The Cayman Islands Monetary Authority’s (CIMA) updated AML rules, which came into force on 18 September 2026, place greater focus on the requirement for Cayman private funds to undertake independent AML audits.
Langham Hall can undertake these audits for eligible Cayman private funds, complementing the fund administration and AML services we already provide.
A coordinated approach to your AML audit
An independent AML audit should provide the fund’s governing body with an objective assessment of whether its AML framework, policies, procedures and controls are appropriate and operating effectively. Our review is tailored to each fund’s circumstances and risk profile.
For existing clients, our teams can coordinate efficiently on administrative matters and the provision of relevant information.
How independence is maintained
CIMA permits an independent AML audit to be performed by an internal audit function, provided sufficient independence is demonstrated. Where Langham Hall already provides services to a fund, our audit approach has been structured with safeguards designed to preserve the objectivity of the review. In particular:
- Separate audit function: The audit will be led and conducted by personnel who are separate from the teams responsible for investor onboarding and day-to-day AML compliance activities, and who have not been involved in the design, operation, management or oversight of the AML controls being reviewed (the “Audit Team”).
- No financial or governance interest: Langham Hall and the Audit Team do not hold a directorship, ownership interest or control in the fund.
- Independent reporting: The Audit Team communicates its findings directly to the fund’s governing body, without requiring prior notification, discussion or approval from the teams responsible for day-to-day compliance activities.
The audit is overseen by a CPA with extensive Cayman private fund industry experience, who undertakes Cayman AML training regularly and keeps abreast of AML, CFT, CPF and CIMA regulatory developments.
How Langham Hall can help
Our audit covers relevant areas of the fund’s AML framework and internal governance, with findings and practical recommendations for consideration by the fund’s governing body.
To discuss the applicability of the requirements to your fund, the anticipated timeline, audit scope and fees, please contact aml.asia@langhamhall.com.
