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Attorney General leads Cayman’s CFATF plenary delegation

Cayman Islands Attorney General, the Hon. Samuel Bulgin, QC


The Attorney General, the Hon. Samuel Bulgin, QC, led a 10-person delegation from the Cayman Islands to the Caribbean Financial Action Task Force (CFATF) plenary held the week 22 November in Antigua. During the plenary, Cayman presented our First Follow-Up Report (FFUR), which was submitted to the CFATF in September. The report outlined our progress to date in fulfilling the CFATF’s 63 recommended actions for our jurisdiction.

The Attorney General delivered a presentation to almost 200 delegates from over 25 countries that outlined our significantly enhanced legislative framework; our increased effectiveness in implementing the legislative framework, as a result of additional resources, policies, training, and outreach; and our improved understanding in both the public and private sectors of our role in the global AML/CFT/ PF fight.

During the plenary sessions, delegates also discussed the mutual evaluation reports for the Turks and Caicos Islands and Bermuda, with Ms. Elisabeth Lees, National Coordinator for Cayman’s Anti-Money Laundering Steering Group, acting as legal assessor during the peer review. Representatives from the United Kingdom Treasury educated delegates on the implementation of targeted financial sanctions without delay and the delegation discussed proposed changes to the CFATF mutual evaluation process.

Ms. Lees also presented to the delegation on the Cayman Islands’ recently completed National Risk Assessment of Terrorist Financing. The Cayman Islands was the first country in the Caribbean to assess its jurisdictional risks for terrorist financing using the methodology issued by the Financial Action Task Force in June 2019. By being one of the first jurisdictions to use this methodology, Cayman has provided a key blueprint for other jurisdictions to follow, Ms. Lees said.

Ms. Lees, who coordinates our jurisdiction’s response to the CFATF, said in relation to the Cayman Islands’ own peer review process that Cayman has a 21 February 2020 deadline to demonstrate that it has made positive and tangible progress in implementing the recommendations of the report. The Financial Action Task Force (FATF) has to decide then whether to impose a remediation plan on the Cayman Islands and place the jurisdiction on the compliance document.

“The Cayman Islands is committed to taking proactive steps to ensure compliance with international standards.  All stakeholders are doing everything they can to fulfill the 63 recommended actions, and it was good to present to Plenary on the significant progress we have made. Whatever decision is made by FATF, the Cayman Islands will continue to ensure all the recommended actions are fulfilled.”

Note to Editors

The FATF sets the global regulatory standard for AML/CFT/CPF, and CFATF acts on behalf of the FATF within the Caribbean region. The FATF will deliver its decision regarding Cayman’s fulfilment of the recommended actions at its June 2020 Plenary.

The recommended actions are contained in the CFATF’s March 2019 report on Cayman’s anti-money laundering, countering the financing of terrorism, and countering proliferation financing (AML/CFT/CPF) regime, and the effectiveness of our regime’s implementation by regulators and industry (MER).


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