CIMA has recently clarified that it expects ‘natural persons’ to be appointed to the positions of MLRO, DMLRO and AMLCO to all financial services businesses, including investment funds.
This recent clarification means that all funds will now be required to appoint natural persons in these various positions by September 30, 2018. Funds may continue to designate and rely on other persons to perform these functions, as long as the person is a named individual.
Compliance can be demonstrated by funds by the submission of the requisite information via the Authority’s REEFS portal, on or before September 30, 2018.
FTS can provide investment funds with one of the Cayman Islands most experienced compliance professionals to perform any of these roles. For further information please contact us at fundMLRO@ftscayman.com