Please be advised of the CIMA extension to the notification deadline for funds as follows:
Regulated Funds
- These funds are still required to formally appoint AML Officers by 30 September 2018.
- The required submission of this information via CIMA's online Regulatory Enhanced Electronic Forms Submission ("REEFS") portal has been extended until 31 December 2018.
Unregulated Funds
- The deadline to formally appoint AML Officers has been extended to 31 December 2018.
- There is currently no system in place for submitting this information to CIMA.
We understand that CIMA has intentionally differentiated between regulated and unregulated funds, given the industry attention to date has been on regulated funds due to their REEFS notification requirements.
Following issuance of the CIMA AML/CFT Guidance Notes in December 2017, DMS Compliance Services have consistently and accurately advised on the requirement for all Cayman domiciled funds (regulated and unregulated) and Cayman domiciled fund managers to appoint natural persons who are suitably qualified and experienced as AML Compliance Officer ("AMLCO"), Money Laundering Reporting Officer ("MLRO") and as Deputy MLRO ("DMLRO") Learn more.
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