A dispute between a Cayman resident and Santander UK revealed the bank considers Cayman a financial crime risk.
Santander closed two UK bank accounts of Cayman resident and UK citizen Janice Brown on 15 April 2024. The bank later revealed that one factor in its decision was Brown’s Cayman connection.
In a 13 Feb. 2025 letter to Brown, Santander said: “The bank has legal and regulatory obligations to ensure it manages its financial crime risk, including its exposure to other jurisdictions. The bank has assessed the Cayman Islands as a jurisdiction where its exposure should be restricted.
“The bank’s assessment has been carried out using publicly available global risk indices and independent sources including the International Narcotics Control Strategy Report on Money Laundering Countries of Primary Concern (a country-by-country report produced by the United States Government, setting out the efforts to combat all aspects of money laundering and financial crimes) and the International Monetary Fund’s offshore centre list.”
Santander’s view of Cayman is surprising given that that the group has entities registered in the jurisdiction. It also runs counter to the jurisdiction’s efforts to comply with international financial regulation. In 2023, Cayman was removed from the Financial Action Task Force’s ‘grey list’ for anti-money laundering and terrorism financing. That was followed by the EU removing Cayman from its anti-money laundering ‘blacklist’ in 2024.
Discrimination based on ‘outdated views’?
“It is disappointing to read these outdated views, based on historic stereotypes,” said a spokesperson for Cayman Finance.
“Cayman is in good standing with [the taskforce], the global anti-money laundering watchdog, and both the EU and [Organisation for Economic Co-operation and Development] with respect to cross-border tax compliance. International banks should not discriminate against the Cayman Islands in such a way.”
Going into more detail, the Cayman Finance spokesperson questioned Santander’s methodology for evaluating the jurisdiction. “The IMF has not maintained an offshore list for more than 15 years. The US International Narcotics Control Strategy Report specifically states it is not a “blacklist” of jurisdictions, nor are there sanctions associated with it. The list includes every major financial centre, including the UK, Spain and the US itself.”
Responding to a list of Cayman Compass questions, a Santander UK spokesperson emphasised that “risk appetite decisions are made on a case-by-case basis” and noted the importance of “identifying and preventing economic crime”. Yet there is no suggestion that Brown, a former primary school teacher, artist and founder of local souvenir company, Island Creations, is involved in illicit finance or money laundering.
UK banks can withdraw services from customers who reside abroad. And banking experts consulted by the Cayman Compass believe that was likely Santander’s motivation for this closure. Moreover, Santander confirmed to the Compass that Cayman isn’t on its list of “prohibited jurisdictions”.