FINANCIAL REPORTING AUTHORITY

(CAYFIN)
Delivery Address:
133 Elgin Ave, 4th Floor
Mailing Address:
Government Administrative Building
P.O. Box 1054
Grand Cayman
Grand Cayman KY1-1102
Cayman Islands
Cayman Islands
Tel No. (345) 945-6267
Fax No. (345) 945-6268
E-mail: [email protected]

COMPLIANCE REPORTING FORM

 This form should be used to report all compliance-related information to the Financial Reporting
Authority (FRA) including information regarding suspected designated persons (Part B); assets you
have frozen (Part C); and suspected breaches of financial sanctions (Part D).

 Please note that the information you provide may be shared for the purpose of facilitating or
ensuring compliance with financial sanctions regulations, in accordance with the FRA’s information
sharing powers.

 Annexes B and C to this form provide key terms and information to assist you in completing your
report.

 Your financial sanctions reporting and compliance obligations are described in FRA’s Industry
Guidance. You should consult this guidance prior to completing this form. You should note that for
some businesses there is a legal obligation to report, and that not doing so is a criminal offence:

 Please ensure that when you complete this form, you believe that the facts and information provided
in this form are accurate and true to the best of your knowledge.

 You should note that a criminal offence may be committed if you contravene any of the prohibitions
in respect of the financial sanctions regime(s) detailed in part 12 below, or you intentionally
participate in activities knowing that the object or effect of them is to circumvent any of those
prohibitions or enables or facilitates the contravention of any of those prohibitions.

 Please email completed forms, including any associated documents, to [email protected]

with “SUSPECTED DESIGNATED PERSON”, “FROZEN ASSETS”, or “SUSPECTED BREACH” as applicable in
the subject line.
 Alternatively, completed forms can be posted to:

The Sanctions Coordinator

Financial Reporting Authority
P.O. BOX 1054
Grand Cayman KY1-1102
Cayman Islands

If you are unsure of your compliance or reporting obligations under financial sanctions, you should
seek independent legal advice.

PART A: GENERAL INFORMATION

Please complete this part of the form and indicate what you are reporting on.

1. Person submitting this report

a. Name (Including title)

b. Job title

c. Company / organisation

d. Address

e. Contact number(s)

f. Email address

2. Date submitted
(dd/mm/yyyy)

Yes
3. Are you submitting this form on behalf of a third party? Tick box
No

If yes, please provide the third

party’s contact details, including
their Group ID if they are a
designated person.

4. What are you reporting? Tick all applicable

Suspected designated person [please complete Part B of this form]

Frozen assets [please complete Part C of this form]

Suspected breach [please complete Part D of this form]

PART B: REPORTING A SUSPECTED DESIGNATED PERSON

This part should be used to report your knowledge or suspicion that an individual, business or
organisation is a designated person and therefore subject to financial sanctions. Please
complete a separate form for each designated person on whom you are reporting.

Your report should include information by which a designated person can be identified. For
example, aliases or alternative identities that could be used to evade sanctions.

If you are also reporting that you have frozen the assets of a designated person, please
complete Part C of this form. If you are also reporting a suspected breach of financial
sanctions, please complete Part D of this form.

5. Suspected designated person (including persons owned or controlled by them)

a. Group ID from the

consolidated list

b. Name of the designated

person as given on the
consolidated list

c. Name of the person/entity

if owned/controlled by a
 designated person

6. Information on which your knowledge or suspicion is based

Please provide as much detail as possible, including your relationship
a. What has caused you to
with the person, what information you hold and how it came to you.
know or suspect that the
person you are reporting
on is a designated person
(or is owned/controlled by
one)?
e.g. new aliases, dates of birth, addresses, passport numbers,
b. Please provide any
additional trading names, etc.
information not already on
the consolidated list by
which the designated
person can be identified

PART C: INFORMATION ON FROZEN ASSETS

This part should be used to report that you have frozen the assets of a designated person.
Please complete a separate form for each designated person whose assets you have frozen.

If you know or suspect that a person is a designated person, please complete Part B of this
form. If you are also reporting a breach of financial sanctions, please complete Part D of this
form.

7. Designated person (DP)

a. Group ID from the

consolidated list

b. Name of the designated

person as given on the
consolidated list
c. Name of the person/entity
if owned/controlled by a
designated person

8. Please provide information on all funds and economic resources you have frozen ( For
definitions and guidance on what to include please see Annexes B & C.)

