Deadline for Notifying CIMA of the Appointment of AML Officers to Cayman Investment Funds Launched Prior to 1 June 2018 has been extended to 31 December 2018.

The Cayman Islands Monetary Authority (“CIMA”) has extended the deadline for each CIMA registered Cayman domiciled investment fund which launched prior to 1 June 2018 to notify CIMA of the appointment of natural persons to act as its Anti-Money Laundering Compliance Officer (“AMLCO”), Money Laundering Reporting Officer (“MLRO”) and Deputy Money Laundering Reporting Officer (“DMLRO”) from 30 September 2018 to 31 December 2018. CIMA has clarified that CIMA regulated funds must still appoint these AML Officers by 30 September 2018 but now have until 31 December 2018 to notify CIMA of such appointments. Notification of the appointment of AML Officers to CIMA registered funds must take place via the CIMA REEFS portal.

CIMA has also clarified that each unregulated Cayman investment fund (and is therefore not registered with CIMA) which launched prior to 1 June 2018 now has until 31 December 2018 to designate entity specific AML Officers. Each Cayman investment fund launched from 1 June 2018 (“Post May 2018 Funds”) are expected to have AML Officers designated from the time of launch. Post May 2018 Funds which are required to register with CIMA will be required to register details of their AML Officers at the time of the fund’s registration with CIMA.

For specific advice on the appointment of AML Officers to your Cayman Islands’ investment funds, please contact any of:

E: gary.smith@loebsmith.com
E: vivian.huang@loebsmith.com
E ramona.tudorancea@loebsmith.com
E elizabeth.kenny@loebsmith.com