Who Is Required To Undertake Cayman AML Training?

Supervisors, managers and senior management (including Directors) of Financial Service Providers (“FSPs”) (including Funds and SIBL-Registered Persons) operating in the Cayman Islands are required to understand Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) and obtain Cayman Islands specific training regularly.

Cayman AML training requirements

Part II, Section 5 (d) of the Anti-Money Laundering Regulations (2020 Revision) (“AMLR”) states that:
“a person carrying out relevant financial business shall not, in the course of the relevant financial business carried out by the person in or from the Islands, form a business relationship, or carry out a one-off transaction, with or for another person unless that person provides employees from time to time with training in the recognition and treatment of transactions carried out by, or on behalf of, any person who is, or appears to be, engaged in money laundering, terrorist financing or proliferation financing, or whose assets are subject to targeted financial sanctions applicable in the Islands”

Guidance notes on the prevention & detection of money laundering

The Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the Cayman Islands (2020 Revision) (“GNs”) add clarity to the above requirements of the AMLR.

Part II, Section 10. E. of the GNs provides that:
“Although Directors and Senior Managers may not be involved in the day‐to-day procedures for handling transactions that may relate to ML/TF, it is important that they understand the statutory duties placed upon them, their staff and the firm itself given that these individuals are involved in approving AML/CFT policies and procedures.

Supervisors, managers and senior management (including Board of Directors) should receive a higher level of training covering all aspects of AML/CFT procedures, including the offences and penalties arising from the relevant primary legislation for non‐reporting or for assisting money launderers, the procedures relating to dealing with production and restraint orders and the requirements for verification of identity and retention of records.”

THE WAYSTONE SOLUTION

At Waystone (formerly DMS), we have developed an online, self-administered AML/CFT compliance training specifically designed for FSPs conducting relevant financial business within the Cayman Islands. This online compliance training has been developed by highly qualified and experienced AML compliance specialists and provides a comprehensive overview of regulatory requirements in an easy-to-follow format and covers the following areas:

• Anti-Money Laundering;
• Combating of Terrorist Financing;
• Proliferation Financing;
• Customer Due Diligence and Know Your Customer Requirements; and
• Customer and Transaction Screening

This training will take approximately 40 minutes to complete.

Should you have any questions regarding the training please reach out to our Cayman Fund Governance Solutions team today.