Cayman Islands Monetary Authority Fines Blacktower Financial Management (International) Limited CI$230,038.72 (2025-09-29)

Summary

This is an enforcement notice announcing that CIMA has imposed discretionary administrative fines totalling CI$230,038.72 on Blacktower Financial Management (International) Limited under sections 42A and 42B of the Monetary Authority Act and the Monetary Authority (Administrative Fines) Regulations. The fines relate to breaches of the Anti-Money Laundering Regulations and the Securities Investment Business (Conduct of Business) Regulations 2003, identified through an onsite inspection.

• Record keeping failure: Did not maintain records of transaction monitoring analysis results for at least 5 years after termination of the business relationship, contrary to Regulation 31(1)(b) of the AMLRs.
• Transaction monitoring failure: Failed to maintain a transaction monitoring system, contrary to Regulation 5(a)(ix) of the AMLRs and Rule 4.1 of the Rule on Internal Controls, 2007.
• Enhanced due diligence failure: Failed to perform enhanced due diligence in instances of unusual or suspicious activity, contrary to Regulation 17 and Regulation 27(f) of the AMLRs.
• Client disclosure failure: Failed to provide clients with sufficient and timely disclosure of matters necessary for informed decisions on securities investment business, contrary to the Securities Investment Business (Conduct of Business) Regulations 2003.

The notice is informational, confirming a completed enforcement action rather than imposing new prospective requirements; it reiterates CIMA's expectation that licensees maintain effective AML/CFT/PF and Sanctions policies, robust transaction monitoring, proper record keeping, and adequate client disclosures, and signals continued supervisory vigilance and enforcement.

Applies to

securities investment business licensees, AML/CFT regulated entities

Deadlines

• at least 5 years following the termination of the business relationship: Underlying AMLR requirement (Regulation 31(1)(b)) to retain records of transaction monitoring analysis results, which the Licensee was found to have breached.