Real estate still poses high risk of money laundering

| 05/08/2022 | 138 Comments

(CNS): More than 40% of property developers and real estate agents selected last year by the Department of Commerce and Investment for inspection for their anti-money laundering processes were found to be non-compliant with the regulations. According to both the DCI’s 2021 Supervisory Report and the National Risk Assessment 2021, which have both been made public, the local property sector remains highly vulnerable to both money laundering and terrorist finance abuse, given the lack of restrictions on foreign ownership.

In May last year, CNS reported on the risk property development poses, creating a weak link in Cayman’s anti-money laundering regime. However, it appears from these latest reports that work is still needed to address the vulnerabilities.

Real estate agents provide money launderers with the appearance of respectability and normality for large transactions, which frustrates detection and investigations, the 2021 NRA report said. Property here is a very high-value commodity that is attractive for both money laundering and the investment of criminal proceeds. And there are a large number of transactions involving overseas buyers, which the risk assessment found provides fertile ground for laundering cash.

The property sector is seen as even more high risk here than dealers in precious metals and stones and jewellery shops, despite their inherent appeal to financial criminals given the high value and portability of the goods. Those dealers have mitigated their risk by sourcing inventory from reputable entities with GIA certificates and selling face-to-face to customers, primarily from cruise ships.

The DCI supervises precious metal and stone dealers as well as real estate agents and developers, collectively known as Designated Non-Financial Business and Professions (DNFBPs). Of the two categories, property dealers face a greater risk of abuse because of the more complex nature of their business.

Of the DCI’s 60 inspections last year, just four were of jewellery dealers; the rest were property related. Of those, just one entity was completely compliant with the rules and 22 were only partially or non-compliant. The report does not differentiate between the two categories, but given the domination of the property sector in the reviews, it appears that the failings documented by the DCI were largely down to realtors or developers

Of the long list of compliance requirements checked, 23 entities failed to properly collect and maintain Customer Due Diligence records, 46 failed to carry out an independent audit of their systems, 18 had no effective staff training, 22 had no or deficient policies to screen new workers, 12 could not vet clients against sanctions lists and 19 had no monitoring systems in place against potential financial abuse.

“The Inspection Teams continue to find some deficiencies,” the DCI found, with the most significant being the lack of procedures to train new employees and to conducted independent audits They also found that in several cases there was no one in the organisation who was responsible for anti-money laundering prevention. Although things have improved since 2019, the DCI said, “The Non-Compliant registrants remain a concern and improvement plans have been implemented.”

According to the NRA report, there are 164 property developers and real estate agents that are classified as DNFBPs. The report concluded that Cayman’s real estate sector is vulnerable to abuse as the exposure to international influences is significant.

“The appeal of Cayman Islands real estate to High-Net-Worth and Ultra High-Net-Worth international purchasers and investors for development is particularly noteworthy, given the risk that the local market may be abused by foreign criminal elements,” the report stated.

“It is not uncommon for a nominee to be used and the beneficial owner to be added to the sale and purchase agreement at the last minute,” the authors said and explained how buyers can place a purchase in the name of a trust. “This presents challenges in identifying the true beneficial owner or effective controller of the customer,” they stated.

See the reports below:


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Category: Business, Financial Services, Real Estate, Retail

Comments (138)

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  1. Anonymous says:

    I’m no fan of parasitic realtors but fail to see how it’s their job to police their clients. If the money is in the client’s bank, the kyc/aml has been done already by the bank. AML compliance is no more a realtor’s job than it is a supermarket’s job to document where your money came from. In any event if a crook can get their money into the banking system they can certainly get is past a bar tender turned realtor.

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    • Anonymous says:

      You are being simplistic and limiting your thinking to the placement stage of laundering. A transaction in real estate can easily be part of the layering or integration stages. The best banking AML in the world isn’t going to detect the fact that the money coming in from a layered account is then used to acquire a property for someone completely different from the supposed owner of the funds now, is it?

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    • Anonymous says:

      Anyone engaging in multi million dollar transactions needs to be competent enough to do due diligence. Additionally facilitating Igor accepting criminal proceeds is a crime. So i am not sure you really have a point.

