Cayman Islands Monetary Authority Fines Blacktower Financial Management (International) Limited CI$230,038.72

The Cayman Islands Monetary Authority (the “Authority”) has imposed discretionary administrative fines totalling CI$230,038.72 on Blacktower Financial Management (International) Limited (the “Licensee”) pursuant to the provisions of sections 42A and 42B of the Monetary Authority Act (2020 Revision) (as amended) and the Monetary Authority (Administrative Fines) Regulations (2025 Revision) for breaches of the Anti-Money Laundering Regulations (2023 Revision) (as amended) (now superseded by the 2025 Revision) (the “AMLRs”).

The administrative fines were imposed for the Licensee’s failure to comply with the legislative requirements of the AMLRs as follows:

1. Failing to comply with record keeping requirements pursuant to Regulation 31(1)(b) of the AMLRs in that the Licensee did not maintain records of the results of any analysis undertaken as part of its transaction monitoring for at least 5 years following the termination of the business relationship;
2. Failing to maintain a transaction monitoring system in contravention of Regulation 5(a)(ix) of the AMLRs and Rule 4.1 of the Rule on Internal Controls, 2007 (now superseded by the Rule and Statement of Guidance, Internal Controls for Regulated Entities); and
3. Failing to perform enhanced due diligence pursuant to Regulation 17 of the AMLRs in instances of unusual or suspicious activity in contravention of Regulation 27(f) of the AMLRs.

Additionally, the administrative fines were imposed for the Licensee’s failure to comply with the legislative requirements of the Securities Investment Business (Conduct of Business) Regulations 2003 as follows:

1. Failing to ensure that clients are provided with sufficient and timely disclosure regarding any other matter reasonably to be regarded as necessary to enable the client to make informed decisions regarding securities investment business conducted with or through a licensee.

The above findings were as a result of an onsite inspection.

This case underscores the need for licensees to have appropriate, effective and fully implemented anti-money laundering/countering the financing of terrorism/proliferation financing (“AML/CFT/PF”) and Sanctions policies and procedures, as well as sound practices under the Securities Investment Business framework. It also reinforces the importance of maintaining robust transaction monitoring systems, adhering to record keeping obligations, conducting enhanced due diligence in instances of unusual or suspicious activity, and ensuring clients receive sufficient and timely disclosures to make informed decisions. These measures are essential to avoiding the risk of entities being used as a conduit for money laundering, terrorist financing and any other financial crime.

The Authority remains firmly committed to strengthening the Cayman Islands’ AML/CFT/PF and Sanctions regime. Through on-site, off-site, and other supervisory activities, it will continue to exercise vigilance in monitoring compliance. Breaches of the jurisdiction’s AMLRs or regulatory acts will be treated with utmost seriousness, and appropriate enforcement or other actions will be taken where necessary.