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FATF Notes the Cayman Islands’ Continuous Progress

Updated: Apr 9

The Cayman Islands is pleased that the FATF has duly noted our continuous progress toward completing the final recommended action regarding investigations and prosecutions of money laundering cases.

“Our aim is to demonstrate significant progress in time for the FATF June plenary, and therefore avoid the need for FATF to consider next steps for insufficient progress,” said the Minister of Financial Services and Commerce, the Hon. André Ebanks.

The plenary that concluded today was held in Paris, from 20-24 February. The Attorney General, the Hon. Samuel Bulgin, KC; the Head of the Anti-Money Laundering Unit, Mr Francis Arana; and Minister Ebanks participated in the proceedings.

The Attorney General oversees the Cayman Islands’ AML/CFT regime, and the Chief Officer in the Ministry of Financial Services and Commerce is the AMLSG’s deputy chair.

FATF sets the global regulatory standard for anti-money laundering and terrorist financing (AML), and it also monitors countries for their compliance with this standard.

Among other matters, plenary agendas include determining if countries will be added or removed from FATF’s list of countries that, because of deficiencies in their AML regimes, are under increased FATF monitoring.

FATF added the Cayman Islands to this list in February 2021, and required us to complete three recommended actions in order to be delisted. These three actions were what remained from 63 actions, recommended in March 2019 by the Caribbean Financial Action Task Force (CFATF), to strengthen our AML regime. CFATF supports the FATF’s global work in the Caribbean region.

Following significant progress last year, FATF confirmed at the October 2022 plenary that the Cayman Islands had only one remaining recommended action to address: Investigations and prosecutions of money-laundering cases.

“They occur in sequence,” Minister Ebanks explained. “First is that offences are investigated, followed by offenders being successfully prosecuted; and second, that the courts apply effective, proportionate and dissuasive sanctions to those convicted.

“For FATF to consider this recommended action as addressed the Cayman Islands must demonstrate, among other things, that those convicted have been sentenced.”

Minister Ebanks said that, in accordance with FATF procedures, the Cayman Islands will provide an update during the FATF Joint Group’s review meeting this April, prior to the FATF Plenary this June.



IMS is one of the longest established company management firms in the Cayman Islands. IMS is licensed by the Cayman Islands Monetary Authority to provide independent directors, company management and incorporation, mutual fund administration, captive insurance and trust services. For more information about our services, please contact us.


Disclaimer: this publication does not constitute legal or professional advice and should not be relied on as such.

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