November 9, 2026
What happens if a fund has no internal AML review history when its first independent audit comes due?
A Cayman fund with no prior internal AML audit reports typically receives its first audit finding before testing even…
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November 9, 2026
Can a Cayman Fund Use an Overseas AML Officer?
CIMA’s AML/CFT/CPF Compliance Rule sets an independence and qualification standard for a fund’s AML officer, not a…
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November 9, 2026
What does CIMA’s Sanctions Rule require, separately from the AML/CFT/CPF Compliance Rule?
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November 9, 2026
Does outsourcing AML functions to a fund administrator or third-party AML officer transfer away a fund’s compliance responsibility?
No – CIMA’s AML/CFT/CPF Compliance Rule states that where a financial services provider (FSP) relies on a third party…
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October 28, 2026
What does an independent AML auditor ask for first, and how should a fund prepare for it?
A fund’s independent AML auditor typically requests its prior internal review reports before anything else. wb.group…
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October 28, 2026
Who can perform an independent AML audit under CIMA’s Compliance Programme Rule, and why can’t a fund’s own AML officer do it?
Rule 12.2 of CIMA’s Compliance Programme Rule requires a fund’s AML audit to be performed by suitably qualified persons…
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October 28, 2026
How often must a Cayman Islands fund complete an independent AML audit under CIMA’s Compliance Programme Rule?
Under Rule 12 of CIMA’s AML/CFT/CPF Compliance Rule, audit frequency is risk-based, but internal audits are capped at…
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October 28, 2026
Which Cayman Islands entities are in scope of CIMA’s AML/CFT/CPF Compliance Rule?
CIMA’s AML/CFT/CPF Compliance Rule, effective 18 September 2026, reaches every FSP CIMA regulates and supervises,…
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October 28, 2026
What is CIMA’s AML/CFT/CPF Compliance Rule, and when did it take effect?
CIMA’s Rule on an Effective Compliance Programme for AML/CFT/CPF took effect on 18 September 2026 and applies to every…
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October 26, 2026
What do CIMA’s FAQs say about the AML Compliance Officer’s liability, qualifications and independence?
CIMA's FAQs set out when an AML Compliance Officer can be personally liable, the qualifications CIMA expects and what…
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