AML/CFT Reporting Forms for VASPs (2020-12-03)

Summary

This is a Supervisory Information Circular issued by the Cayman Islands Monetary Authority (CIMA) on 3 December 2020, following the launch of the Virtual Asset (Service Providers) Law, 2020 regime on 31 October 2020. It announces a new AML/CFT reporting form -- the 'AML/CFT Inherent Risks – Virtual Asset Service Provider' form (AIR 157-84) -- that must be completed by entities that are engaged in, or wish to engage in, virtual asset services. The requirement applies both to new applicants and to entities already licensed or registered with CIMA for other regulated activities who also carry on virtual asset services.

• Submission method: The form is submitted through CIMA's REEFS online portal.
• New applicants: For new applicants, the form is packaged together with the VASP registration form (APP-101-84); the AML/CFT form becomes accessible via a link after the registration form is successfully submitted.
• Guidance: Guidance Notes for completing the form are separately available on CIMA's website.
• Deadline: The circular sets a hard filing deadline of 31 January 2021, expressly stating that no extensions will be granted.
• Legal basis: The filing requirement is grounded in regulation 53(A) of the Anti-Money Laundering Regulations (2020 Revision), which obliges relevant entities to produce information CIMA requires for its supervisory functions; the circular reminds affected entities of this ongoing obligation.

Key obligations

• Entities engaged in, or wishing to engage in, virtual asset services must complete and file the AML/CFT Inherent Risks – Virtual Asset Service Provider form (AIR 157-84) via CIMA's REEFS platform on or before 31 January 2021, with no extensions available.
• This filing obligation also applies to entities already licensed or registered with CIMA for another regulated activity that also engage in or wish to engage in virtual asset services.
• New applicants must submit the registration form APP-101-84 first, after which the AML/CFT form becomes accessible via a link for completion.
• Entities must, pursuant to regulation 53(A) of the AMLRs, produce such information as CIMA may require in connection with the exercise of its supervisory functions.

Applies to

virtual asset service providers, entities engaged in or wishing to engage in virtual asset services, entities licensed or registered with the Authority for other activities that also engage in virtual asset services

Deadlines

• 31 January 2021: Deadline to complete and file the AML/CFT Inherent Risks – Virtual Asset Service Provider form (AIR 157-84) via REEFS; no extensions will be considered.