It is perhaps slightly anti-intuitive to bracket COVID-19 restrictions and AML / CFT matters as a source for cheer, but one side effect of the pandemic is that it has extended the observation period for FATF assessment of the Cayman Islands' response to the country's Mutual Evaluation Report (the “MER”) published in March 2019. This observation period now ends at the end of October and the FATF will make its decision in February next year whether the Cayman Islands has made sufficient progress in implementing the recommendations of the MER. The Cayman Islands industry participants will be well aware of the extensive AML / CFT improvements that have been implemented, including changes in legislation and technical requirements deriving therefrom, increased supervision and inspection (including for non-financial businesses), education and outreach programmes and greater coordination between law enforcement and regulatory bodies. Hopefully the Cayman Islands will be recognised for the tangible efforts of both its public and private sector.
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