AMLCO, MLRO and DMLRO services
Experienced, Cayman-based individuals to act as your Anti-Money Laundering Compliance Officer, Money Laundering Reporting Officer or Deputy MLRO, meeting the management-level and fitness standards of CIMA's 2026 AML Rule.
What the AML Rule expects of your officers
- The AMLCO, MLRO and DMLRO must be natural persons operating at no lower than management level (AML Rule 7.1(c)–(d), 8.10).
- They must be of good repute, suitably qualified and experienced, and the entity must be able to evidence this to CIMA (8.1, 8.11).
- The AMLCO needs authority, direct access to senior management and the board, independence from the functions they oversee, and sufficient resources (8.2).
- The AMLCO reports to the board at least annually (8.8). The MLRO assesses internal SARs and files external SARs with the FRA (8.9).
CIMA's FAQs describe the qualifications it expects: an appropriate professional qualification, knowledge of the Cayman AML/CFT/CPF/TFS framework, relevant experience and good repute (FAQ 11). The function may be outsourced, but accountability stays with the entity and its board (FAQs 14, 24).
What we provide
AMLCO
Oversight of the compliance programme, board reporting, policy maintenance, service provider oversight and regulatory liaison.
MLRO and DMLRO
Receipt and assessment of internal reports, SAR decisions and filings with the FRA, and handling of consent (DAML) requests.
Every member of our team holds ACAMS certification, provided by AML Cayman Ltd., and has at least ten years of relevant financial services and AML processing experience at senior levels.
Independence: where we act as AML officer for an entity, we will not carry out its independent AML audit. CIMA says AML officers form part of the programme and cannot audit it (FAQ 39). You will need a separate independent auditor, and we will tell you so up front.
Frequently asked questions
Can one person hold more than one AML officer role?
CIMA says one individual may hold multiple AML roles where the law permits, provided conflicts are managed and they can discharge every responsibility (CIMA FAQ 15). The MLRO and DMLRO must be different people, because the DMLRO acts in the MLRO's absence (AML Rule 8.10).
Must the AMLCO be employed by the entity?
No. CIMA says the AMLCO function may be performed by an appropriately qualified individual engaged through an outsourcing arrangement. The entity keeps the accountability (CIMA FAQ 14).
If you are our AML officer, can you also audit our programme?
No. The AML officers form part of the programme and cannot audit it (CIMA FAQ 39). You will need a separate independent auditor.
Need an AMLCO, MLRO or DMLRO?
Tell us about your entity and the roles you need filled. We will reply with a proposal.