01 · Investor onboarding
Work new subscriptions.
We review investor documents, trace beneficial ownership, screen related parties and document the risk assessment. Your authorised team makes the acceptance decision.

Cayman Islands KYC services
We complete onboarding and overdue KYC reviews under your fund’s AML policy. If your administrator does the work, our Shadow KYC reviewers check their files and report the gaps to your board.
Your AML policy · Qualified human review · Your team keeps approval

Managed investor KYC
We support Cayman mutual funds, private funds and their administrators. You can engage us for a defined backlog or recurring investor reviews.
01 · Investor onboarding
We review investor documents, trace beneficial ownership, screen related parties and document the risk assessment. Your authorised team makes the acceptance decision.
02 · KYC remediation
We review files with missing evidence, outdated ownership records or unresolved screening hits. Our reviewers check the agreed population against your current policy and record the resolution or escalation of each gap.
03 · Periodic reviews
We perform scheduled KYC refreshes and trigger-event reviews. Our reviewers update screening, ownership records and risk assessments at the frequency you set under your risk methodology.
Shadow KYC · Independent file review
Your board remains accountable for outsourced AML work. Our reviewers test your administrator’s investor files against your fund’s policy. You receive the findings and evidence you need to challenge gaps and oversee remediation.
Scope an independent review See how Shadow KYC worksCIMA’s AML/CFT FAQs 25 and 43–45 describe periodic testing of outsourced activities and fund-specific audit evidence. Shadow KYC supports that oversight; it is not a substitute for a programme-wide independent AML audit. Read the CIMA AML Rule guide →
Managed KYC deliverables
Our reviewers document their work so your approver can check the evidence and resolve outstanding questions.
Included in the file
Verification evidence and an ownership chain traced to the relevant natural persons under your policy.
Included in the file
Sanctions, PEP and adverse-media results, with a recorded disposition for each reviewed hit.
Included in the file
A reasoned risk rating, source of funds and wealth evidence where required, and unresolved exceptions.
Included in the file
Indexed documents, reviewer notes and a record of the work, ready for your authorised approver.
The process
01 · Scope
Provide your AML policy, risk methodology, available files and target date. We agree deliverables, access, price and responsibilities.
02 · Work & review
Agents organise evidence and perform the first pass. Qualified compliance reviewers check the work and escalate complex or high-risk cases.
03 · Handover
Receive completed files and an exception log. Your authorised team retains approval; recurring reviews follow your agreed risk-based schedule.
Questions
Scope, responsibility and what your Cayman fund receives.
Scope your KYC workYes. Shadow KYC is our independent review of administrator-held investor files against your fund’s AML policy. We agree access and scope with you, test the files and return traceable exceptions and a board-ready summary.
Yes. Send the investor population, available documents, AML policy, risk methodology and target date. We agree the scope, price and delivery schedule, then report progress and outstanding evidence case by case.
Your fund and its governing body retain responsibility for AML compliance. We perform the agreed operational work and document our findings. Your authorised AML officers retain customer acceptance and other compliance decisions.
Shadow KYC gives your board an independent review of the investor files your administrator holds. Our reviewers document gaps, trace findings to source evidence and recommend remediation. Your board can use the report to oversee the administrator, and your AML auditor can draw on the findings when assessing the wider compliance programme. The auditor’s scope extends beyond investor files to areas such as governance and suspicious activity reporting.
Shadow KYC is AgentKYZ’s term, inspired by shadow NAV. CIMA expects effective oversight and periodic review and testing of outsourced AML activities. Our service supplies fund-specific file findings to support that oversight.
We quote for the case population and scope, including ownership complexity, document availability and review requirements. We confirm the price, delivery schedule and your responsibilities for supplying missing evidence in the engagement letter.
Discuss your files
Tell us how many files you have and your target date. We’ll agree the scope with you and confirm pricing and delivery in writing.
Or send the case list to [email protected]