The Cayman Islands Monetary Authority (“CIMA”) has extended the deadline for each Cayman domiciled investment fund to designate and appoint 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.
Each Cayman investment fund which launched prior to 1 June 2018 now has until 31 December 2018 to designate entity specific AML Officers (and, where the relevant fund is registered with CIMA, to register the details of such officers with CIMA). 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.
CIMA licensed or registered funds that have not registered AML Officers by the 31 December 2018 deadline may be the subject of enforcement action.