FATF: CAYMAN ISLANDS SECOND FOLLOW-UP REPORT

On 9 March, FATF published this report from the relevant FATF-style regional body, CFATF.  This follow-up report looks at the actions Cayman Islands has undertaken to address the weaknesses identified in the report and to meet the requirements of FATF Recommendations that have changed since their 2019 mutual evaluation.  The Cayman Islands has been re-rated on several Recommendations, but will remain in enhanced follow-up and will continue to report back to the CFATF on progress to strengthen its implementation of AML/CFT measures.  Regular follow-up is the default monitoring mechanism for all countries. Enhanced follow-up is based on the CFATF’s policy that deals with members with significant deficiencies (for technical compliance and/or effectiveness) in their AML/CFT systems and involves a more intensive process of follow-up.  It should be noted that, as is normal, the report does not address the progress that Cayman Islands may have made to improve its effectiveness.  The Cayman Islands has made progress to address the technical compliance deficiencies identified in the MER and requested a re-rating (including in respect of revised Recommendations) in relation to 16 Recommendations.  As a result of this progress, the Cayman Islands has been re-rated on 16 Recommendations – 1, 2, 15, 18, 21, 22, 23, 24, 25, 26, 28, 29, 32, 34, and 35.  However, it has been downgraded on Recommendation 15 from LC to PC for failing to meet the requirements of the revised Recommendation, primarily due to non-commencement of the new VASP Law.  It is concluded that the Cayman Islands will remain in enhanced follow-up on the basis that it had a low or moderate level of effectiveness for 7 or more of the 11 effectiveness outcomes (which, as mentioned above, are not assessed or affected by this assessment of technical compliance)).  Under this enhanced follow-up process, Cayman Islands will continue to report back to the CFATF on progress to strengthen its implementation of AML/CFT measures.

https://www.fatf-gafi.org/media/fatf/documents/reports/fur/CFATF-2nd-Follow-Up-Report-Cayman-Islands.pdf

I would be grateful for any modest contribution for my time and ongoing costs of computer, relocation, and (still ongoing) removal costs, I have a page, where contributions start as low as $3, at https://www.buymeacoffee.com/KoIvM842y

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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