INTRODUCTION

There have been several new regulatory developments over the past few months that potentially impact CLO transactions. The Maples Group is proactively monitoring and addressing these regulatory developments to ensure that our clients' CLO transactions are compliant with new requirements. This CLOser Look focuses on the implications of the recent regulatory developments on the CLO market in particular, and provides a gateway to the more general updates that have been issued by the Maples Group.

CAYMAN ISLANDS

EU AML LIST

As highlighted in the October 2021 CLOser Look, the EU Securitisation Regulation was amended on 9 April 2021 to prevent the use of SPVs from countries on the EU AML high-risk third countries list ("EU AML List"). The EU added several countries to the EU AML List, including the Cayman Islands, following the adoption of a Delegated Regulation, which came into force on 13 March 2022. The Maples Group has been proactively developing solutions for clients who are impacted. To date, we are finding that the preferred solution is to relocate affected transactions to Jersey. The Maples Group has a full service offering in Jersey that mirrors our Cayman Islands service offering to the CLO market. Our teams in the Cayman Islandt:s and Jersey have been working closely together to provide a seamless solution to clients whose transactions are impacted by the updated EU AML List.

Cayman Islands and the EU AML High-Risk Third Countries List

THE REGULATORY 15/15

The Reg 15/15 is a monthly 15-minute webcast released by our Cayman Islands Regulatory team on the 15th day of each month, providing timely updates on current regulatory developments. The March 2022 webcast covered the following topics:

  • Russia Sanctions
  • EU AML High-Risk Third Countries List
  • EU Tax List
  • DITC Portal Updates
  • CIMA Updates
  • VASP - Travel Rule
  • The Maples Group New Product

The webcast can be accessed on demand https://maples.com/en/knowledge-centre/2022/3/the-regulatory-1515-march-2022 here.

Please click here to view the full report.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.