AML Steering Group releases money-laundering case studies

The Cayman Islands Anti-Money Laundering Steering Group (AMLSG) has compiled real-life crime cases, from Cayman and abroad, in its publication ‘Money Laundering Typologies and Trends’ to demonstrate how different industry sectors can be misused by criminals.

The publication includes money laundering, terrorist financing, tax evasion, drug trafficking and proliferation financing examples involving real estate, jewellery and corporate services among others.

The case studies, particularly those relating to the misuse of legal persons, featured prominently in outreach sessions held during the week of 4 Nov. for these specific groups and individuals.

Attorney General Samuel Bulgin said in a press release that while the identities of individuals and companies are not provided in the publication, the cases would raise public awareness of these types of crimes.

Attorney General Samuel Bulgin

“But foremost, this publication is for financial institutions, and designated non-financial businesses and professions – a group that includes realtors, dealers of precious metals and stones, and accountants,” he added. “Providing these actual cases will help them to develop even more effective policies and procedures to prevent, detect, and respond to these crimes.”

Data for the publication came from the Financial Crime Unit, Royal Cayman Islands Police Service, Cayman Islands Monetary Authority, Financial Reporting Authority, Department of Commerce and Investment, Cayman Islands General Registry, Cayman’s 2015 National Risk Assessment and international sources.

The publication is one aspect of fulfilling the Caribbean Financial Action Task Force’s recommended actions, outlined in its March 2019 report, regarding Cayman’s regime against money laundering, terrorist financing and proliferation financing.

The ‘Money Laundering Typologies and Trends’ report helps improve the use of intelligence to better counter these crimes. Cayman has until February 2020 to demonstrate its progress.

AMLSG national coordinator Elisabeth Lees said that international consultants Financial Transparency Advisors are continuing to support Cayman by facilitating the interactive meetings, as well as an outreach session scheduled for Friday, 8 Nov.


  1. The Cayman Islands Anti-Money Laundering Steering Group should adopt the approach of the FCA (Financial Conduct Authority ) in the UK to avoid excessive paperwork overload imposed on businesses. The FCA has for years favored the self-policing approach. It has created extensive policy requirements and has placed a heavy burden on the principals or controlling person of each business to implement those. Unlike the very ‘filings heavy’ regime adopted by CYMA, FCA relies on the threat of potential heavy penalties and jail time for non-compliance. This approach has helped reduce dramatically paperwork and filings, that we see currently in Cayman.

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