Cayman Islands ML/TF National Risk Assessment Survey (2017-10-17)

Summary

This is a General Industry Notice issued by CIMA in October 2017 concerning the Cayman Islands' second Money Laundering/Terrorist Financing (ML/TF) National Risk Assessment (NRA), undertaken in preparation for the 4th Round CFATF mutual evaluation. It explains the background to the NRA process, a World Bank-assisted, multi-phase exercise run by the Anti-Money Laundering Steering Group and Anti-Money Laundering Unit, and describes five sector-specific online SurveyMonkey questionnaires designed to gather ML/TF risk data from financial institutions and designated non-financial businesses and professions (DNFBPs).

The notice is primarily informational and promotional: it explains what threats, vulnerabilities and consequences mean in the risk-assessment context, sets out the NRA's organisational structure, and provides links to the five sector surveys, along with guidance on what information respondents should gather beforehand. It also lists contact email addresses for each sector survey for further assistance.

• Sector surveys: Five sector-specific surveys are provided: banking, insurance, securities and investment, other financial, and DNFBPs.
• Preparation guidance: Respondents are advised to gather information beforehand such as staff numbers, client counts, SAR filings, and risk classifications.

Although the surveys are described as 'critical' and participation is 'strongly encouraged,' the notice does not impose a binding legal filing requirement with sanctions for non-completion; it is framed as a request for voluntary private-sector input into the national AML/CFT risk assessment ahead of the mutual evaluation. The stated survey closing date (30 March 2015) had already passed well before this notice's publication date of 17 October 2017, suggesting the document is a historical/archival notice retained on CIMA's general industry notices page rather than a currently actionable instruction.

Key obligations

• Financial institutions and DNFBPs are strongly encouraged to complete the relevant sector-specific NRA online survey honestly, completely and in a timely manner.
• Respondents should gather specified information before completing the survey (e.g., numbers of compliance and non-compliance staff, MLRO/CO experience, client counts by year, client residency/nationality data, client risk classifications, and SARs filed with the FRA).

Applies to

banks, insurance companies, insurance brokers, insurance managers, CIMA licensees and registrants under the Securities and Investment Business Law, mutual fund administrators, Cayman Islands Stock Exchange Listing Agents, money services businesses, financial leasing providers, non-bank lenders or depository institutions (credit unions, cooperative societies, short-term lenders, mortgage lenders), persons involved in money/currency changing, designated non-financial businesses and professions (real estate agents, dealers in precious metals and stones, lawyers, notaries, legal professionals and accountants, trust and company service providers)

Deadlines

• Tuesday, 30 March 2015: Stated closing date for the online NRA sector survey questionnaires (SurveyMonkey).