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Accountants play a critical gatekeeper role in the financial system, facilitating transactions and providing financial information that underpin the Cayman Islands economy. Because of this role, the accounting profession has a responsibility to help prevent criminals from misusing the financial system to legitimise the proceeds of crime, finance terrorism, or support the proliferation of weapons. A robust AML/CFT framework helps protect the integrity of the Cayman Islands’ financial system, supports economic growth and maintains international confidence in the jurisdiction.
Legislative Framework
The Cayman Islands’ AML/CFT/CPF regime is established through a comprehensive set of laws that define criminal offences, regulatory obligations, and supervisory responsibilities. The principal laws include:
- The Proceeds of Crime Act (2025 Revision) criminalises money laundering and creates reporting obligations related to suspicious activity. Recent amendments that came into force in January 2025 also require persons filing a suspicious activity report (SAR) to obtain prior consent from the Financial Reporting Authority (FRA) for certain defences against money laundering.
- The Terrorism Law (2018 Revision) criminalises terrorist financing, including the provision or collection of funds intended to support or facilitate terrorist acts.
- The Proliferation Financing (Prohibition) Law (2017 Revision) prohibits financing used, in whole or in part, for the manufacture, acquisition, transfer, or use of nuclear, chemical, biological, or radiological weapons (proliferation financing).
- The Anti-Money Laundering Regulations (2025 Revision) implement the detailed AML/CFT/CPF requirements for persons carrying out relevant financial business, including customer due diligence, risk assessments, record-keeping, internal controls, compliance functions, suspicious transaction reporting and sanctions screening.
Together, these laws provide the statutory foundation for preventing, detecting, and reporting money laundering, terrorist financing, and proliferation financing activities, with penalties and enforcement measures for non-compliance.
CIIPA’s Role in AML/CFT Supervision
Since December 2017, CIIPA has been designated as the AML Supervisory Authority for the accountancy profession in the Cayman Islands under the Anti-Money Laundering (Designated Non-Financial Businesses and Professions) (Amendment) (No. 2) Regulations, 2017. CIIPA’s supervisory responsibilities include:
- Registering accounting firms and accounting service providers that are subject to AML/CFT obligations;
- Monitoring compliance with applicable laws, regulations, and supervisory guidance;
- Issuing guidance, directives, and procedures to support effective AML/CFT implementation; and
- Taking appropriate supervisory or enforcement action where necessary.
CIIPA’s supervision is risk-based and aligned with international standards.
International Standards and Cooperation
The Cayman Islands has implemented the Financial Action Task Force (FATF) 40 Recommendations, which represent the international standard for effective AML/CFT/CPF regimes. The jurisdiction participates in international cooperation and regional bodies that support information sharing and coordinated action against financial crime.
Key concepts explained:
What is Money Laundering?
Money laundering is the process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activities.
What is Terrorist Financing?
Terrorist groups, like criminal organisations, must develop sources of funding, a means of laundering those funds, and a way of using those funds to obtain materials and logistical items to commit terrorist acts.
What is Proliferation Financing?
Proliferation financing refers to the act of providing funds or financial services which are used, whole or in part, for the manufacture, acquisition, possession, export, trans-shipment, brokering, transfer, stockpiling or use of nuclear, chemical, radiological or biological weapons.
Who Needs to Register with CIIPA?
Any firm engaging in public practice, or providing accounting services including but not limited to bookkeeping, payroll, accounts preparation, tax advisory or tax compliance services must register with CIIPA by completing this form. Public Practice Firms already registered with CIIPA according to the Accountants Law, do not need to register separately. Firms are also responsible for notifying CIIPA within 15 days, when services provided are changed. If updating services please complete the Services Update Declaration (Renewal form).
Risk Assessment and Supervisory Approach
CIIPA has conducted a risk assessment of accounting services in the Cayman Islands to inform its supervisory plan and assist firms in developing their own risk-based AML/CFT programmes. Firms are expected to assess their risk exposures and implement controls that reflect the nature, size, and complexity of their business and client base.
Resources and Registers
Registered Firms:
CIIPA AML/CFT Resources
Access guidance, templates, and supervisory materials on CIIPA’s AML/CFT Resources page.
Financial Sanctions Notices
The Financial Reporting Authority (FRA), within the Portfolio of Legal Affairs, administers and coordinates financial sanctions in the Cayman Islands. Firms must comply with applicable sanctions requirements. Current Financial Sanctions Notices are available via the FRA and other official channels.
Relevant Legislation
Visit our Legislation page to learn more about the relevant legislation impacting CIIPA and its members.
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