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In the second episode of AML Uncovered, host Mark Mangion sits down with Glenn Kennedy, Founder and Managing Director of Leeward Management, a leading provider of governance, compliance, and corporate services to Cayman Islands investment funds and legal entities. Together, they explore the key aspects of the Cayman AML regime, including risk assessments, sanctions screening, and the vital roles of AML officers. They also examine how these regulations compare to upcoming AML requirements for US fund managers, emphasizing the critical importance of proactive preparation for the evolving compliance landscape.
Topics covered include:
[04:13] Detailed explanation of the Cayman AML regime, the roles of AMLCO, MLRO, and Deputy MLRO, and the processes to ensure compliance, including risk-based policies and procedures and reporting suspicious activities.
[07:30] Discussion on verifying source of funds and source of wealth, differences between U.S. and Cayman requirements, and high-risk factors like political exposure influencing due diligence procedures.
[23:00] Importance of regular sanctions checks, internal audits, and maintaining AML programs. Insights into the periodic review process and operational tasks involved in AML compliance.
[28:00] Explanation of coordinated efforts between Passthrough and Leeward to streamline subscription and KYC processes, offering a unified and efficient approach to AML compliance for fund managers.
[31:59] Comparisons between existing Cayman AML requirements and new U.S. AML rules coming into effect by January 2026, emphasizing the importance for fund managers to start preparing their compliance programs.
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