In June 2021, following action by the Financial Action Task Force (FATF) we published a briefing outlining concerns that AML-related actions of the EU might make it more difficult for European entities to deal with Cayman securitisation SPVs.
In a document dated 7 January, the European Commission has proposed to add the Cayman Islands to its list of jurisdictions which have strategic deficiencies in their Anti-Money-Laundering / Counter Terrorist Financing (AML/CFT) regimes that pose significant threats to the financial system of the EU.
In this briefing we set out the next steps and possible consequences for EU entities who have relationships with Cayman securitisation SPVs. We also consider the implications for non-EU sponsors of Cayman securitisation SPVs that seek EU investors.