Cayman Islands -- Travel Rule Implementation Regulatory Overview

Published: 2026-04-29 Updated: 2026-04-18 Author: Perplexity Sonar Version 1 Sources cited in: English (5), Spanish (1)

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The Cayman Islands has fully adopted and implemented the FATF Travel Rule under Part XA of the Anti-Money Laundering Regulations (as revised) (AMLRs), effective July 1, 2022.[1][2][3][4][5]

Key Details

Adopted and Effective Date: Adopted via the Anti-Money Laundering (Amendment) (No. 2) Regulations, 2020, with Part XA commencing on July 1, 2022. CIMA issued guidance requiring VASPs to submit compliance plans by March 31, 2022.[1][2][3][4]
Threshold Amounts: USD 0; applies to all virtual asset transfers, defined as any transaction on behalf of an originator to make virtual assets available to a beneficiary.[1][2]
VASPs Covered: All VASPs registered or applying for registration/licensing with the Cayman Islands Monetary Authority (CIMA), including obliged entities under the 2020 VASP Act (e.g., cryptocurrency exchanges, trading platforms, custodians). Covers transfers involving VASPs, other obliged entities, or non-obliged entities.[1][2][4][5]
Technical Implementation Requirements: VASPs must exchange specific originator and beneficiary data (e.g., identification, verification info) during transfers, maintain records for at least 5 years, and implement policies, procedures, and technological tools. Registrants submit compliance details to CIMA via email (vaspinfo@cima.ky) or REEFS portal (APP 101-84 Schedule E). Aligns with FATF Recommendation 16 and 2021 FATF guidance on private wallets, NFTs, and DeFi.[1][2][4][5]
Penalties for Non-Compliance: Not explicitly detailed in available sources; general AMLR penalties apply for breaches, with CIMA supervisory enforcement. Registration is mandatory for VASPs.[2]

Specific Legislation and Guidance

Primary Legislation: Anti-Money Laundering Regulations (as revised), Part XA; Anti-Money Laundering (Amendment No. 2) Regulations, 2020.[1][2][3][4]
CIMA Guidance: Travel Rule Requirements notice (Feb 22, 2022); Sector Specific Guidance on VASPs (Sept 2023 revision); Guidance Notes on Prevention of Money Laundering/ Terrorist Financing (amendments).[2][4][5]
Key Sources: CIMA official page at https://www.cima.ky/travel-rule-requirements-for-vasp[4]; Cayman Finance overview at https://caymanfinance.ky/2025/01/06/virtual-asset-service-providers-and-the-travel-rule/[1]; 21 Analytics summary at https://www.21analytics.co/travel-rule-regulations/cayman-islands-travel-rule-regulation/[2]. No updates post-2023 indicate ongoing compliance as of 2026.[1][5]