INDEPENDENT OVERSIGHT.
GENUINE ASSURANCE.
Cayman Islands investment funds require qualified AML functionaries — an AMLCO, MLRO, and Deputy MLRO — with the independence, expertise, and seniority these roles demand. Daymer Group delivers hands-on, substantive AML officer services and decades of regulatory experience.
Where others confirm procedures are in place, we review, assess, and where necessary challenge. True compliance requires genuine independence — not oversight provided by the same firm administering your fund.
THE REGULATORY LANDSCAPE — WHY INDEPENDENT AML OFFICERS MATTER
A Tightening Regulatory Environment
Cayman Islands investment funds are required by law to appoint qualified AML functionaries — an Anti-Money Laundering Compliance Officer (AMLCO), a Money Laundering Reporting Officer (MLRO), and a Deputy MLRO. These are not ceremonial titles. They carry meaningful legal and regulatory weight under the Proceeds of Crime Act, the Anti-Money Laundering Regulations, and CIMA's Guidance Notes.
CIMA's expanding programme of thematic inspections and off-site reviews has placed these roles under increasing scrutiny. Funds that treat AML officer appointments as a box-ticking exercise are exposing themselves to significant regulatory and reputational risk.
The Independence Problem
The market has increasingly recognised the limitations of models in which AML officer functions are fulfilled by the fund administrator — creating a situation where the administrator, in effect, monitors its own activities. This is not a theoretical concern. It is a structural conflict of interest that undermines the very purpose of independent AML oversight.
"An independent AML officer provides the board with genuine oversight and a separate line of assurance. When the administrator monitors its own activities, who is watching the watchers?"
Key Regulatory Requirements
AMLCO: Responsible for establishing and maintaining the fund's AML/CFT compliance programme, ensuring policies and procedures are appropriate and effective.
MLRO: Receives and evaluates internal disclosures of suspicious activity, determines whether Suspicious Activity Reports (SARs) should be filed with the Financial Reporting Authority (FRA).
Deputy MLRO: Provides continuity and support, ensuring the MLRO function is never left vacant or under-resourced.
OUR AML OFFICER SERVICES — SERVICE OVERVIEW
Our AML officer services are tailored to the specific structure, strategy, and risk profile of each fund. We do not offer a one-size-fits-all package. Depending on the engagement, the scope of our services may encompass some or all of the following:
Compliance Oversight & Programme Development
Working with the fund's board and service providers to develop, implement, and maintain an AML/CFT programme appropriate for the fund's structure and aligned with applicable Cayman Islands law, the AML Regulations, and CIMA's Guidance Notes. This includes reviewing and, where required, assisting in the development of entity-specific AML policies and procedures — ensuring the fund has its own documented framework rather than relying solely on those of its service providers.
Fund Administrator Framework Review
Assessing the AML/CFT policies, procedures, and controls maintained by the fund administrator on which the fund relies for investor onboarding, customer due diligence, and ongoing monitoring. Our review considers whether those frameworks meet the standards expected under applicable law and whether any gaps or areas for enhancement should be brought to the attention of the board.
Investment Manager Monitoring Framework
Reviewing the measures implemented by the investment manager to monitor portfolio activity, investment counterparties, and transactional flows for AML/CFT purposes. We assess whether those measures are proportionate to the fund's investment strategy and risk profile, and provide observations to the board as appropriate.
MLRO Services
Acting as Money Laundering Reporting Officer, including receiving and evaluating internal disclosures relating to potential suspicious activity, determining whether reports should be made to the Cayman Islands Financial Reporting Authority (FRA), maintaining appropriate records of disclosures and decisions, and ensuring the board is informed of any material developments. Our MLRO function is discharged independently and with the seniority that the role demands.
Board Reporting & CIMA Liaison
Providing regular AML/CFT compliance reports to the board, keeping directors informed of material developments, regulatory changes, and any identified deficiencies. Acting as the primary point of contact for CIMA in connection with AML/CFT matters, including regulatory enquiries and inspections.
WHO WE SERVE
Our AML officer services are designed for:
• Cayman Islands investment funds (open-ended and closed-ended)
• Registered and regulated mutual funds
• Private funds under the Private Funds Act
• Fund management companies
• Master-feeder structures
• Segregated portfolio companies
• Other entities conducting relevant financial business
TECHNOLOGY-ENABLED COMPLIANCE — BOARDPILOT
Most AML service providers rely on manual processes, spreadsheets, and third-party tools they do not control. Daymer is different.