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  2. George Ebanks. says:

    Say what you want about realators, Kass Coleman is the best and always goes the extra mile!

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    • Anonymous says:

      I wasnt sure if “George Ebanks” was a real person or a troll account. Finally we know for sure.

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    • NWisdom says:

      Not sure about that. What about the man in Heroe’s square. He sold swamp like it had gone out of style. He could sell fridges to Eskimos as well as the same land twice. What a guy, him and Jimmy Hoffer. I always wondered what happened to Jimmy.

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    • Anonymous says:

      If I were KC, I wouldn’t be thrilled with that endorsement.

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    • Anonymous says:

      George, agreed she is wonderful. She assisted my family is finding the perfect family home some years ago. She listens to your needs and helps to guide you through the process. Truly such a gem. While there are some awful realtors out there. She is not one of them.

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  3. Anonymous says:

    What’s all the new car rental companies about? Money laundering or PR points – or both?

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    • Anonymous says:

      They sold them all during covid, but they should remove the stickers

      • Lomart says:

        There are quite a number of new names in the rental car business. I too am wondering about the reason for that. The big names sold off quite a number of their fleets during the border closure and I guess that somehow gave the springboard for new ones to set up?

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    • Anonymous says:

      What about all the radio stations? Look into that too.

    • Anonymous says:

      Something weird going on. Half the knackered old Honda Fit’s running round Westbay are hire cars being driven by locals/residents not tourists. Every one seems to be from a different rental company you never heard of too.

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    • Anonymous says:

      Jamaican hair and nail salons, “bakeries”…

  4. Sea Wood says:

    Is there a list of the Realtors subject to this investigation?

    I would like to add one.

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    • Anonymous says:

      Will some agency please confiscate these realtors signs blocking sidewalks?

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    • Anonymous says:

      All realtors are subject to AML compliance and thus the investigation. If you are wanting the list of those companies which were noncompliant, I doubt we, the public, will ever see that. We might eventually find out if some are prosecuted and convicted.

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  5. Anonymous says:

    There are now some young, well educated and professional Caymanians who have started their real estate careers.This is refreshing because most real estate agents in Cayman are foreigners.Recently i came across the social media posts of a young foreigner, who just got a work permit to work with a major real estate brand here, and I was shocked. Shocked that it is being allowed as her posts appear flirtatious and suggestive.Makes you wonder what else is she selling! It is disgraceful that the brokers are allowing it. Watch her soon have Caymanian Status. Only in Cayman!

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    • Anonymous says:

      A young woman, and her social media postings are flirtatious! Outrageous. Nothing of course to do with her job, and you then suggest she is selling sex. Wow. Just wow.

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  6. Anonymous says:

    Where is CIMA too? These development presales that get flipped several times before actual delivery is more like a stock/security than real estate.

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    • Anonymous says:

      What about overseas lawyers faciliting?

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    • Fact Checker says:

      CIMA does not regulate the real estate industry in the Cayman Islands.
      That is the responsibility of DCI and Ministry of Commerce.

      • Anonymous says:

        What is suggested is pre-construction real estate offerings tend to have features typically subject to oversight by a securities regulator.

  7. SJames says:

    Anyone thought of the biggest laundries for pure cash. Well think about if.
    Try the churches. Every Sunday. Cash. Cash. Cash.
    Any audit? No. Any money laundering officers? No.
    Any music and dancing licence? No.
    The money laundering laws are selective make no mistake.

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    • Anonymous says:

      And, 9:59, what about all the new church buildings? There’s a huge one going up on the Anton Bodden Bypass in Bodden Town: XXXXXX. Why are these new churches in a country that already has far too many being allowed?

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    • Anonymous says:

      So are persons wrong for giving tithes and offerings to God?

      Are criminals and law abiding citizens wrong for washing clothes?

      Where do we, as a society, draw the line?

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    • Anonymous says:

      Your last sentence is correct.

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  8. Math is hard says:

    Of the DCI’s 60 inspections last year, just four were of jewellery dealers; the rest were property related. Of those, just one entity was completely compliant with the rules and 22 were only partially or non-compliant.

    So DCI did 56 non-jewllery inspections. Of those only 1 was compliant while 22 were partially or non-compliant.

