Practical notes on CIMA's AML Rule and Sanctions Rule, independent AML audits and FRA reporting for Cayman funds and regulated entities.
CIMA's FAQs suggest every 2, 3 or 4 years for higher, medium and low risk. How to set, document and defend your AML audit frequency.
Read the article: How often must a Cayman entity have an AML audit?Internal audit, external auditors or independent consultants, but never your AMLCO, MLRO or DMLRO. CIMA's independence tests explained.
Read the article: Who can perform an AML audit in the Cayman Islands?AML Rule 12.2(d) requires filing as soon as practically possible after the audit. What the report should contain and what happens next.
Read the article: Filing your AML audit report with CIMAHow the POCA consent regime affects SAR filings: DAML requests, the 7-working-day notice period, deemed consent and the 30-day moratorium.
Read the article: The Cayman FRA consent regime (DAML): a guide for financial services providersSection-by-section summary of the Rule on an Effective Compliance Programme.
Screening, re-screening without delay, freezing, CRF reporting and training.
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