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Outsourced AML officers

AMLCO, MLRO and DMLRO appointments

AML officers are mandatory appointments for entities conducting relevant financial business in the Cayman Islands, and the regime expects those roles to sit with senior people who understand the business. We take the appointments ourselves rather than passing them to a junior team.

Our experience covers hedge and private equity structures, CLOs and capital markets transactions, securities investment business and banking. That means we can read a transaction, spot the risk that matters and deal with directors, administrators and authorities without needing to be walked through the basics.

Named appointments recorded with CIMA and reflected in your register
Quarterly and annual compliance reporting to your board
Suspicious activity report filing and liaison with the Financial Reporting Authority
Oversight of delegated CDD, screening and ongoing monitoring

AML policies and procedures

Drafting, review and annual refresh

A manual that repeats the regulations back to you is not much use to the person doing the onboarding. We write procedures that describe how your business actually works, then map them to the Cayman requirements so an inspector can follow the trail.

Where you already have a manual, we review it against the current regulations and guidance notes, mark up what has fallen behind and rewrite only what needs rewriting.

AML, CTF and proliferation financing procedures
Sanctions screening and escalation criteria
Entity level and institutional risk assessments
Customer risk rating methodology and CDD matrices

Compliance, regulatory and corporate governance

Ongoing advisory support

Rules change, deadlines move, and someone has to tell the board what it means for them. We act as the compliance resource for firms that do not need a full time hire, and as a second opinion for those that already have one.

We keep clients current on Cayman and international developments, including sanctions designations, prohibited lists and changes in supervisory expectations, and we translate that into what to do next.

Board and governance reporting packs
Regulatory filings, notifications and correspondence
Service provider and delegate oversight reviews
Economic substance and beneficial ownership questions

AML audit and regulatory inspections

Independent testing and remediation

The Cayman regime requires independent testing of your AML programme. We audit the programme and the controls behind it, assess whether they work in practice, and escalate what senior management needs to know rather than burying it in an appendix.

If CIMA has already been in, or a letter has already arrived, we work the findings with you: what to fix, in what order, who owns it and what evidence closes it out.

Full programme audit with sample file testing
Gap analysis ranked by regulatory risk
Mock inspection and interview preparation
Remediation plans and progress reporting to the regulator

AML and CTF training

Annual, tailored and verifiable

Staff and senior management need AML training every year, and it needs to be provable. Our material is written for the Cayman money laundering, terrorist financing and proliferation financing requirements, and updated as sanctions and advisories change.

Sessions use examples from your own business, so people leave knowing what a red flag looks like in the files they actually handle. Testing at the end gives you the record.

Board and senior management briefings
Operations, onboarding and client facing staff sessions
Attendance registers, testing results and certificates
In person in Grand Cayman or online for offshore teams

Bank regulatory and advisory

For banks and licensed institutions

Banking brings a second layer of supervision on top of the AML regime. We support licensed institutions on the prudential and regulatory side, drawing on experience of how CIMA assesses applications and how it follows up afterwards.

Licence applications and change of control submissions
Regulatory returns and prudential reporting review
Correspondent banking and de-risking questionnaires
Policy frameworks for credit, liquidity and operational risk
Scope and fees

You will know the number before we start

Audits, policy drafting and training are quoted as fixed fees against a written scope. Officer appointments and ongoing advisory work run on an annual retainer sized to the entity.

1 Scoping call and written summary of obligations at no cost
2 One engagement letter, named advisers, agreed dates
3 Any change in scope is agreed in writing before we do the work
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