AG Opening Remarks at 2025 NPO Symposium

Good morning, distinguished guests, colleagues, and representatives of Cayman’s vital nonprofit sector.

It is my pleasure to join you today at this pivotal symposium, co-hosted by the R3 Foundation and the Government General Registry, as we collectively seek to advance the integrity, resilience, and trust that underpin our nonprofit community. 

Let me begin by extending my sincere gratitude to the R3 Foundation for its steadfast commitment to empowering NPOs, and to the General Registry for partnering in these outreach initiatives that play a crucial role in sensitising NPOs about their obligations and permissible activities, as well as preparing us for the Cayman Islands’ upcoming 5th Round Mutual Evaluation by the CFATF/FATF.

Nonprofit organisations are the lifeblood of our society. Your work uplifts vulnerable communities, addresses critical gaps, and fosters social cohesion. The value you bring to our islands is not just commendable- they are indispensable to Cayman’s sustainable development.

As we strive for greater transparency and accountability, we are mindful of the need to avoid overregulation, which could inadvertently undermine the legitimacy and vibrancy of our NPO sector. Our regulatory approach, informed by FATF standards, is designed to prevent abuse, such as using NPOS for terrorist financing, while supporting the autonomy and innovation that make your organisations so effective.

Therefore, having as its purpose -NPO engagement, knowledge sharing and collaboration, this event is very timely indeed.

Because of the undoubted importance of our NPO sector it is equally important that the Regulatory Framework for our sector can and will stand up to international scrutiny such as the 5th round mutual evaluation. 

Therefore, with outreach initiatives such as these today, you are demonstrating to the world that we are ensuring that proper guardrails are in place to prevent potential abuse of the sector.

This gathering here today aimed at building trust, and resilience, and thereby strengthening the integrity of the sector is to be applauded.

Although Cayman, relatively speaking, is considered a low risk jurisdiction for terrorist financing activities – it is important for us to maintain our continuing heightened scrutiny in areas such as customer, due diligence of donors, beneficiaries, and third parties; and to insist on robust record-keeping of transactions as well as ongoing risks assessments and training support and awareness.

We can, and should do all of the above-while at the same time ensuring that our AML/CFT policies; procedures; and controls are only those that are necessary; proportionate; reasonable and therefore commensurate with our risks profile – and thereby ensuring that our NPO can continue to thrive and provide the invaluable support to our community.

I would like to particularly acknowledge the contributions of the Greenacre Group, whose expertise in risk-based approaches to NPO oversight has been recognised internationally. Their work, including our 2019 risk assessment, has helped inform the jurisdiction on how to strike the right balance between safeguarding the sector and enabling its essential work.  So allow me to say a special thank you to Ben Evans for the stellar job, be it risk assessment survey or otherwise. We are grateful, Ben.

Thanks to all the directors, other minds, and management of R3, who are present here today. True to your mission, you continue to provide that critical support which makes it easier for our NPOS to focus more on the provision of much-needed assistance and less on how they are going to fund their mission.

To all NPO leaders present: thank you. Your engagement in forums like this signals your commitment to ethical excellence and partnership with the government. Together, we will continue to build frameworks that protect our jurisdiction’s reputation without compromising your mission.

In closing, I urge you to seize the opportunities presented by this symposium to engage, learn, and collaborate. With your continued dedication and support, I am confident that Cayman will remain a global example of responsible, impactful nonprofit governance.

Thank you,

Samuel Bulgin KC, JP

Hon. Attorney General