KSG Risk Solutions

We provide solutions in regulatory compliance, risk, Economic Substance and AML to regulated financial service providers and funds. Our team has a wealth of experience in respect of Cayman laws and regulations. We have a detailed appreciation of the applicable global standards and can tailor your response to them in a robust and commercial way.


  • CIMA Inspections: audit, preparation and remediation
  • AML (and the related fields of CFT / CPF / TFS)
  • Economic Substance advice
  • Policies & Procedures: drafting, amendment and testing
  • AMLCO Outsourcing
  • MLRO / DMLRO Outsourcing
  • Bespoke training and assessment on all regulatory matters
  • Business Risk Assessments
  • Country Risk policies and assessment


KSG Risk’s Partner, Hugo Lodge, is an expert in AML and related fields. He advises regularly on Economic Substance and Data Protection & Cyber Security. Hugo is a UK barrister and highly experienced Compliance professional, with over 20 years’ standing both onshore and offshore. Hugo is a published academic author with Oxford University on sanctions and terrorist financing.

Prior to moving to the Cayman Islands, Hugo practised as a barrister in England and Wales from 1998. He later worked at the Financial Conduct Agency in its Retail Banking / financial crime divisions. On moving to Cayman Hugo took up the role of Partner in the Regulatory and Financial Services group of another leading off-shore law firm. Hugo formed part of the Cayman Islands delegation responding to the CFATF mutual evaluation. He now leads KSG Risk Solutions as its Partner.

Hugo has gained valuable experience of the regulatory regimes in the U.K. and Cayman Islands. He provides bespoke solutions to banks and other financial services providers. Hugo is known for his pragmatic, commercial and reasoned approach to the compliance risks faced by regulated entities and for offering robust and effective solutions.

Outsourced Anti-Money Laundering Compliance Officer (“AMLCO”)

Regulated financial services providers in the Cayman Islands, as well as funds in the jurisdiction, need to appoint a natural person with sufficient experience to perform the AMLCO role for the firm or fund. The AMLCO is responsible for key regulatory tasks, such as: ensuring that policies and procedures are kept up to date following changes to laws and regulations; ensuring that the compliance function within the entity or fund maintains appropriate systems and controls; reporting to the Board; and, responding to requests for information by competent authorities.

We can provide an experienced person to fulfil this role or alternatively, can assist you in identifying a suitable person from within your organization, and train that person to allow them to fulfil the role.

Outsourced Money-Laundering Reporting Officer (“MLRO”) / Deputy MLRO (“DMLRO”)

Every financial services provider must designate a suitably qualified and experienced person as MLRO, as well as a Deputy MLRO (who must be of similar status and experience to the MLRO). These people should have a good understanding of the types of transactions which the provider handles and should be fully conversant with the AML and associated risks.

The roles of MLRO and Deputy MLRO can be outsourced, should a provider not have appropriately qualified staff, and we can assist with this.

Policy and Procedures enhancement

The laws, regulations and guidance on money laundering and regulatory compliance are constantly evolving. We can assist you with enhancements to your existing policies and procedures documents to ensure that you remain compliant.

AML Audits

Regulated entities must ensure that regular, periodic AML Audits are performed to ensure that they continue to adhere to the applicable Anti-Money Laundering laws, regulations and guidance. KSG Risk Solutions can work with you to design an audit plan and perform the appropriate testing of your compliance with these requirements. With extensive experience and knowledge of Trusts, Corporate Services, Banking, Insurance, Fund Administration and Insurance we are well placed to understand your business model and your AML and related risks, and to prepare a suitable audit plan.

Regulatory Inspection Remediation

KSG Risk Solutions can assist you with the remediation of issues raised during a CIMA, or other regulatory, inspection. These remediation projects can be time-consuming: our services will allow you to comply with the remediation requirements while not having to re-allocate staff from their ongoing duties. We can develop a remediation plan and ensure that the requirements in it are met.

Regulatory investigations and Administrative fines

We are well placed to represent those facing administrative fines for alleged breaches of the Anti-Money Laundering Regulations. We can draw on a wealth of experience of former regulators and financial crime attorneys.