Two weeks ago we set out how the global AML rulebook is being rewritten in 2026. Since then the pace has picked up. In a few weeks the European Union's new anti-money laundering authority finalised the standards that will define customer due diligence across the bloc, Switzerland switched on its beneficial ownership register, US regulators kept moving stablecoin issuers into the AML perimeter, and FATF published new work on underground banking and gambling. Closer to home, the Cayman Islands brought new enforceable AML and sanctions rules into force and the BVI stepped up its inspection programme.
None of these measures was written for the Caribbean, but each will reach Caribbean institutions through correspondent banks, group compliance teams, international clients and assessors. Here is what changed and what it means in practice.
1. Europe: AMLA Finalises the Core of the Single Rulebook
The EU Anti-Money Laundering Authority (AMLA) has finalised three regulatory technical standards and submitted them to the European Commission for adoption. They cover:
- Customer due diligence: the information institutions must collect and verify, and how simplified and enhanced measures apply.
- Business relationships and occasional or linked transactions: when a series of dealings becomes a relationship that triggers full CDD.
- Group-wide AML/CFT arrangements: how parent entities must set and enforce policies across branches and subsidiaries, including those outside the EU.
AMLA has also consulted on implementing technical standards for suspicious transaction reporting, a step toward standard STR formats across the EU, and issued an advisory note on money laundering risks as the MiCA transitional period for crypto-asset service providers comes to an end.
Why it matters for the Caribbean: European banks, fund administrators and payment firms with Caribbean branches, subsidiaries or respondents will push these standards down their chains. Expect more detailed data requests on customer identity, source of funds and ownership, and expect group audits to test Caribbean entities against EU expectations rather than local minimums. Institutions serving European clients, from trust and corporate service providers to real estate and yacht businesses, should expect counterparties to ask whether their CDD meets the new EU baseline.
2. Switzerland: A Beneficial Ownership Register Goes Live
Switzerland's beneficial ownership register became operational on 1 October 2026. In-scope legal entities must register their beneficial owners and report changes, subject to transition periods. The register is not public; access is limited to designated authorities and to entities subject to Swiss AML legislation.
This continues a clear global trend. Even as the United States has ended domestic beneficial ownership reporting, other major financial centres are building registers and raising expectations for verified, current ownership data. For Caribbean corporate service providers and banks, the takeaway is the same one we made in who really owns the company: verifying beneficial ownership, rather than just collecting it, is now the global baseline, and Swiss and EU counterparties will expect Caribbean structures to match it.
3. United States: Stablecoins Move Into the AML Perimeter
Under the GENIUS Act framework, FinCEN and OFAC have proposed treating permitted payment stablecoin issuers as financial institutions with full AML/CFT and sanctions programme obligations, followed by a proposed customer identification programme rule. Final rules had not been issued at the time of writing.
Separately, US regulators have proposed reforming AML programme rules so that enforcement focuses on significant or systemic failures rather than technical deficiencies, with the OCC, FDIC and NCUA proposing aligned bank rules. This is a shift toward effectiveness, not a relaxation: programmes will still need to show that they actually identify and mitigate risk.
Why it matters for the Caribbean: several Caribbean jurisdictions are positioning themselves as digital asset hubs, and US dollar stablecoins are central to cross-border flows in the region. Banks with VASP customers, MSBs settling in stablecoins and VASPs themselves should expect US issuers and their banking partners to require stronger sanctions screening, Travel Rule compliance and redemption controls. See our analysis of stablecoin regulation and AML in the Caribbean.
4. FATF: Underground Banking, Gambling and Effectiveness
FATF's recent output gives assessors and correspondents new reference points:
- Hawala and underground banking. A new report examines how professional money launderers use hawala and other informal value transfer systems, with indicators for both authorities and the private sector. In the Caribbean, informal remittance channels, trade-based settlement and cash-intensive businesses can all carry these patterns.
- Gaming and gambling risk indicators. New indicators cover both land-based and online gambling, a live issue for Caribbean jurisdictions that license casinos and remote gaming operators.
- Mutual evaluations focused on effectiveness. Canada's latest evaluation recognises progress while calling for stronger action on complex money laundering cases. The lesson for CFATF members in the current round is consistent: assessors want results, not policies. Our review of the Barbados Mutual Evaluation explains why.
FATF's next plenary under the UK presidency is due this autumn, and its grey list decisions will again affect correspondent risk ratings across the region. The British Virgin Islands and Haiti remain under increased monitoring.
5. The Caribbean: Cayman Codifies, the BVI Inspects
Regional supervisors are not waiting. The Cayman Islands Monetary Authority's new AML and sanctions rules, gazetted in July and in force from September 2026, turn key expectations previously spread across lengthy guidance into enforceable obligations. Requirements on compliance programmes, independent audit and governance are now directly enforceable.
In the BVI, the Financial Services Commission has said it will increase inspections by around 25 percent, with AML/CFT/CPF components in all of them, while the Financial Investigation Agency has published typology work on terrorist financing and virtual assets and feedback on SAR quality. For licensees across the region this is a preview of where supervision is heading: fewer warnings, more testing, and more emphasis on the quality of what gets reported. If your reporting needs work, start with why good suspicious activity reports are crucial.
What Caribbean Regulated Entities Should Do Before Year End
- Benchmark CDD against the EU baseline. If you have EU parents, correspondents or significant EU clients, compare your CDD and EDD procedures with AMLA's finalised standards now, before a group audit or correspondent questionnaire does it for you.
- Close beneficial ownership gaps. Refresh ownership information for higher-risk and legacy clients, document how ownership was verified, and flag discrepancies against any registers you can access.
- Map your stablecoin and VASP exposure. Identify direct and indirect exposure, confirm Travel Rule arrangements and check that sanctions screening covers wallet addresses as well as names.
- Add new typologies to your risk assessment. Update your enterprise-wide risk assessment and monitoring scenarios with FATF's underground banking and gambling indicators where relevant.
- Prepare for inspection. If you are licensed in Cayman, map the new rules to your policies and evidence. Everywhere else, assume inspections will test effectiveness and keep testing results, management information and remediation logs ready.
- Brief the board. Give directors a short note on these developments and on the upcoming FATF plenary, so that risk appetite and resourcing decisions are made with the full picture.
The autumn 2026 changes share one message: the world's major financial centres are aligning on verified data, effective controls and enforceable standards. Caribbean institutions that meet that standard will find correspondents, regulators and international clients easier to deal with. Those that do not will increasingly be asked to explain why.
Need help turning these changes into an action plan? Four CCCC supports Caribbean AML/CFT compliance programmes, KYC and due diligence and regulatory inspection preparation across the region. Our training portal also offers practical courses for compliance teams and boards.
Rhonda Callender is a governance and compliance advisor with more than twenty years of experience across the international business and financial services sectors.