    Is there a category missing or what was found in the other inspections?

    CNS: The other category is ‘largely compliant’. The full report is right there if you want more details.

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  9. Anonymous says:

    Real Estate has always been the money launderers friend. It’s also a prime target for those wanting to ‘lose’ tax money from national exchequers.

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  10. Anonymous says:

    Seems that DCI is job for the boys… no substance. Keeps a few employed… the banks and financial institutions are the ones that should be tracking the money. Poor old estate agents have not got the access to the info that the banks have. But anyone dealing with cash warrants a SAR!

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  11. Anonymous says:

    What about these car dealers and boat sellers do they have to do DD? Plenty of cash going their way.

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  12. Anonymous says:

    DCI too busy fining Sunday music violators, that they can’t pull or suspend these noncompliant real estate T&BLs? Great work, take the rest of the year off.

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  13. Anonymous says:

    realtors only care about 1 thing: their commission.
    couple that with their lack of education/qualifications generally and you have a recipe for disaster.

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    • Anonymous says:

      Generally true 5/8 1:27 pm but I have noticed that ReMax has at least two young Caymanians with master degree level education. Both from reputable universities. I had the pleasure of dealing with one of them at a recent open house event and was surprised to later read on the website that she is very new at this! Although I did not purchase she was helpful and very professional. I will certainly reach out to her again should I need a realtor! Hopefully other young Caymanians of this caliber will follow in real estate careers.

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  14. Anonymous says:

    Something regarding the reports and risk assessments amounts to a crock of dung.
    In light of the fact that banks/financial services providers in the Cayman Islands, USA, EU, and other compliant countries have very strict measures in place to verify the source of funds and customers, and considering that virtually 100% of funds involved in broker-assisted property sales here involve fund transferred by/through those highly-regulated banks/financial services providers, by the time funds reach the broker and their clients here, a vastly substantial amount of scrutiny is involved. The reality is, gone are the days of people hopping off private jets carrying briefcases of cash.
    The real estate broker transactions can pose no more threat than allowed by the financial institutions involved in the funds transfers/deposits. If the banks miss potential money launderers and funders of terrorism and their dirty money, it would be damn near impossible for the brokers to identify them.

    Of course the government agencies involved are going to blow things out of proportion and publish reports and risk assessments with sensationalist data in order to inflate their own importance.

    The reports referenced fail to elaborate about the incredible amount of scrutiny involved in funds transferred from regulated foreign banks/financial services providers to banks/financial services providers and customers in the Cayman Islands. That is a glaring and stinking omission!

    A prudent follow-up article would include the following information:
    1. How many money launders and funder’s of terrorism have been caught at the real estate broker level–the ones who managed to get past financial institution scrutiny?
    2. Compare the numbers between brokers with a high degree of compliance versus those with a low degree of compliance.
    3. Give us some insight into the compliance requirements and audits done in regard to private transactions that involve non-broker-assisted sales.
    4. Does the Department of Commerce and Investment even bother to investigate/audit non-broker-assisted sales? People owning multi-million-dollar properties selling to individuals could be a splendid outlet for dirty funds.
    THOSE would be interesting bits of information. I seriously doubt that the Department of Commerce and Investment has compiled those statistics or does audits on private sales not involving brokers. If they do not, they are not doing their job. No surprise there if they don’t. That is the norm for government agencies in the Cayman Islands: make work for themselves, often tout their own importance, and grossly under-perform.

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    • Anonymous says:

      This is actually a sensible comment – provided that there is no cash and crypto involved in these sales I agree that the banks should be the ones responsible for verifying source of funds.

      Do we really expect / want real estate brokers to employ compliance departments to scrutinize the source of funds of their clients? It’s not reasonable to expect them to have the expertise or the resources to do this. It should fall to the banks to do this.

      AML outside the banks is like the TSA – it’s mostly theatre that comes at a considerable cost to the 99% of honest people trying to conduct businss.

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      • Anonymous says:

        So what happens if it is a cash deal? No bank required.

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        • Anonymous says:

          Cash transactions in real estate should be illegal.

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        • Anonymous says:

          Have you ever tried depositing a large amount of cash into the bank? It’s an absolute pain and it wasn’t even that much.

