The Cayman Islands Monetary Authority (CIMA) ensures that the Cayman Islands maintains its global position by introducing new legislation and sets the standard for global regulation. In doing so, we understand that it can be challenging for you to stay on top of and comply with the regulatory environment.
The increased accountability means that you need to ensure your compliance management regime is in place and robust. A practical way to achieve this is to outsource compliance functions to a service provider who can discharge your obligations efficiently and cost effectively.
Our team of specialists understands your needs and offer high quality regulatory, compliance and FATCA/CRS (AEOI) outsourcing services.
We will tailor your solution to your specific needs. Our approach is characterised by excellence, responsiveness and price transparency.
CIMA has recently stipulated that all Cayman Islands domiciled funds, whether regulated or unregulated, and other entities performing “relevant financial business” are now required to appoint a “natural person” to fulfil the roles of Anti-Money Laundering Compliance Officer, Money Laundering Reporting Officer (MLRO) and Deputy Anti-Money Laundering Reporting Officer (DMLRO). These are management level roles and the responsibility of each appointment is substantial.
Our outsourcing solutions include the following:
Anti-Money Laundering Compliance Officer
- Assess the overall integrity and effectiveness of the AML/CTF systems and controls of the Fund’s investment manager and/or administrator (as the case may be) on a regular basis
- Review and maintain the Fund’s anti-money laundering and counter terrorist financing (AML/CTF) systems, controls, policies and procedures in accordance with the Cayman Islands anti-money laundering regime
- Report periodically to the Board or operator of the Fund on AML/CTF matters
- Maintain regulatory registers, as necessary
- Respond to requests from relevant reporting and regulatory authorities
- Complete appointment documentation and agreements
Money-Laundering Reporting Officer
- Review the suspicious activity reporting policies and procedures
- Review internal and external suspicious activity reports (SARs)
- Where applicable submit SARs to the appropriate authorities
- Maintain the suspicious activity register
Deputy Money-Laundering Reporting Officer
- Assume the responsibilities of the MLRO in their absence
Fundamental compliance obligations require that you “know your client” and are able to demonstrate robust client acceptance AML/KYC policies and procedures. You may need expert advice from AML/KYC specialists and our outsourcing solutions include the following:
- Collection, review and verification of your client’s/fund investor’s KYC identification documentation
- Sanctions, anti-money laundering, PEP and adverse media screening
- Regular ongoing monitoring
- Provision of a secure e-mail drop box for your client’s/fund investor’s documentation
Automatic Exchange of Information Services
Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) for the Automatic Exchange of Information (AEOI) have had a profound impact on financial institutions. Harneys has been at the forefront of the AEOI regimes and can assist in how best to comply with your reporting responsibilities.
Our outsourcing solutions include the following
- FATCA/CRS classifications
- FATCA/CRS obligations advice
- GIIN registration
- FATCA responsible officer
- Principal point of contact
- Authorised person
- Registration and reporting requirements
We can prepare:
- FATCA / CRS board resolutions
- XML schemas
- Annual filings
Compliance Consultancy Services
Our compliance team delivers a suite of additional compliance services tailored to your individual needs, our services include:
- AML/CFT gap analysis
- Review and/or preparation of AML/CFT policies and procedures
- Regulatory inspection advice
- AML/CFT risk assessments
- AML/CFT training