Cayman FSPs: Prepare Now for the FATF Fifth Round Review

1. Evidence effectiveness. Demonstrate the effectiveness of documented anti-money laundering, countering the financing of terrorism, counter-proliferation financing (“AML/CFT/CPF“) and targeted sanctions policies, procedures and controls by conducting independent audits.
2. Engage the board. Governing bodies should demonstrate awareness of the upcoming FATF inspection and participate in national pre-evaluation initiatives and risk assessments.
3. Complete and operationalise entity-wide risk assessments. Ensure AML/CFT/CPF frameworks are informed by these assessments, and that sanctions screening is risk-based, calibrated and performed at onboarding and throughout the relationship with real-time access to global lists.
4. Ensure beneficial ownership transparency. Collect, verify, retain and make readily available accurate beneficial ownership information for legal persons and arrangements.
5. Train your people. Ensure annual AML/CFT/CPF and sanctions training that reflects legislative changes and current global risks is undertaken by all governing body members and staff (where applicable).

Maples Group can help you get there. Our team supports FSPs with business risk assessments and tailored AML/CFT/CPF and sanctions manuals; corporate governance and internal control policies; record keeping policies; outsourcing policies and procedures; policy gap analyses, mock audits and remediation planning; regulatory notifications, prudential returns and responses to information requests; governance and AML/CFT/CPF and sanctions training for boards, senior management and staff; customer lifecycle controls, including onboarding, beneficial ownership verification and ongoing due diligence; sanctions screening calibration and adverse media processes; and alignment of data protection, cybersecurity and tax reporting within a coherent compliance architecture.

To discuss practical next steps and an implementation plan aligned to the Fifth Round, contact the Maples Group team in the Cayman Islands.