FAQs for Filing of REEFS Forms for AML Officers to Funds (2019-02-01)

Summary

This is a CIMA general industry notice published as a set of Frequently Asked Questions (FAQs) explaining the practical mechanics of notifying the Authority about the appointment of AML Officers (Money Laundering Reporting Officer, Deputy MLRO, and Anti-Money Laundering Compliance Officer) for CIMA-regulated funds.

• Portal and form use: How to use the REEFS online portal and form MLO-154-99.
• Technical issues: Common technical issues, such as a fund not appearing in the portal's drop-down list.
• Status checks: How to check filing status.
• Corrections: How to correct errors in a filing.
• Rejection reasons: Reasons a filing might be rejected, such as the MLRO and DMLRO being the same individual, or duplicate filings.

• REEFS access: REEFS access is restricted to local (Cayman-based) service providers; funds without such access should use another local provider that has it.
• Original deadline: The original deadline for notifying the Authority of AML Officer appointments was 31 December 2018 for both regulated and unregulated funds.
• Enforcement for late filings: CIMA can impose administrative fines and pursue further enforcement for late filings.
• Filing window after changes: A 21-business-day window applies for filing a new form following any Board Resolution changing an AML Officer.

Overall this is an operational/explanatory document rather than a new rule-making instrument, but it restates and clarifies existing filing obligations and timelines tied to the Anti-Money Laundering Regulations, so funds and their service providers should treat the procedural requirements described as binding compliance steps.

Key obligations

• All CIMA-regulated funds must notify the Authority of AML Officer (MLRO, DMLRO, AMLCO) appointments via the REEFS Portal using form MLO-154-99, not by email.
• The MLRO and DMLRO must be different individuals; the same person cannot hold both designations.
• If an error is made in a submitted MLO-154-99 Form, the fund/service provider must contact the Authority to have the filing rejected for correction rather than submitting a new/duplicate form.
• Any change in appointed AML Officer(s) following a Board Resolution must be notified to the Authority via a new MLO-154-99 Form within 21 business days of the Resolution being passed.
• Funds without local REEFS access should arrange for a local service provider with REEFS access to make the required filings.
• Supporting documentation (e.g., Board Resolutions, resumes, officer biographies) must be provided if discrepancies arise regarding an AML Officer's identity details.

Applies to

CIMA regulated funds, unregulated funds, local service providers, Money Laundering Reporting Officers (MLRO), Deputy Money Laundering Reporting Officers (DMLRO), Anti-Money Laundering Compliance Officers (AMLCO)

Deadlines

• 31 December 2018: Original deadline for regulated and unregulated funds to notify the Authority of AML Officer (MLRO/DMLRO/AMLCO) appointments via REEFS.
• 21 business days: Timeframe within which a new MLO-154-99 Form must be filed via REEFS following a Board Resolution changing an appointed AML Officer.