The statutory requirements for the appointment of an MLRO for Cayman Managers are:
- The MLRO must be a natural person and be named in the SIBL.
- The MLRO must meet and comply with Cayman legislative requirements.
- There is no requirement for the MLRO to be a Cayman resident.
If you are registered under the SIBL as an Investment Manager or Advisor it is mandatory to have a MLRO.
Apex now offers its clients MLRO services covering the following:
- Many Cayman funds set up a Cayman IM / IA and if the manager opts out of MLRO support services on the fund, the MLRO can be provided by a third party such as Apex.
- Apex MLRO support services ensure controls and procedures are in place to prevent money laundering and operates independently of any AML/KYC services already provided.
- Apex MLRO support services ensure that the person allocated to this role is well versed in the different types of transactions handled.
- The MLRO will have in depth knowledge of all aspects of the primary legislation, regulations and internal policies.
- An MLRO will ensure that compliance with Cayman law and regulation is monitored, controlled and maintained.
- The MLRO will ensure appropriate disclosures are made to the relevant Reporting Authority to maintain compliance.
- Having an MLRO in place keeps third party service provider fees reasonable by managing risks effectively.