Walkers Partner Outlines the Steps Cayman Funds Should Take to Comply With the Requirement to Appoint AML Officers

In 2018, investment funds organized in the Cayman Islands were required to designate natural persons as anti-money laundering (AML) officers. Although private equity (PE) funds were required to comply by December 31, 2018, the industry has noticeably lagged, exposing PE sponsors to regulatory scrutiny by the Cayman Islands Monetary Authority and compromising the integrity of their AML compliance programs. In an interview with the Private Equity Law Report, Walkers partner Lucy Frew discussed the requirements in the Cayman Islands Anti-Money Laundering Regulations (2018 Revision) to designate AML officers, practical considerations for deciding whom to appoint and steps funds should take to ensure they comply with these requirements. For additional insights from Walkers attorneys, see “Annual Walkers Fundamentals Seminar Highlights Trends in Investor Sentiment, Governance, Side Letters, Fund Structures, Investment Vehicles and Restructurings” (Jan. 11, 2018). To further explore the topic of AML compliance, on Thursday, May 30, 2019, at 11:00 a.m. EDT, our sister publication, the Hedge Fund Law Report, will host a complimentary webinar discussing key components of a robust AML program. The webinar, entitled “Best Practices for Private Fund Managers’ AML Programs,” will be moderated by Kara Bingham, Senior Editor of the Hedge Fund Law Report, and will feature Frew; Seetha Ramachandran, partner at Proskauer and former Deputy Chief in the Asset Forfeiture and Money Laundering Section at the Criminal Division of the DOJ; and Sarah Curran, director at Promontory Financial Group and former member of the SEC’s Private Funds Unit. To register for the webinar, click here.

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