On 29 December 2023, CIMA published the supervisory circular describing how it monitors AML/CFT remediation by financial service providers (“FSPs”) and sets out the key elements of a successful remediation plan. FSPs may use this publication to strengthen their respective compliance programmes and to ensure that any remediation plans they deploy are effective, adequate and meet regulatory requirements.

 The full circular can be found in this link AML/CFT Remediation (cima.ky).

 Observation and recommendations

Supervisory circulars provide good guidance to regulated entities, and offer access to CIMA’s practical approach to inspections as well as the process of addressing regulatory comments.

 Recommended actions include:

  1.  Review circular and determine whether it requires any updates to your policies.
  2. As stated in the circular, regulated entities should use the publication to review their internal compliance programs.