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KPMG can help you through our outsourced AMLCO/MLRO/DMLRO Service Offering.

KPMG can help you through our outsourced AMLCO/MLRO/DMLRO Service Offering

The Cayman Islands Monetary Authority (“CIMA”) have stipulated that all Cayman Islands domiciled funds, whether regulated or unregulated, and other entities performing “relevant financial business” are now required to appoint a “natural person” to fulfil the role of Anti-Money Laundering Compliance Officer (“AMLCO”), Money Laundering Reporting Officer (“MLRO”) and Deputy Anti-Money Laundering Reporting Officer (“DMLRO”).

Our team of experienced Anti-Money Laudering ("AML") compliance professionals can take on these roles for you, freeing up your time and resources to more effectively manage your business. Furthermore, CIMA have already clarified that it is permissible to outsource these roles to third parties in accordance with Section 10.C of the regulations.


KPMG AMLCO/MLRO/DMLRO Service Offering can provide the following:


  • Provide the Client with appropriately qualified staff and resources to act as the Client’s AMLCO to enable the Client to register our appointment on the CIMA’s Regulatory Enhanced Electronic Forms Submission (“REEFS”) Portal.
  • Oversee the Client’s Anti-Money Laundering and Counter Terrorist Financing systems (AML/CTF).
  • Act as the Client’s primary point of contact for requests or communications from competent authorities related to the Anti-Money Laundering Regulations (“AMLRs”).
  • Review and provide feedback on the Client’s Policy and Procedures (“P&Ps) to ensure its P&Ps are reflective of the operations at the Client and that the P&Ps meet the minimum requirements of the AMLRs and to identify potential compliance gaps in the operations.
  • Determine if the Client has completed an AML compliance review to assess the adequacy of its controls in relation to the AMLRs and section 10B of the AML Guidance Notes. If an AML compliance review has not been completed, KPMG will work with management to ensure that one is competed by a qualified, independent third party.
  • Ensure that required logs are maintained, specifically with respect to declined business, Politically Exposed Persons (“PEPs”) and requests from competent authorities in relation to investigations.
  • Provide a written report to senior management and/or the Board on a bi-annual basis or an agreed upon schedule in relation to the effectiveness of its AML/CTF program, as well as identifying areas of risk or program deficiency.
  • Respond to requests for information by relevant competent authorities.



  • Provide the Client with appropriately trained staff and resources to act as the Client’s MLRO to enable the Client to register our appointment on CIMA’s REEFs Portal.
  • The appointed MLRO will receive and examine the Client’s Suspicious Activity Reports (“SARs”) to determine if there is evidence of, knowledge of or reasonable grounds for suspicion of money laundering or terrorist financing activity.
  • KPMG will maintain a register of money laundering/terrorist financing referrals.
  • If KPMG has knowledge of, suspicion of or reasonable grounds for knowing or suspecting that another person is engaged in money laundering or terrorist financing, KPMG will notify management and submit a SARs to the Financial Reporting Authority (“FRA”).
  • The appointed DMLRO will perform all of the duties of the MLRO in their absence or incapacitation.


White Label Solution

KPMGs white labelling solution enables Fund Administrators or Managers lacking the resources or expertise to provide the service under their name with KPMG providing back office support. This allows smaller administrators or larger risk adverse managers to deliver full service solutions to clients.

For more information on the services we provide, contact our team today.

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