Cayman Islands Monetary Authority
A CIMA compliance monitoring programme
CIMA content is planned in the same structure as VARA, so every requirement can be marked applicable per registration or licence, linked to your policies and controls, and tested.
Status: Planned. CIMA content would follow in the same structure as VARA. TODO(Miles): confirm whether CIMA is on the launch roadmap and its timing
What the compendium covers for CIMA
- Planned scope, to be confirmed: the Virtual Asset (Service Providers) Act and CIMA's related rules and guidance, and the Anti-Money Laundering Regulations with CIMA's guidance notes. TODO(Miles): confirm the CIMA scope
How updates are handled
- Every requirement will carry its reference, source link, effective dates and version.
- When a rule changes, the requirement gets a new version, and firms with the old version marked applicable get a change task.
- New and changed content is reviewed by a person before it is published.
Typical monitoring tests
- A periodic review of a sample of client files against your customer due diligence procedures.
- A check that each item on the compliance monitoring plan was performed, reviewed and evidenced on time.
- A check that policies due for review were reviewed and re-approved by the right people.
Glossary
- CIMA
- The Cayman Islands Monetary Authority, the financial services regulator of the Cayman Islands.
- VASP Act
- The Virtual Asset (Service Providers) Act, which governs virtual asset service providers in the Cayman Islands.
- AMLCO
- Anti-Money Laundering Compliance Officer.
- MLRO
- Money Laundering Reporting Officer.
The tests above are examples of what a plan can hold. Your own tests come from the requirements you mark applicable and from your policies.
TODO(Miles): check the glossary definitions and the planned scope against current CIMA publications