          • Anonymous says:

            Depends if you have copy of a bank draft or cheque, which was cash (not deposited), that explains source of funds. No problem then.

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        • Anonymous says:

          Like literal cash? In a suitcase? That would be a major red flag. All cash deals still involve bank accounts to transfer the funds in legit transactions…

        • Anonymous says:

          What happens if they don’t use agents. So no escrow of any kind. One guy hands a briefcase of cash to the other.

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          • Anonymous says:

            @3:35:
            EXACTLY!
            Transactions between private sellers CAN involve hard cash with no oversight whatsoever, unless the cash recipient tries to deposit the funds in a lump sum. CIREBA-affiliated brokers have very strict compliance requirements. But yet the government reports pick on broker-assisted sales. That is moronic! Talk about straining at a gnat and swallowing a camel!

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          • Anonymous says:

            You need a cash business to bank a lot of suitcase cash. A liquor store or bar can work.

        • Anonymous says:

          So where does this person put the cash? under his mattress..Such Stupidity! Banks will not let you deposit anything but small amounts in cash..Try walking into any bank with $500K in cash and see how far you get..

  15. Anonymous says:

    And Im other news, the sun rises in the east

    You do realize what’s going on with all the empty smb condo flipping?

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  16. Anonymous says:

    What about all the Stratas on SMB who launder money for their owners who do vacation rentals. They do Not have local bank account but can use the strata accounts to do so. They are not monitored by anyone. An easy way to launder money no one would suspect it!

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    • Anonymous says:

      Given the strata fees get expenses rather than returned or produce a saleable asset, it would be a fairly stupid way to launder money.

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    • Anonymous says:

      All unlawful under our domestic laws as no Trade and Business licenses and often no Caymanian participation. All reported for multiple years and the authorities do NOTHING. They are complicit.

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      • Anonymous says:

        Cayman stratas are exempt from TBL.

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        • Anonymous says:

          Not if they are operating a Trade or Business.

        • Anonymous says:

          Not if they are engaging in the provision of services to third parties, or operating a hotel. But let’s not worry about that. Our laws are an irrelevance, used rarely but even then to get someone who has stepped on the wrong toes. We are corrupt.

  17. Anonymous says:

    There are so many ethically challenged people people working in the real estate industry that none of this comes as a surprise to me. It would not surprise me if a large portion of the upscale real estate market respesents money from less that fully clean sources.

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    • Anonymous says:

      Since the vast majority of funds involving real estate sales passes through local financial services providers, if the money is dirty, those providers have failed in their due diligence.

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  18. Anonymous says:

    money laundering in cayman????….never!

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  19. Anonymous says:

    What evidence is there that this is a real problem in Cayman now? I don’t recall the US, UK, EU or anyone else tracking Cartel or oligarch money to Cayman real estate. Much of this sounds like make-work for underemployed bureaucrats. On the other hand, the thieving agents’ cartel deserves whatever they get so why do I care?

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    • Anonymous says:

      There was a law ready in the UK back in 2014, to monitor the UK, especially the London property market for exactly those people.

      Role on the invasion in 2022, and the Law still has not been passed or even read to Parliament.

      Loads of evidence it occurs frequently, with looking at some of the major Kleptocracy’s and the 1MBD scandal

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  20. Anonymous says:

    No one comes here buying a $5 million house with cash!

    Real estate agents and developers also often have attorneys, and high net-worth clients have their local attorneys as well.

    Funds paid for property always go through the banking system which is extremely regulated and compliant – unless there are realtors accepting hundreds of thousands or millions of dollars in cold, hard cash for a property transaction; this article is simply shedding false, negative light on the Cayman real estate industry and the legal and financial services industry which are supported by its buyers and their funds.

    Overseas buyers are often wiring their funds from major US banks or THROUGH major US banks – there are so many tiers of money-laundering protection in a real estate transaction in Cayman that it is a downright shame such a headline would be published on internet media like this!

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    • Anonymous says:

      @10:47:
      I agree! The bigger shame is that the risk assessment reports fail to mention what you brought to light: If dirty money is making its way to real estate brokers, the local banks have failed in their due diligence.
      The Department of Commerce and Investment purposely left that out of their reports in order to grab some attention as to how important they are and how wonderfully they are doing their job. I call BS on this one!

