Reminder of Travel Rule Requirements for VASPs (2022-03-23)

Summary

This is a short reminder notice from the Cayman Islands Monetary Authority (CIMA) directed at virtual asset service providers (VASPs), reiterating obligations first set out in a Notice dated 22 February 2022 regarding the AML/CFT "Travel Rule" under Part XA of the Anti-Money Laundering (Amendment) (No. 2) Regulations, 2020. It does not create new substantive requirements but reinforces an existing deadline and process for compliance reporting.

• Existing VASPs: All VASPs that are registered with CIMA, or in the process of registering, must inform the Authority how they will comply with the Travel Rule by submitting details of their compliance arrangements — including relevant policies, procedures, and technological tools — via email to vaspinfo@cima.ky by 31 March 2022.
• New applicants: Since the original February 2022 Notice, all new applicants for VASP registration or licensing must indicate their Travel Rule compliance approach as part of their AML/CTF policy submissions through the REEFs application (Form APP 101-84, Schedule E), referencing updated REEFs Form Guidance available on CIMA's website.

Given the March 2022 date of this notice, the 31 March 2022 deadline referenced is historical and has already passed; the notice is retained here as a record of the compliance expectation and process rather than as an ongoing action item, though the underlying REEFs submission requirement for new applicants remains relevant context for current filings.

Key obligations

• Registered VASPs and those in the process of registering must submit to CIMA (via vaspinfo@cima.ky) details of their Travel Rule compliance arrangements, including policies, procedures, and technological tools, by 31 March 2022.
• New applicants for VASP registration/licensing must indicate in their applications how they will comply with the Travel Rule, submitted as an attachment to their AML/CTF policies via the REEFs application (Form APP 101-84, Schedule E).

Applies to

virtual asset service providers (VASPs)

Deadlines

• 31 March 2022: Deadline for registered or registering VASPs to submit details of their Travel Rule compliance arrangements to vaspinfo@cima.ky.