In accordance with Regulation 55A of the Anti-Money Laundering Regulations (“AMLRs”), all firms of attorneys at law operating in the Cayman Islands are required to register with the Legal Services Supervisory Authority (“LSSA”) as a Designated Non-Financial Business or Profession (“DNFBP”).

Firms of attorneys at law are defined by the AMLRs as:

i. a body corporate, association, partnership, or limited liability partnership of attorneys who are admitted to practice law in the Cayman Islands; or
ii. an attorney admitted to practice law in the Cayman Islands who is in independent practice as a sole proprietor or who provides legal services to an employer other than the Government.

What is a DNFBP?

The following types of businesses have been identified as DNFBPs in the Cayman Islands:

  • Real estate agents and brokers

  • Dealers in precious metals and precious stones
  • Firms of accountants
  • Firms of attorneys at law
  • Any other business assigned a Supervisory Authority under Regulation 55B of the AMLRs.

Registration with the LSSA

In accordance with Regulation 55E of the AMLRs, the LSSA is required to maintain a register of DNFBPs.

All firms of attorneys at law operating in the Cayman Islands, including sole practitioners, must register with the LSSA.

As part of the registration process, the LSSA may request documents, statements or other relevant information in accordance with its authority under Regulation 53AA of the AMLRs, to determine whether the firm is conducting relevant financial business.

Firms Conducting Relevant Financial Business (“RFB”)

Firms of attorneys at law, including sole practitioners, conducting relevant financial business must register with the LSSA using the RFB Registration Form, available in the Forms Library.

Under Schedule 6 of the Proceeds of Crime Act (2024 Revision), RFB includes legal services provided in the course of business relating to:

  • The sale, purchase or mortgage of land or interests in land on behalf of clients or customers;
  • Management of client money, securities or other assets;
  • Organisation of contributions for the creation, operation or management of companies;
  • Management of bank, savings or securities accounts; and
  • Creation, operation or management of legal persons or arrangements, and buying and selling of business entities.

RFB Registration Requirements

Firms conducting relevant financial business must submit RFB Registration Form along with the following supporting documents, where applicable:

  • Certificate of Incorporation
  • Register of Directors & Officers
  • Register of Members/Shareholders

  • Memorandum & Articles of Association

  • Partnership Agreement
  • Certification as a Recognised Body
  • Operational Licence
  • Business Structure / Organisational Chart
  • Professional Indemnity Insurance

Fit and Proper Person Assessment

As part of the registration process, all persons conducting RFB or considered connected persons of the registrant firm are subject to a fit and proper person assessment by the LSSA.

Connected persons are defined as managers, directors, company secretaries, senior executives and beneficial owners. This assessment is conducted in accordance with Regulation 55H of the AMLRs, which sets out the criteria used to determine whether an individual is suitable to hold a position of responsibility within a DNFBP engaged in RFB.

Firms must consider that managers under the connected persons definition include the designated Anti-Money Laundering Compliance Officer (“AMLCO”), the Money Laundering Reporting Officer (“MLRO”) and the Deputy Money Laundering Reporting Officer (“DMLRO”), collectively referred to as AML Officers. Sections 3(1) and 33 of the AMLRs require that these roles be employed at managerial level.

When evaluating fitness and propriety, the LSSA will consider the following factors:

  • The person’s probity, competence and soundness of judgement for fulfilling the responsibilities of the position;
  • The diligence with which the person is fulfilling or likely to fulfill the responsibilities; and
  • Whether the DNFBP’s interests are, or likely to be, in any way threatened by the person holding the position.

If the LSSA determines that a person is not fit and proper, it may take supervisory action, including the revocation of the firm’s registration under Regulation 55G of the AMLRs.

Firms are expected to conduct their own due diligence on all relevant persons prior to submission and must disclose any material information to the LSSA as part of the registration and ongoing compliance process.

Ongoing Reporting Obligations of RFB Firms

The registration of firms conducting RFB with the LSSA is a mandatory one time process. However, registered firms must remain compliant with ongoing reporting obligations and notify the LSSA of any material changes, including:

  • Name change;
  • Change of business address;

  • Change in the firm’s risk assessment; and

  • Changes to connected persons as defined above.

The relevant forms for reporting these changes are available in the Forms Library. Firms are expected to conduct their own due diligence on all relevant persons and must disclose any material information to the LSSA as part of the registration and ongoing compliance process.

Firms That Do Not Conduct Relevant Financial Business (Non-RFB)

Law firms that do not currently conduct, and do not intend to conduct RFB as defined under the AMLRs are still required to register with the LSSA.

Such firms must complete the Non-RFB Registration Form, available in the Forms Library

Annual Declaration Requirement

Once registered, firms classified as non-RFB must submit an annual declaration confirming their continued non-RFB status. This declaration is due by 31 December annually.

The LSSA reserves the right to request additional information or clarification regarding the nature of a firm’s business. Any such inquiries will be made in writing, in accordance with Section 53AA of the AMLRs.

Changes in Business Activity

If a non-RFB firm’s circumstances change—particularly if it intends to begin conducting relevant financial business—the firm must notify the LSSA within 30 days, as required under Regulation 55MA of the AMLRs.

Such changes must be reported using the Material Change Form, which should be submitted electronically to supervision@caymanlssa.ky. In addition, the firm will be required to complete and submit the RFB Registration Form.

Firms are strongly encouraged to review their service offerings regularly and ensure timely and accurate reporting of any changes in risk exposure.

Registration Help & Guidance

All registration forms should be completed electronically, wherever possible, and submitted to the LSSA by:

Please ensure that all forms are submitted with the required supporting documentation, as specified on each form.