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      • Anonymous says:

        Local banks due diligence seems to be more about harrassing small consumers than about catching the big fish!

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    • Noname says:

      The report doesn’t mention cash transactions but it does mention the fact of last minutes assignments to fiduciaries see page 78 of the National Risk Assessment report which goes into high detail on the matter.

      The problem here is that those last minute assignments don’t leave enough time to ascertain origins of funds or actual Beneficial Ownership of the fiduciary entity if such entity is settled in an out of scope jurisdiction.

      Your comment aims to mislead on the substance of the report and its contents.

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    • Anonymous says:

      We built a beachhouse and paid for everything by wire transfer. Our bank filed the IRS forms. We did not then and do not now have a Cayman bank account. It would just be asking for trouble, not to mention the aggravation.

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  21. Anonymous says:

    We have a population of 71000, but 164 property developers and real estate agents. Tells its own story.

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  22. Noname says:

    Return to greylisting or blackliisting in 3…2..1.

    I am for one glad the reports points out what I suspected for years now that the KYC carried by the local realtors was as the report put oh so diplomatically “deficient” and ripe for exploitation from less than reputable individuals.

    On the one hand, entities on island have to go through a lot of hoops if they decide to relocate here (red tape oh my love) if they have their accounts managed by financial institutions on island, on the other hand that process doesn’t take place at all if they decide at any point in the process to forego with the election of the an on island bank as remitting bank and decide to invest in real estate.

    The gaps in the system reside not only in the lack of beneficiary ownership documentation (to the kind exception of institutional trust companies that require not only the beneficiaries to settle accounts here but also provide proof of origin of funds, full documentation of the recipients and that their actual fiscal residence to be established on island)! , but the complete lack of access in the real estate sector to such documentation (which you will agree is quite the mouthful) leaves the whole sector ripe for exploitation!

    The present UBO system here on island remains completely inaccessible to realtors to this day and despite the 2018 legislation in place here isn’t used outside institutional trust companies. Offshore fiduciaries (settled out of the island’s jurisdiction are even less so under the obligation to provide ANY documentation, much even less to a local realtor).

    What can and should be done by the realtors is to raise the flag for last minute assignments to off island settled fiduciaries and non parties to cayman’s UBO documentation requirements to CIMA, effectively freezing the closing and assingnement processes until the investigation is complete) I am sure the interests of such “investors” would quickly evaporate, the commission of the realtor remain due as a result by the assigner , which will leave the realtor unscathed financially on the transaction, exposing them to the substantial fines that exist in the financial services sector over information they can’t access seems excessive IMHO.

    Is it a perfect solution? Certainly not! But it might be considered a worthwhile effort to reinforce the respectability of this sector of our economy that has been ripe for exploitation for decades!

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  23. Anonymous says:

    Even after successive failing FATF/CFATF report cards highlighting and bullet-pointing Cayman Islands real estate as a significant problem area, how does it look that DCI are only now wisening up to these gaps in mid-2022? By contrast, the Financial Services sector invests thousands of unbillable office hours collecting and reviewing intense spreadsheets of required PCAMLCTF documents and KYC, signing MOUs, TEAs, regulator exchange agreements, creating AML handbooks and scheduling staff training, enduring surprise CIMA-audits, only to watch aghast as enabling intermediaries, cash-for-gold pawn shops, jewellery stores selling conflict gems, crypto-exchanges, SIBL/SEZ pump and dumps, moneygram services, Cabinet Ministries/SAGCs, churches, construction firms, and real estate brokers continue to enjoy a cursory regulatory frisk, if ever. AML standards are so dramatically uneven that most in Financial Services seem to accept with disappointment that it’s by corrupt design.

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  24. Anonymous says:

    The real estate agents should be held to account. If financial services companies were non-complaint they would be slammed with fines and the reputation of the island broken.

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    • Anonymous says:

      Prosecutions too?

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    • Anonymous says:

      The realtors have to do their due diligence but that money gets double due diligence once it hits the banks. the banks do not get a pass as they have the second pair of eyes.

      This is nothing more than the DCI trying to toot their horn and make Cayman look bad internationally.

