CI$100,000 Administrative Fine Imposed on Cainvest Bank and Trust Limited

Grand Cayman, Cayman Islands (Thursday, 12 November) The Cayman Islands Monetary Authority (“the Authority”) recently imposed a discretionary administrative fine of CI$100,000.00 on Cainvest Bank and Trust Limited (“the company”) pursuant to sections 42A and 42B of the Monetary Authority Law (2020 Revision) for breaches of the Anti-Money Laundering Regulations (“the AMLRs”).  

The fine was imposed for the company’s failure to comply with the following legislative requirements of the AMLRs:

1. The application of Customer Due Diligence measures
2. The application of Enhanced Due Diligence measures
3. Failing to identify beneficial ownership
4. Failing to scrutinize transactions

Some of the findings represent failings by the company to remediate similar deficiencies identified during a previous onsite inspection conducted by the Authority in 2018.

This case highlights the importance of licensees having in place effective anti-money laundering/countering the financing of terrorism/proliferation financing (“AML/CFT/PF”) policies and procedures which are appropriate, effective and fully implemented to ensure compliance with the jurisdiction’s AML/CFT/PF and regulatory frameworks, thus avoiding the risk of entities being used as a conduits for money laundering, terrorist financing and any other financial crime.

The Authority is committed to enhancing the Cayman Islands’ AML/CFT regime and through its on-site, off-site and other monitoring processes it will continue to exercise vigilance in that regard.  We will also continue to treat breaches of the jurisdiction’s AMLRs or regulatory laws with particular seriousness and take the appropriate enforcement or other actions where necessary.