Anti-Money Laundering 
     Measures in the 
     Cayman Islands 
      
                                       ANTI-MONEY LAUNDERING MEASURES IN THE CAYMAN ISLANDS 
       Preface 
       This publication has been prepared for the assistance of those who are considering the law of the 
       Cayman  Islands  (sometimes  referred  to  as  “Cayman”)  as  it  pertains  to  anti-money  laundering 
       measures.  It deals in broad terms with the requirements of Cayman law.  It is not intended to be 
       exhaustive but merely to provide brief details and information which we hope will be of use to our 
       clients.  We recommend that our clients and prospective clients seek legal advice on Cayman law in 
       respect of any specific scenarios, matters or concerns. 
       Conyers Dill & Pearman             
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                                              ANTI-MONEY LAUNDERING MEASURES IN THE CAYMAN ISLANDS 
         TABLE OF CONTENTS 
         1.   INTRODUCTION                                                         4 
              THE PROCEEDS OF CRIME LAW                                            4 
         2.
         3.   THE ANTI-MONEY LAUNDERING REGULATIONS (2020 REVISION)                7 
         4.   THE GUIDANCE NOTES ON THE PREVENTION AND DETECTION OF MONEY 
              LAUNDERING AND TERRORIST FINANCING IN THE CAYMAN ISLANDS             12 
         5.   ANTI-CORRUPTION LAW                                                  13 
         6.   ANTI-TERRORISM                                                       13 
         7.   RELATED LEGISLATION                                                  14 
         8.   CONCLUSION                                                           14 
          
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                                                                        ANTI-MONEY LAUNDERING MEASURES IN THE CAYMAN ISLANDS 
             1.       INTRODUCTION  
             The Cayman Islands is a leading international financial centre with a robust anti-money laundering 
             regulatory  structure.    Cayman’s  anti-money  laundering  legislation  has  been  carefully  crafted  and 
             diligently upgraded to ensure that the jurisdiction remains in compliance with the highest of international 
             standards.  Most importantly, the highly skilled professionals in the Cayman Islands, including lawyers, 
             accountants, auditors and fund managers and administrators, cultivate a strong culture of compliance, 
             taking  very  seriously  the  negative  impact  (both  in  terms  of  direct  and  reputational  damage)  that 
             regulatory failures would bring to the jurisdiction. 
             The Proceeds of Crime Law (2019 Revision) (as amended) (the “PCL”) is the primary legislation in the 
             Cayman Islands intended to combat the activity of money laundering.  The PCL reflects the “forty plus 
             nine” recommendations formulated by the Financial Action Task Force (“FATF”), and has as its primary 
             objective the development and improvement of Cayman’s legal systems and mechanisms to counter 
             the laundering of drug trafficking money and other criminal proceeds.  
             The  Anti-Money  Laundering  Regulations  (2020  Revision)  (as  amended)  (the  “Regulations”)  are 
             promulgated  under  the  PCL.    In  addition,  the  Cayman  Islands  Monetary  Authority  (“CIMA”)  has 
             published  Guidance  Notes  on  the  Prevention  and  Detection  of  Money  Laundering  and  Terrorist 
             Financing in the Cayman Islands (as amended) (the “Guidance Notes”).  The PCL, the Regulations 
             and  the  Guidance  Notes  combine  to  create  a  comprehensive,  robust  and  modern  anti-money 
             laundering, anti-terrorist financing and counter proliferation financing legislative regime.  
             2.       THE PROCEEDS OF CRIME LAW 
             The PCL creates the core money laundering offences.  It also contains provisions for the making and 
             enforcement of confiscation orders and establishes certain investigatory and co-operative powers to 
             enhance enforcement efforts.  The PCL strives to reflect the approach advocated by the FATF and 
             other international agencies concerned with the prevention and detection of money laundering.  The 
             PCL also creates and sets out the obligations and duties of the Financial Reporting Authority, the 
             financial intelligence unit established in the Cayman Islands to receive, analyse and take action with 
             respect to reports of suspicious activities.   
             2.1.     The Money Laundering Offences 
             Under the PCL, five primary offences are defined: (a) concealing, disguising, converting, transferring or 
             removing from the Islands, of criminal property; (b) entering into arrangements for the facilitation of the 
             acquisition, retention, use or control of criminal property; (c) acquisition, possession or use of criminal 
             property; (d) failure to disclose a suspicion of criminal conduct; and (e) tipping off. 
             “Criminal conduct” is defined as conduct which constitutes an offence in Cayman or would constitute an 
             offence in Cayman if it occurred there.  Property is “criminal property” if it constitutes a person’s benefit 
             from  criminal  conduct  or  it  represents  such  a  benefit  (in  whole  or  in  part  and  whether  directly  or 
             indirectly) and the alleged offender knows or suspects that it constitutes or represents such benefit. 
              
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