Cayman Islands FATF Compliance Association Update October 2020

The Cayman Islands' compliance with FATF recommendations and effectiveness outcomes are highlighted in the update. The mutual evaluation report, timelines for reviews, and progress made by the jurisdiction are detailed. Enhanced collaboration, risk assessments, and actions taken to combat money laundering and terrorist financing are emphasized in the report.

• Cayman Islands
• FATF
• Compliance
• Association
• Update

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1. Cayman Islands Compliance Association FATF update, October 2020

2. Two parallel processes Technical Compliance 40 recommendations Effectiveness 11 immediate outcomes CFATF: Enhanced follow up: Technical compliance and effectiveness FATF: Observation period: Effectiveness

3. The Timeline Mutual Evaluation Report published: March 2019 End of observation period: October 2020 30thNovember to 4thDecember 2020: Virtual CFATF Plenary November 2020: Post Observation Period Report to the Joint Group of Americas December 2020 / January 2021: Joint Group face-to-face meeting February 2021: FATF Plenary decision

4. FATF PLENARY February 2021 JG presents POPR to the next FATF ICRG meeting June 2020 (with an action plan if after their analysis of the Big 6 if rated NC / PC and progress in each IO rated low or moderate the Cayman Islands do not make sufficient progress) Cayman Islands does not provide high level political statement it goes to the Public Statement FATF ICRG determines that Cayman Islands HAS MADE ENOUGH PROGRESS. FATF ICRG determines that jurisdiction HAS NOT MADE ENOUGH PROGRESS. Cayman Islands provides High level political commitment it goes to the Compliance document The jurisdiction is monitored by the CFATF only for the MER follow-up process. JG monitors progress and makes recommendations to the FATF ICRG (updates provided at every FATF Plenary)

5. Progress made by the Cayman Islands 63 Recommended Actions Sufficient Progress, positive and tangible The Cayman Islands has made significant progress in all areas: Enhanced Domestic Collaboration Understanding of Risk Enhancing Law Enforcement Targeted Financial Sanctions Supervision of Financial Institutions, TCSPs, DNFBPs and NPOs Transparency of legal persons and arrangements Outreach

6. Enhanced Domestic Collaboration

7. Increasing the Understanding of ML / TF / PF Risks via Risk Assessments Terrorist Financing SIBL EPs Special Economic Zone NPOs Legal Persons and Arrangements key findings Proliferation Financing Threat Assessment The Cayman Islands as an International Financial Centre Consequential actions https://amlu.gov.ky/wp-content/uploads/2020/03/consequential-risk-actions- final-march-13.pdf (Also note sectoral risk assessments)

8. Enhancing Law Enforcement The Cayman Islands Bureau of Financial Investigations Stand alone ML, foreign predicate and TF Removing the Benefit from Crime and Outgoing International Requests Guidance on SARs Strategic analysis Customs and Border Control - ability to identify individuals seeking to move cash and BNIs across borders Human and IT resources and training

9. Targeted Financial Sanctions FRA dissemination FRA website sanctions notifications CIMA notifications Outreach and training, Quick Guide to Targeted Financial Sanctions

10. Supervision of Financial Institutions and TCSPs Establishment of AML Division at CIMA SIBL EPs abolished - Registered Persons are supervised Risk rating technology VASPs Guidance notes: Proliferation Financing Targeted Financial Sanctions Ongoing Monitoring Risk Based Approach Virtual Asset Services Providers

11. Supervision of Designated Non-Financial Businesses and Professionals Lawyers Accountants Dealers in Precious metals and stones Real estate agents Property Developers

12. Supervision of Non-Profit Organizations 502 registered NPOs in June 2020 Targeted risk based supervisory methodology Onsite inspections Guidance and outreach

13. Transparency of Legal Persons and Arrangements Information which is publically available Directors, Alternate Directors Authorised share capital, initial subscribers BO enforcement manual Trustees Duty to keep records Duty to disclose Power to request information

14. Outreach It s everyone s business E-learning platform AMLSG Outreach Sub-Committee AMLU website

15. COVID-19 adaptation FATF guidance The Financial Reporting Authority implemented the necessary safeguards to allow the filing of SARs via email Since mid-March 2020, CIMA has deployed remote, virtual and video technology to conduct inspections CARA remote inspections CIMA, CARA, CIBFI advisories Compliance and awareness Virtual court hearings Recruitment, outreach, Stakeholders Forum

16. Industry engagement and assistance The achievements of the jurisdiction The use of risk assessments E-learning platform, attendance at outreach, feedback Targeted Financial Sanction notifications AMLU website: www.amlu.gov.ky

17. The Outcome Strengthen the Cayman Islands AML / CFT / CPF regime Deter and prevent criminals from utilizing the jurisdiction Improve the international reputation of the Cayman Islands

18. CONTACT US Anti-Money Laundering Unit, Attorney General s Chambers Phone: 345 949 7900 | Fax: 345 949 7183 | www.amlu.gov.ky