DNFBPs

Who is caught

These instruments apply to persons carrying on 'relevant financial business' in or from the Cayman Islands, and specifically to the subset of designated non-financial businesses and professions (DNFBPs) brought within the AML/CFT regime. The Proceeds of Crime Act (2025 Revision) defines the outer boundary of relevant financial business in Schedule 1, and the Anti-Money Laundering Regulations (2025 Revision) address DNFBPs directly through Part 12A.

• Relevant financial business: Under Schedule 1 to the Proceeds of Crime Act, scope includes providers of virtual asset services, securities investment businesses, real estate and listing agents, Cayman Islands Stock Exchange broker members, providers of registered office services to private trust companies, and persons investing, administering or managing funds for others.
• Dealers in precious metals or stones: Caught in respect of cash transactions of US$10,000 or more, per Schedule 1 to the Proceeds of Crime Act.
• Trust and corporate services providers: TCSPs are a core supervised population, subject to the AMLRs and Guidance Notes and to CIMA's onsite inspection and sanctions-screening reviews.
• Company management and corporate services: Persons applying for or holding a Companies Management Licence or Corporate Services Licence under the Companies Management Act are regulated by CIMA under the Companies Management Regulations (2026 Revision).
• Money services businesses: Persons applying for or holding a licence to carry on money services business (money transmission, remittance, currency exchange) under the Money Services Act, and their sub-agents, are regulated under the Money Services Businesses Regulations (2026 Revision).
• DNFBPs generally: The AML Regulations establish a designation and registration regime for DNFBPs operating in or from the Cayman Islands, applying the AML/CFT/CPF framework to them via Part 12A.

Sources: Anti-Money Laundering Regulations (2025 Revision) · Companies Management Regulations (2026 Revision) · Proceeds of Crime Act (2025 Revision) · 2022 Review of TCSPs Compliance with AMLRs – Sanctions Screening Policies and Procedures (2023-07-27) · Money Services Businesses Regulations (2026 Revision) · Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the Cayman Islands (2020 Revision)

Key duties

The recurring obligations sit in the Anti-Money Laundering Regulations (2025 Revision) and CIMA's Guidance Notes, supplemented by licensing and fee duties in the sector-specific regulations. Detailed operational AML/CFT obligations are set out in the Regulations and Guidance rather than in the Proceeds of Crime Act itself.

AML/CFT programme

• Compliance programme: Establish and maintain systems, controls and staff training to prevent money laundering, terrorist financing and proliferation financing.
• Appointments: Appoint an Anti-Money Laundering Compliance Officer and a Money Laundering Reporting Officer (and, per the Guidance Notes, a deputy MLRO) with defined duties.
• Risk assessment: Conduct and document risk assessments of customers, products, delivery channels, new technologies and countries, applying a risk-based approach.
• Customer due diligence: Perform standard, simplified or enhanced due diligence as appropriate, including for politically exposed persons and life insurance beneficiaries.
• Record-keeping: Maintain records of customer identification, transactions and due diligence in line with the record-keeping procedures.
• Suspicious activity reporting: File suspicious activity reports when required and maintain internal reporting procedures.
• Sanctions screening: Screen clients and associated parties against applicable targeted financial sanctions lists at onboarding and on an ongoing basis, document alert resolution, and file a Compliance Reporting Form with the Financial Reporting Authority where there is a true match (per Regulations 5(a)(v), 5(a)(viiia) and 5(a)(viiib) of the AMLRs).
• Wire and virtual asset transfers: Comply with identification and record-keeping requirements for wire transfers (Part 10) and for transfers of virtual assets (Part 10A).

DNFBP registration and supervision

• Registration: DNFBPs must register with their designated Supervisory Authority, allow site visits, notify the Supervisory Authority as required, and respond to information requests.
• Supervisory Authority duties: Supervisory Authorities must maintain a DNFBP register, submit annual reports, and may impose administrative fines for breaches of prescribed provisions.

Licensing and fees

• Companies management licences: Applicants must submit the information in Schedule 1 to the Companies Management Regulations, demonstrate the required minimum net worth, and pay prescribed fees (a US$1,000 application fee, grant fees of $750 for a Companies Management Licence and $500 for a Corporate Services Licence, and tiered annual or renewal fees based on the number of managed or serviced companies as at 31 December of the preceding year).
• Money services licences: Applicants must provide the Schedule 1 particulars and pay the Schedule 3 fees; licensees must report to CIMA on each sub-agent, provide specified information before entering a sub-agent arrangement, fund an independent sub-agent assessment if CIMA requires, and notify CIMA forthwith of any change in the information supplied in the licence application.

Sources: Anti-Money Laundering Regulations (2025 Revision) · Companies Management Regulations (2026 Revision) · Proceeds of Crime Act (2025 Revision) · 2022 Review of TCSPs Compliance with AMLRs – Sanctions Screening Policies and Procedures (2023-07-27) · Money Services Businesses Regulations (2026 Revision) · Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the Cayman Islands (2020 Revision)

Exemptions and carve-outs

The instruments indexed here contain few express carve-outs. The principal threshold that limits scope is the cash transaction floor for dealers, and the Regulations and Guidance allow risk-calibrated treatment rather than outright exemption.

• Dealers threshold: Dealers in precious metals or precious stones are within scope only for cash transactions of US$10,000 or more, per Schedule 1 to the Proceeds of Crime Act.
• Simplified due diligence: The AML Regulations and Guidance Notes permit simplified due diligence for lower-risk relationships as part of the risk-based approach, but this is a modulation of the obligation rather than an exemption from it.

Sources: Anti-Money Laundering Regulations (2025 Revision) · Proceeds of Crime Act (2025 Revision) · Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the Cayman Islands (2020 Revision)

Enforcement and penalties

Enforcement runs through CIMA's supervisory powers, an administrative fines regime, and criminal liability for certain breaches. The AML Regulations provide the standing administrative fines framework, with the fine categories originally introduced by a 2016 amendment to the Monetary Authority Law.

• Administrative fines: The AML Regulations provide for an administrative fines and appeals framework, with fine categories set out in Schedule 2 and appeal rights to the Grand Court.
• Fine categories: CIMA's 2017 circular describes the regime as non-discretionary 'minor' breaches at $5,000 per breach (up to $20,000 if ongoing) and discretionary 'serious' or 'very serious' breaches from $50,000 to $1,000,000 per breach.
• Requirements and remediation: Following onsite inspections CIMA can impose requirements on firms with inadequate systems and controls; 32 requirements were issued to TCSPs after the 2022 inspections, with remediation monitored against prescribed timeframes.
• Criminal offence: Failure to comply with targeted financial sanctions requirements is a criminal offence, per CIMA's sanctions-screening circular.
• Asset recovery powers: Under the Proceeds of Crime Act the courts may make confiscation, restraint, receivership and civil recovery orders, and there are summary procedures for search, seizure, detention and forfeiture of cash suspected to be proceeds of crime.

Sources: Anti-Money Laundering Regulations (2025 Revision) · Proceeds of Crime Act (2025 Revision) · 2022 Review of TCSPs Compliance with AMLRs – Sanctions Screening Policies and Procedures (2023-07-27) · TCSPs Onsite Inspections Findings & Administrative Fine Regime (2017-02-01)