Following recent changes to the Cayman Islands anti-money laundering (“AML”) regulations, Cayman Islands funds are required to take certain actions by September 30, 2018 in order to be in compliance with the AML regime. Any person who violates the AML regulations could be liable for such non-compliance and required to pay a fine to the Cayman Islands Monetary Authority (“CIMA”).

CIMA now requires all Cayman funds (whether registered with CIMA or not, and regardless of where their administrator is located) to appoint named individuals to serve as a fund’s Money Laundering Reporting Officer (“MLRO”), Deputy Money Laundering Reporting Officer (“DMLRO”) and AML Compliance Officer (“AMLCO”). Different natural persons must serve as MLRO and DMLRO, however, the same natural person may serve as both the AMLCO and MLRO.

CIMA has provided existing funds until September 30, 2018 to make these appointments and related adjustments to its AML policies and procedures and fund offering documents. Any Cayman fund launching before September 30, 2018 will be required to have such appointments in place at the time that it commences its activities.