AML Notification – Extension of the Notification Deadline for Funds (2018-09-25)

Summary

This is a short notice from CIMA announcing that the deadline for regulated funds to notify the Authority of their appointed Anti-Money Laundering Compliance Officer (AMLCO), Money Laundering Reporting Officer (MLRO) and Deputy MLRO has been pushed back to December 31, 2018. Regulated funds must complete the relevant appointment forms and submit them through CIMA's REEFS portal by that date.

• Regulated funds: Must complete the relevant appointment forms and submit them through CIMA's REEFS portal by December 31, 2018.
• Unregulated funds: Remain subject to the underlying obligation to appoint these AML Officers and should have such appointments in place by the same December 31, 2018 date, even though they are not currently required to formally confirm the appointments to CIMA.

Finally, the notice mentions that CIMA is still reviewing feedback from its consultation on the Guidance Notes on the Prevention and Detection of Money Laundering and will issue amendments in due course, so further AML-related changes may follow.

Key obligations

• Regulated funds must complete the requisite form for each appointed AML Compliance Officer, MLRO and Deputy MLRO and submit it via CIMA's REEFS portal by December 31, 2018.
• Unregulated funds must have AML Compliance Officer, MLRO and Deputy MLRO appointments in place by December 31, 2018, although they are not currently required to confirm these appointments to CIMA.

Applies to

regulated funds, unregulated funds

Deadlines

• December 31, 2018: Extended deadline for regulated funds to submit AML Officer (AMLCO, MLRO, Deputy MLRO) appointment forms via the REEFS portal.
• December 31, 2018: Deadline by which unregulated funds should have AML Officer appointments in place (no confirmation to CIMA currently required).