Part D: INFORMATION ABOUT A SUSPECTED BREACH

This part should be used to report any suspected or known breach of financial sanctions. Please
complete one form for each overarching activity. Multiple transactions/transfers relating to an
overarching activity may be listed in one form.

Your report should include all known details in relation to the suspected breach activity.
Additional supporting material should be attached to your submission and noted in section 22.
Where information is not known or not applicable, please state.

9. Who do you suspect has committed, or has attempted to commit, the suspected breach?
Please provide details
10. Summary of facts
Including the date(s) the suspected breach (or breaches) was discovered, how it was discovered, and
the series of actions that led to a suspected breach taking place (where known).

11. Does this information relate to a suspected completed, or suspected attempted, breach?
Tick box
Completed

Attempted (including blocked or rejected activity)

12. Financial sanctions regime(s) under which the suspected breach has occurred
The list of all financial sanctions regimes in effect in the UK can be found on OFSI’s on GOV.UK:
https://www.gov.uk/government/collections/financial-sanctions-regime-specific-consolidated-
lists-and-releases

Additionally, the list of all financial sanctions regimes in effect in the Cayman Islands can be found
on the FRA website:
http://fra.gov.ky/contents/page/1
 a. Financial sanctions regime(s)

b. Act/Regulation(s) (if known)

c. Relevant section(s), article(s),

regulation(s) suspected of
having been breached (if
known)

DETAILS OF SUSPECTED BREACH

See Annex B for a description of what can constitute funds, economic resources, and financial
services.

13. What does the suspected breach involve: Tick all applicable

Funds

Describe, in full, the type(s) of

funds involved.

Economic resource(s)

Describe, in full, the economic

resource(s) involved.

Financial Services

Describe, in full, what the

financial services are, including
how and when they were
provided.

Licence conditions

Give the licence condition(s)

and describe, in full, how you
suspect it has been breached.
 Please include the licence no.

Reporting obligations

Give the reporting obligation

and describe, in full, how you
suspect it has been breached.
Please include the licence no.
where relevant.

14. Total value of the suspected breach (actual or estimated)

Please provide this information in the currency that was used at the time of the transfer (or provide
an estimated value in KYD if unknown).

15. Method(s) of payment and/or transfer

e.g. bank transfer, cash, cheque, money order, internet/electronic, or physical asset transfer – road,
rail, air, sea, etc.
 16. Remitter/sender information
Please provide full information
on the remitter/sender of the
funds and/or economic
resources, including: dates,
goods involved, amount(s),
currencies, account names,
account numbers and sort
codes, bank details, and
nationalities of payers, dates of
birth, where known.

If more space is required, please complete Annex 1 (A1), or attach supporting documents with
your submission.

17. Intermediary information

Please provide any information
you have on intermediaries
involved in the activity,
including: role in transfer,
name(s), date of birth, company
registration information, country
of operation/nationality,
address/location, account name,
account number and sort code
and bank details, where known.

If more space is required, please complete Annex 1 (A2), or attach supporting documents with
your submission.

18. Ultimate beneficiary information

Please provide information on the
ultimate beneficiaries of the funds
and/or economic resources,
including: name, account name,
account number and sort code,
bank details, residential/company
address, date of birth and
nationality, where known.

If more space is required, please complete Annex 1 (A3) or attach supporting document(s) with
your submission.

19. Please list all external parties who have been made aware that this information is being
passed to FRA, including any designated persons

20. Has this matter been reported to any other authority?

If so, please provide their contact details.

21. Other relevant information

Please provide any other information you think will help us understand what has happened
 Yes
22. Are you providing any supporting documents?
Please include any documents that support the information provided, such
No
as bank statements, transaction reports, copies of licences, paperwork,
contracts, etc. including those from other jurisdictions.

Please list the supporting

documents you are
providing.
 Compliance Reporting Annex A
Additional remittances (for Section 15 Remitting information)

A1. Additional remittance information

Additional intermediaries involved (for Section 16 Intermediary information)

A2. Additional intermediaries

Additional beneficiaries involved (for Section 17 Ultimate beneficiary(ies) information)

A3. Additional beneficiaries

Compliance Reporting Form Annex B
This Annex describes some of the common terms used in financial sanctions legislation.

Designated Persons

A designated person is an individual, entity or body, listed under EU or UK legislation as being

subject to financial sanctions.

