On February 22, 2022, the Cayman Islands Monetary Authority (the “Authority”) issued a public notice advising virtual asset service providers (VASPS) that the identification and record-keeping requirements relating to transfers of virtual assets under the Anti-Money Laundering Regulations (“AMLRs”) will commence effective July 1, 2022. On March 23, 2022, the Authority issued a reminder that all VASPS must submit certain details to the Authority by March 31, 2022.
Details of submission
According to the Authority’s notice, Financial Action Task Force (“FATF”) Recommendation 16 prescribes that originating virtual asset service providers (“VASPs”) must obtain, and hold required and accurate originator information along with the required beneficiary information on virtual asset transfers. These requirements apply to VASPs whenever their transactions (in fiat currency or virtual assets) involve: (a) a traditional wire transfer, (b) a virtual asset transfer between a VASP and another obliged entity or (c) a virtual asset transfer between a VASP and a non-obliged entity. The application of the FATF’s wire transfer requirements in the virtual asset context is known as the “Travel Rule”.
All VASPS registered or in the process of registering with the Authority are required to advise the Authority on how they will comply with the Travel Rule related provisions as outlined in the AMLRs, by submitting details of their compliance arrangements, including the relevant policies and procedures and the use of resources (including technological tools) via email to [email protected] by March 31, 2022.
How should the information be filed with the Authority
According to the Authority, the foregoing information should be included by VASPS as an attachment when submitting their policies pertaining to Anti-Money Laundering/Counter Terrorist Financing via the REEFs application, APP 101-84 (Schedule E).
There is also updated REEFs Form Guidance on the Authority’s website.
Assistance with filing
Service providers who have questions or who require any further information should contact [email protected]