1. The DAML / Consent regime is now live. The biggest change is the new Defence Against Money Laundering (DAML) / Consent regime, which the FRA flags as a FATF Recommendation 4 requirement. Amendments to sections 133 –135 of the Proceeds of Crime Act now require SAR filers to obtain the FRA's consent before they "commit the act”. The automatic defence those sections once offered is gone. This moves Cayman closer to the UK-style consent model and changes the calculus for anyone holding suspected criminal property.
2. Output and turnaround metrics. The FRA's productivity figures stand out:

• 565 financial intelligence reports (disclosures) produced during 2025.
• 311 domestic disclosures, with RCIPS-FCU/CIBFI (181), CIMA (104) and CBC (24) the top recipients.
• 175 directives issued under section 4(2)(c) of the POCA.
• 1,532 cases received, generating 2,976 recorded reasons for suspicion.
• Disclosure turnaround reportedly improved against the 45-day benchmark recorded in 2024.

3. Sanctions activity is rising. Formal applications under the Russia sanctions regime nearly doubled, 23 in 2025, up from 13 in 2024. The FRA now converts OFSI notices into Cayman Financial Sanctions Notices in just 1–3 hours. It also notes that designated persons appeared as investors in, or beneficial owners of, Cayman funds and companies, often overlapping with PEP exposure.
4. Emerging typologies worth flagging to clients. Beyond familiar fraud patterns (business email compromise, romance scams, misappropriation from investment vehicles), the report highlights a rise in VASP-related suspicious activity reports (SARs) involving "cash-back" or reward-farming behaviours, as well as continued crypto-linked fraud requests from overseas FIUs with a Cayman nexus. The subject data is telling of subjects reported, 392 were Caymanian, and 317 of those were legal entities, not individuals.

5. Forward signals. The FRA's 2026 priorities point to greater use of AI and machine learning to triage SARs and cut manual workloads, plus upgrades to core systems (AMLive, i2 iBase, Analyst Notebook). Combined with FATF’s expectations on beneficial ownership transparency, proliferation financing risk assessment and asset recovery, these show where supervisory and reporting expectations are heading before 2027.

For investment funds: Cayman vehicles feature prominently in the FRA’s caseload. Legal entities made up most of the Caymanian subjects reported, and funds recur in misappropriation, sanctions and PEP-linked typologies. Investor onboarding, beneficial ownership verification and sanctions screening (particularly around the expanding Russian regime) all warrant fresh scrutiny.

For VASPs: The rise in “cash-back” and reward-farming SARs, together with the new DAML / Consent regime, raises the stakes on transaction monitoring, and on the timing and content of consent requests before dealing with suspected criminal property.

The annual report can be found here.