Cayman Islands Monetary Authority ("CIMA") AML Supervisory Visit Findings
In May 2025, CIMA published its findings from supervisory AML visits to Registered Persons ("RPs") for the period January 2022 to March 2024.
The Authority has observed an improvement in compliance by RPs since January 2022 and acknowledges the progress that RPs have made in implementing their AML/CFT policies, procedures, systems, and controls. Notably:
- Employee training and awareness programme: evidencing that their employees are aware of their regulatory obligations appropriate to their roles, including where specific to the Cayman Islands.
- Oversight of AML/CFT compliance function: demonstrating oversight of the compliance function by their Board of Directors (“Board”) or its equivalent.
- Outsourced AML/CFT compliance functions: regarding their outsourcing policies, procedures, and risk assessments.
- Assessing risks and application of a Risk-Based Approach (“RBA”): assessing risk and applying an RBA relative to their identified AML/CFT risks.
- Internal reporting: maintaining logs regarding the reporting of suspicion and declined business.
- Record keeping: evidencing that all relevant records are appropriately maintained and readily accessible to the Authority
Notwithstanding the encouraging results above, there were some instances where improvements were not seen:
- Customer Due Diligence (“CDD”) and ongoing monitoring documentation: For the period January 2022 to March 2024, 81% of the RPs inspected indicated weaknesses in their CDD and ongoing monitoring programmes. This compares to 75% for the period October 2020 to December 2021.
- Independent AML/CFT Audit Function: For the period January 2022 to March 2024, 63% of the RPs inspected indicated weaknesses in establishing and implementing an effective independent risk-based audit function. This compares to 47% for the period October 2020 to December 2021.
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