Governance, Risk & Compliance

Anti-Money Laundering Services

Centralis' AML Compliance team specialises in the provision of anti-money laundering services, primarily to the Cayman Islands, Bermuda, BVI, Ireland and Luxembourg investment fund industry.

Years of experience working with leading global alternative fund managers enables the team to provide high quality, industry leading anti-money laundering solutions that are tailored to meet the needs of our business partners.

Centralis' AML Compliance solutions provide unmatched accessibility and responsiveness, in a conflict-free independent environment.

Anti-Money Laundering Solutions:

  • Anti-Money Laundering Compliance Officer - responsible for the implementation and oversight of anti-money laundering controls that comply with jurisdictional anti-money laundering requirements.
  • Money Laundering Reporting Officer – responsible for the receipt, investigation and where necessary, the reporting of suspicious activity reports to competent authorities.
  • Deputy Money Laundering Reporting Officer - to assume the responsibilities of the Money Laundering Reporting Officer in their absence.
  • Anti-Money Laundering Advisory Services – covering policy creation, implementation and review.
  • Anti- Money Laundering Audit Services – a detailed review of existing anti-money laundering controls which will ensure ongoing compliance with jurisdictional requirements

Our Services

  • Receipt of internal suspicious activity reports (including suspected sanctions violations) from third parties such as fund administrators, registrar and transfer agent teams, fund directors or fund controllers (“Relevant Persons”):
  • Inform Relevant Persons of the identity of the MLRO and ensure they are aware of their suspicious activity reporting obligations and the procedure to follow when making an internal SAR or compliance report (sanctions);
  • Investigate internal SARs (including, where applicable, those internal to delegates) in order to determine whether a disclosure to the Financial Reporting Authority (the “FRA”) is necessary;
  • Where appropriate file a SAR or Compliance Report with the FRA and update the board of directors/governing body of the Entity (or equivalent) as necessary;
  • Act as point of contact with the FRA throughout the SAR process;
  • Maintain an internal and external SAR log; and
  • Confirm with Relevant Persons on a periodic basis, or as appropriate, that there were no internal reports of suspicious activity relating to the Fund or any of its investors/clients during the period.
  • The implementation of AML policies and procedures which comply with the Anti-Money Laundering Regulations and related regulatory guidance notes, including the implementation of controls that mitigate sanctions and proliferation financing risks;
  • Ensure that investors of the Funds are identified, verified and screened using the risk based approach in accordance with the AML Regulations;
  • Where the Fund has delegated the performance of an AML function to a third party Administrator (the “Delegate”) confirm the adequacy and reliability of the Delegate’s procedures, ensuring that any deficiencies are remediated and that any identified risks are escalated to the governing body of the Funds;
  • Assist with regulatory enquiries from competent authorities (including on-site regulatory AML inspections) and maintain a register of all regulatory correspondence;
  • Ensure that an appropriate ongoing AML risk assessment of the operations of the Funds is conducted and that the results are documented;
  • Maintain a log of Politically Exposed Persons (where applicable);
  • Confirm that governing bodies of the Funds are aware of their jurisdictional AML obligations and receive at least annual AML training which is of a high level; and
  • Ensure that periodic AMLCO reporting is provided to the governing body of the Funds on an ongoing basis, with all board meetings attended.
  • Guidance and practical advice on the implementation of effective anti-money laundering controls, including assistance with regulatory on-site inspections
  • A detailed review/gap analysis of existing anti-money laundering policy and procedures in order to confirm compliance with jurisdictional anti-money laundering legislation

The Advantages of Partnering With Centralis

  • High quality of service provided by seasoned AML professionals. The focus is on hiring and supporting individuals who are best in class.
  • The AML officers have excellent working relationships with Cayman Islands legal firms, independent director firms and global fund administrators.
  • The AML officer portfolios are carefully managed. This ensures that the AML officers are able to fully discharge their obligations at all times.
  • Accessibility – the AML officer is always the main point of contact, as opposed to a junior support team member.
  • Very low risk of AML officer turn-over as the team members are carefully selected, well supported, heavily involved in the AML officer appointment process and fully understand the importance of consistency when appointed.
  • The individuals within the AML services team have many years of experience acting in the AML Officer roles for investment funds. The AML officers know exactly what is required in terms of money laundering (“ML“), terrorist financing (“TF“) and sanctions risk mitigation, ongoing reporting to fund boards, ML/TF risk assessments, data gathering and complying with regulatory obligations in an investment fund context.
  • On the ground presence in the Cayman Islands, Ireland and Luxembourg. This provides greater efficiencies when performing administrator on-site visits as they can be undertaken in person.
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The Team

Meet the AML team