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  25. Anonymous says:

    Be like Bermuda. Stop foreign ownership, except at the very high end (over $5 million maybe). Should get rid of all those greedy real estate agents who don’t care who the buyers are. For the very high end make sure they do enhanced due diligence on the buyers & not allow trusts & companies to make the purchase. If they don’t want to get named then we don’t need them (tax evaders/money launderers/people on the lists the banks here have to check repeatedly).

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  26. Say it like it is says:

    If Govt just makes noises about these offenders, nothing will change. They need to be fined and have their business licences revoked if they do not obey the law. Realtors deal with vast sums of money and need to toe the line, like the financial sector.

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    • Anonymous says:

      “They need to be fined and have their business licenses revoked if they do not obey the law”? How many categories of businesses?

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    • Anonymous says:

      They are not Realtors. Cireba has no ability to confer Realtor status to its member agents and brokers.

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  27. Anonymous says:

    They figured that now?

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  28. Anonymous says:

    How many real estate companies pay minimum wage to their employees, DCI? How many realtors are in fact independent contractors? How many of those agents in fact have have Trade and Business Licenses?

    Just asking because their immigration permissions, which of course no one ever compensates their employer for because that would be illegal, often seems to be on the basis they are employees.

    #Leggewasright

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    • Anonymous says:

      “How many of those agents in fact have Trade and Business Licenses?”

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      • Anonymous says:

        All of them. You literally cannot buy or sell property without one, because it involves registry with Lands and Survey.

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        • Anonymous says:

          What about if overseas lawyers draft instruments to transfer title that is filed by realtors at Land Registry?

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        • Anonymous says:

          Nonsense. In fact, it is legally impossible for an individual non Caymanian real estate agent to have a Trade and Business license. Sure, the broker may have one, and it would be fine if they were employees of the broker, as their work permits contend, but the reality is they are often not. They are independent contractors and for some, their very existence in the Cayman Islands is unlawful. Carry on.

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  29. Anonymous says:

    Excellent. Hollywood has a script for The Firm 2.

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  30. Who wants some palm grease? says:

    And still will while our impotent leaders facilitate its protection. No doubt there have been and still are some high ranking CS people and politicians involved in this nefarious trade too lucrative to shut down.

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  31. Anonymous says:

    All real estate firms should be audited for this. If found in violation they should be fined in-line with the penalties handed out to financial services firms.

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  32. anonymous says:

    Who didn’t know this?? Plenty empty homes in north side and east end. The government knows too, they just don’t care. Caymanians are suffering and can’t afford no land, just to appease big money. AML laws my behind!

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  33. Anonymous says:

    In related news, water is wet.

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  34. Anonymous says:

    Hey DCI. I thought it was an offense to have more than two rental properties and rent them yourself without a license? You are not on top of the basic stuff and you are now worried about trust structures?

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  35. Cayman Grand Prix says:

    Damn straight and still washing money through property management and this global citizen scam still handling dubious and illicit money from criminals and their enterprises look at the real estate agents 100k vehicles and lavish lifestyles and the amount of fly by night real estate companies now here .The last frontier of the money launderer still going strong but yet we got 650 starving eh PACT and the highest GDP and Sponsors propping up invest cayman cayman connection and all sorts Rinky Dink government and so-called private sector money pay to play programs promoting the Cayman Islands and its people .The joke is on us Cayman whilst those overseas get their jollies selling us for fools !

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  36. Anonymous says:

    Hopefully now this will make them stop making random ass American billionaires who’ve never been to the island purchase property 🙂

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  37. Gray Matter says:

    Typo… late 1970’s

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  38. Anonymous says:

    Non compliant businesses need to be shut down. This has gone on long enough.

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  39. Gray Matter says:

    Due to the Secrecy Act Of the Cayman Islands, I Cannot reveal .
    “That was the “Motto” from the late 1070’s And still is today.

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  40. Anonymous says:

    Duh! How about “restaurants”?

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  41. Anonymous says:

    DUH

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  42. Anonymous says:

    Is the risk increased when politicians end up with multi-million dollar condos, laws get changed, and whole groups of people get granted status by the cabinet? Asking for a friend.

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