BoardPilot is our proprietary governance and compliance management platform, developed in partnership with CoBOS Technology. Purpose-built for the investment management sector, it brings AI-enabled automation to every aspect of AML compliance — from programme oversight to board reporting.
BOARDPILOT FOR AML COMPLIANCE
Compliance Calendar & Workflow Engine
Automated tracking of all AML-related deadlines, filing requirements, and review cycles. Never miss a CIMA submission or board reporting deadline.
Automated Programme Monitoring
Continuous monitoring of AML/CFT programme effectiveness with alerts when policies, procedures, or controls require updating.
Real-Time Compliance Dashboards
Live visibility into compliance status across all funds and entities. Board members and directors can access current AML standing at any time.
Secure Data Rooms
Encrypted storage for all AML-related documentation with granular access controls and comprehensive audit logging of every access event.
Regulatory Change Tracking
Automated monitoring of regulatory developments from CIMA, FATF, and other relevant bodies, with AI-generated impact assessments for your fund.
WHY INDEPENDENCE MATTERS — THE DAYMER DIFFERENCE
The market has increasingly recognised the limitations of models in which AML officer functions are fulfilled by the fund administrator — creating a situation where the administrator, in effect, monitors its own activities. An independent AML officer provides the board with genuine oversight and a separate line of assurance.
Daymer brings that independence alongside the deep jurisdictional knowledge and practical experience that effective discharge of these roles requires. Our AML officer services are designed to complement, not duplicate, the work of the fund's other service providers — adding a layer of substantive, experienced oversight that strengthens the overall governance framework and provides confidence to boards, investors, and regulators alike.
The Daymer Model
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Genuinely Independent: We are not a fund administrator. We have no commercial interest in the activities we oversee. Our only obligation is to the integrity of the compliance framework.
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Hands-On and Substantive: We do not rely solely on confirmations from fund administrators or investment managers that procedures are in place. We review, assess, and where necessary challenge.
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Complementary by Design: Our services are designed to complement, not duplicate, the work of the fund's other service providers — adding a layer of experienced oversight that strengthens the overall governance framework.
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Senior-Led: Our AML officers bring decades of combined experience in governance, compliance, and the Cayman Islands regulatory framework. These are not junior staff fulfilling a checklist.
Five Pillars of the Daymer Difference
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Genuine Independence. Daymer has no commercial interest in the activities it oversees. When we review your fund administrator's AML framework, there is no conflict. When we challenge a process, there is no commercial pressure to look the other way.
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Proprietary Technology. Daymer's BoardPilot platform was purpose-built for fund governance and compliance. It is not a bolt-on. It is not licensed from a vendor who serves your competitors. It is ours and we can tailor it to our clients requirements.
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Substantive, Not Ceremonial. Too many AML officer appointments are treated as a regulatory box-tick. Daymer's approach is hands-on and substantive. We review, assess, and where necessary challenge.
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Senior-Led, Multi-Jurisdictional. With a team of 16 professionals across multiple jurisdictions, Daymer brings genuine depth. Our AML officers are not junior staff working from checklists — they are experienced professionals with decades of combined experience in governance, compliance, and the Cayman Islands regulatory framework.
HOW IT WORKS — CLIENT JOURNEY
Discovery
We begin with a comprehensive assessment of your fund's structure, strategy, investment profile, and existing AML arrangements. We identify gaps, risks, and opportunities for strengthening your compliance framework.
Tailored Proposal
Based on our assessment, we develop a bespoke service proposal covering the specific AML officer roles, scope of oversight, and technology deployment appropriate for your fund.
Onboarding & Integration
Our team is formally appointed to the relevant AML officer roles. We deploy BoardPilot, conduct an initial comprehensive review of existing AML policies and procedures, and establish reporting protocols with the board.
Active Oversight
Ongoing, substantive AML oversight including programme monitoring, administrator framework reviews, investment manager assessments, MLRO functions, and regular board reporting — all powered by BoardPilot's AI-enabled platform.
Continuous Improvement
Regular reviews of programme effectiveness, regulatory change assessments, and proactive recommendations to keep your fund ahead of evolving CIMA expectations and industry best practice.
CALL TO ACTION & CONTACT
Your Fund Deserves Independent Oversight
In an era of increasing regulatory scrutiny, the choice of AML officer is not a formality — it is a governance decision with real consequences. Daymer Group brings the independence, expertise, and technology that effective AML oversight demands.
Whether you are establishing a new fund, reviewing your existing AML arrangements, or preparing for a CIMA inspection, we are ready to help.
Contact: martin.Laufer@daymer.group | www.daymer.group
Regulated in the Cayman Islands and Dubai
