unregulated funds must also appoint these individuals by 31 December 2018, but these funds do not currently have to confirm these appointments to CIMA.
Regulated financial services providers should also note that the extension of the deadline only applies to funds. Financial Services Providers should therefore have already appointed individuals to the required positions.