The list of designated persons can be found on Office of Financial Sanctions Implementation (OFSI)
consolidated list of asset freeze targets here:

https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-oftargets

Note that the financial sanctions also apply to persons and entities that are owned or
controlled, directly or indirectly, by a designated person. Those persons or entities may not be
designated in their own right, so their name may not appear on the consolidated list. However,
those persons or entities are similarly the subject of the financial sanctions. For more
information on ownership and control see the FRA’s Industry Guidance on Financial Sanctions.

Funds

Funds means financial assets and benefits of every kind, including but not limited to:

 Cash, cheques, claims on money, drafts, money orders and other payment instruments;
 Deposits with financial institutions or other entities, balances on accounts, debts and
debt obligations;
 Loans and mortgages;
 Publicly and privately traded securities and debt instruments, including stocks and
shares, certificates representing securities, bonds, notes, warrants, debentures and
derivatives contracts;
 Interest, dividends or other income on or value accruing from or generated by assets;
 Credit, right of set-off, guarantees, performance bonds or other financial commitments;
 Letters of credit, bills of lading, bills of sale;
 Documents evidencing an interest in funds or financial resources;
 Any other instrument of export-financing.
Economic Resources

Economic resources mean assets of every kind, whether tangible or intangible, movable or
immovable, (such as goods, property, or rights) which are not funds themselves but which can
be used to obtain funds, goods or services.

Group ID

All reports to the FRA involving a designated person should include their ‘Group ID’ reference
number. The Group ID is a unique identifier for a designated person which can be found in their
entry on the consolidated list.

https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets

Financial Services

Financial services mean any service of a financial nature, including, but not limited to:

 Insurance-related services consisting of:

o Direct life assurance;
o Direct insurance other than life assurance;
o Reinsurance and retrocession;
o Insurance intermediation, such as brokerage and agency;
o Services auxiliary to insurance, such as consultancy, actuarial, risk assessment
and claim settlement services.

 Banking and other financial services consisting of:

o accepting deposits and other repayable funds;
o lending (including consumer credit, mortgage credit, factoring and financing of
commercial transactions);
o financial leasing;
o payment and money transmission services (including credit, charge and debit
cards, travellers' cheques and bankers' drafts);
o providing guarantees or commitments;
o financial trading (as defined below);
 o participating in issues of any kind of securities (including underwriting and
placement as an agent, whether publicly or privately) and providing services
related to such issues;
o money brokering;
o asset management, such as cash or portfolio management, all forms of collective
investment management, pension fund management, custodial, depository and
trust services;
o settlement and clearing services for financial assets (including securities,
derivative products and other negotiable instruments);
o providing or transferring financial information, and financial data processing or
related software (but only by suppliers of other financial services);
o providing advisory and other auxiliary financial services in respect of any activity
listed in sub-paragraphs (i) to (xi) (including credit reference and analysis,
investment and portfolio research and advice, advice on acquisitions and on
corporate restructuring and strategy).

 “Financial trading” means trading for own account or for account of customers, whether
on an investment exchange, in an over-the- counter market or otherwise, in:
o money market instruments (including cheques, bills and certificates of deposit);
o foreign exchange;
o derivative products (including futures and options);
o exchange rate and interest rate instruments (including products such as swaps
and forward rate agreements);
o transferable securities;
o other negotiable instruments and financial assets (including bullion).
Compliance Reporting Form Annex C
Frozen accounts

All reports of frozen accounts should include the following information:

 Name of financial institution holding the account

 Account name
 Details of the account holder
 Date account frozen
 Type of account
 Account number
 Sort code (where relevant)
 Credit balance
 Debit balance
 Currency
 Date account opened
 Any other relevant information relevant to the freezing of the account

Frozen payments / transactions

All reports of frozen payments or transactions should include the following information:

 Details of the institution/person who has frozen the transaction

 Details of their role in the transaction
 Date of transaction (Inc. amount and currency)
 Date transaction frozen
 All relevant account details (originator, intermediaries, beneficiary)
 Details of the originator of the transaction (name, address, etc.)
 Details of the originating financial institution (name, address, etc.)
 Details of any intermediary financial institutions (name, address, etc.)
 Details of the beneficiary of the transaction (name, address, etc.)
 Details of the beneficiary financial institution (name, address, etc.)
 Any additional information found in the originator-to-beneficiary or bank-to-bank
information
 Any other additional information relevant to the freezing of the transaction, including
the payment instruction where available