Hong Kong: Export Controls & Trade & Investment Sanctions

The Cayman Islands Monetary Authority has issued two new binding rules that will fundamentally reshape compliance obligations for financial service providers, including mutual funds, private funds, and SIBA registrants. These rules convert previously non-binding guidance into enforceable requirements with significant penalties for non-compliance, mandating enhanced anti-money laundering programs, sanctions screening protocols, and independent audit obligations.

In recent weeks, courts in England and Hong Kong have taken the opportunity to set out the serious consequences that follow from deliberately breaching disclosure orders made in the context