The Anti-Money Laundering Regulations (2025 Revision) require every regulated entity conducting relevant financial business in the Cayman Islands to provide annual AML training to all relevant staff, including directors and senior management. Training must be Cayman-specific, must cover the entity’s own AML policies and procedures and must include recognition of suspicious activity – and records of training completion must be retained and available for Cayman Islands Monetary Authority (CIMA) inspection.
Who must receive AML training
The obligation applies to all staff involved in relevant financial business – including front office, compliance, finance and operations personnel – as well as directors and senior management. New employees must receive AML training before taking up their role or promptly after joining. There is no category of staff involved in business activity who is exempt from the annual requirement.
What the training must cover
Under CIMA’s Guidance Notes (revised February 2024), AML training must address: the Cayman Islands’ AML/CFT legislative framework; the entity’s internal AML policies and procedures; recognition of suspicious activity including relevant typologies and red flags; the legal obligations and protections around suspicious activity reporting; and the consequences of non-compliance. Training focused exclusively on generic international standards – without reference to Cayman-specific law and CIMA’s Guidance Notes – will not satisfy the requirement.
Frequency, updates and records
Annual training is the regulatory minimum. Entities should supplement annual programmes with updates when the legislative framework changes – as it did in February 2024 when CIMA revised the Guidance Notes – or when CIMA issues new thematic guidance. Records of all training completed, including the date, content covered, provider and participant list, must be maintained and be readily available for inspection.
AML officers: an elevated standard
AMLCO, MLRO and DMLRO appointees are held to a higher standard than general staff. They must demonstrate specific knowledge of the Cayman Islands’ AML/CFT legislative framework, CIMA’s regulatory expectations and their own individual responsibilities under the Anti-Money Laundering Regulations. Training for AML officers should be role-specific and more detailed than the general annual programme delivered to all staff, and should be documented separately.
What CIMA finds in practice
CIMA’s published findings from on-site inspections of Registered Persons indicate that 66% of inspected Registered Persons showed weaknesses in their AML/CFT training and awareness programmes, per CIMA’s Key Findings of Registered Persons from On-site Inspections (covering January 2022 to March 2024) – the most commonly identified deficiency across all inspection categories. The most frequent issues were outdated training material, incomplete attendance records and training content that failed to address Cayman-specific requirements.
AML training is one of the most consistently cited deficiency areas in CIMA inspections – and one of the most straightforward to remedy with a structured, documented annual programme.
Related questions: What anti-money laundering obligations apply to an investment manager running a Cayman-domiciled fund? | How does CIMA assess an investment manager’s AML framework during an on-site inspection? | What is the FATF (Financial Action Task Force) and how do its standards affect Cayman Islands businesses? | What is the Cayman Islands’ anti-money laundering legislative framework and which laws apply?
WB Group provides Cayman-specific AML training for staff, directors and AML officers, as well as AML programme reviews. Contact us to discuss your AML programme or visit our AML compliance service page.
FAQs
Yes. The Anti-Money Laundering Regulations (2025 Revision) require regulated entities to implement AML training programmes for all relevant staff. CIMA’s Guidance Notes (revised February 2024) confirm that annual training is the minimum frequency required for all employees, directors and senior management involved in relevant financial business.
Yes. Training may be delivered in person or online, and a number of compliance providers offer Cayman-specific annual AML training programmes. Whatever the format, training must address Cayman law and CIMA’s Guidance Notes specifically – generic international AML content alone will not meet the regulatory standard.
CIMA regularly identifies training record deficiencies during on-site inspections. Where records are incomplete, outdated or fail to demonstrate Cayman-specific content, CIMA may require remediation, impose conditions on the entity’s licence or registration, or treat the deficiency as part of a broader AML enforcement finding.
Yes. The AMLCO, MLRO and DMLRO are required to have specific knowledge of Cayman Islands AML/CFT legislation and CIMA’s regulatory requirements beyond the general staff programme. Their training should address their individual responsibilities in detail and be documented separately from the entity’s general annual AML training records.