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This document establishes the Cayman Islands Monetary Authority\u2019s (the \u201cAuthority\u201d or \u201cCIMA\u201d) rules and guidance on the recruitment and selection standards for Trust and Corporate Service Providers (\u201cTCSPs\u201d) and Company Managers. 1.2. The Rule and Statement of Guidance (\u201cRSOG\u201d) should be read in conjunction with: a) CIMA-issued measures: Regulatory Policy on Fitness and Propriety; Rule and Statement of Guidance on Internal Controls for Regulated Entities; Rule on Corporate Governance for Regulated Entities; Regulatory Policy on Criteria for Approving Changes in Ownership and Control; the Statement of Guidance on Outsourcing for Regulated Entities; Nature, Accessibility, and Retention of Records for Licensees Conducting the Business of Company Management; and b) all applicable Acts in the Cayman Islands and any other relevant regulatory measures issued by the Authority from time to time. 1.3. Where applicable, any Acts referred to in this document include related regulations as amended from time to time. 1.4. To highlight the Authority\u2019s rules within the compendium, a rule is written in light blue and designated with the letter \u201cR\u201d in the right margin. 1.5. This RSOG is not intended to be prescriptive or exhaustive; rather, it sets out the Authority\u2019s minimum expectations relating to the recruitment, selection, competence, continuing professional development, and training processes of Regulated Persons.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_2\", \"num\": \"2.\", \"text\": \"Statutory Authority 2.1. This RSOG is consistent with the Authority\u2019s statutory objectives as prescribed in Section 34 of the Monetary Authority Act (\u201cMAA\u201d), which provides that the Authority may issue rules, statements of principles, or statements of guidance: \u201c34(1) After private sector consultation and consultation with the Minister charged with responsibility for Financial Services, the Authority may\u2013 (a) issue or amend rules or statements of principle or guidance concerning the conduct of licensees and their officers and employees, and any other persons to whom and to the extent that the regulatory acts may apply; (c) issue or amend rules or statements of principle or guidance to reduce the risk of financial services business being used for money laundering or other criminal purposes.\u201d Rule and Statement of Guidance Recruitment and Selection Standards for Trusts and Corporate Service Providers and Company Managers Cayman Islands Monetary Authority Page 5 of 13\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_3\", \"num\": \"3.\", \"text\": \"Scope of Application 3.1. This RSOG applies to: a) Holders of a Trust Licence, Restricted Trust Licence or Nominee Trust Licence that have been issued under the Banks and Trust Companies Act (\u201cBTCA\u201d); b) Holders of a Companies Management Licence or Corporate Services Licence that have been issued under the Companies Management Act (\u201cCMA\\\"); and c) Persons licensed under other regulatory acts, that are allowed to engage in  the business of company management pursuant to the CMA. 3.2. The Authority will assess Regulated Persons\u2019 compliance with this RSOG in a manner commensurate with the size, complexity, structure, nature of business and risk profile of their operations. 3.3. The Authority acknowledges that Regulated Persons that are part of a group may be subject to group-wide practices, and that such Regulated Persons may rely on the group for certain recruitment and selection standards. Where a Regulated Person is part of a group, it may rely on the group\u2019s framework provided that the Regulated Person\u2019s Governing Body is satisfied that the framework is commensurate with the size, complexity, structure, nature of business and risk profile of its operations and legal requirements in the Cayman Islands, including those outlined in this RSOG. Where gaps are identified, a tailored recruitment and selection standards framework that complies with the legal requirements in the Cayman Islands is required for Regulated Persons.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_4\", \"num\": \"4.\", \"text\": \"Definitions 4.1. The following definitions are provided for the purpose of this RSOG: 4.1.1. \u201cCompetence\u201d relates to the level of a person\u2019s professional or formal qualifications, knowledge, skills, and pertinent experience. Competence also includes a person\u2019s capacity to enable the proper performance of his\/her role and to maintain and enhance knowledge and skills through training and continuing professional development. 4.1.2. \u201cContinuing Professional Development (\u201cCPD\u201d)\u201d encompasses a wide range of company-developed ongoing training regimes and external non-degree bearing training and development courses offered to professionals with a view to maintain and\/or enhance their knowledge and skills. 4.1.3. \u201cContinuing Professional Development Policy (\u201cCPD Policy\u201d)\u201d refers to the documented policy developed by a Regulated Person which outlines its expectations for training and continuing professional development of its employees. 4.1.4. \u201cKey Person\u201d refers to any person who is acting in a Controlled Function as defined under the Authority\u2019s Policy on Fitness and Propriety and includes, but is not limited to, a Director, Partner, Money Laundering Rule and Statement of Guidance Recruitment and Selection Standards for Trusts and Corporate Service Providers and Company Managers Cayman Islands Monetary Authority Page 6 of 13 Reporting Officer and Anti-Money Laundering Compliance Officer of a TCSP. 4.1.5. The \u201cGoverning Body\u201d of a Regulated Person is the Board of Directors where the Regulated Person is a corporation, the General Partner where the Regulated Person is a partnership, the manager (or equivalent) where the Regulated Person is a Limited Liability Company, and the Trustee or the Board of Trustees where the Regulated Person is a trust business. 4.1.6. \u201cRegulated Person\u201d for the purpose of this RSOG means a natural or a legal person, or arrangement that has been approved, licensed, registered or supervised by the Authority pursuant to the relevant regulatory Acts under the Scope of Application. 4.1.7. \u201cTCSPs\u201d refer to those who undertake any one or more of the following activities pursuant to the BTCA or the CMA as applicable: a) acting as a Corporate or Partnership formation agent; b) acting as (or arranging for another person to act as) a Director, Secretary or Official of a Company or a Partner of a Partnership or as a Foundation Official; c) providing administration or management of a Trust, Company, Partnership, Foundation or for any other legal person or legal arrangement; d) providing registered office, business address for accommodation, correspondence for administrative address for a Company, Partnership, Foundation or for any other person; e) acting as a Resident Agent1 for the purposes of meeting the requirements to hold beneficial ownership or interest information; f) acting as (or arranging for another person to act as) a Trustee of an Express Trust; g) acting as (or arranging for another person to act as) a Nominee Shareholder for another legal person; h) Persons who act as Executors and Administrators; and i) establishing and maintaining beneficial ownership registers on behalf of companies and limited liability companies incorporated or formed in the Islands, offering an information technology solution to those companies and limited liability companies to make extracts of information on the beneficial ownership register searchable by the competent authority established under Part XVIIA of the Companies Act and responding to requests from the competent authority about whether a company, a limited liability company or a subsidiary of the same is exempted from the application of that Part or of Part 12 of the Limited Liability Companies Act. 1Consistent with Section 3(1) (ba) of the CMA, Resident Agent means an agent establishing and maintaining beneficial ownership registers on behalf of companies and limited liability companies incorporated or formed in the Cayman Islands. Rule and Statement of Guidance Recruitment and Selection Standards for Trusts and Corporate Service Providers and Company Managers Cayman Islands Monetary Authority Page 7 of 13\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_5\", \"num\": \"5.\", \"text\": \"Recruitment of Key Persons 5.1. Recruitment Stage Approval of Candidates 5.1.1. A Regulated Person must obtain the Authority\u2019s approval before the appointment of a Key Person. 5.1.2. A Regulated Person should evaluate and assess candidates for the role of a Key Person to ensure that they are fit and proper to perform the role for which they are applying. 5.1.3. The Authority will assess candidates for the role of Key Persons, as submitted by the Regulated Person, consistent with the Authority\u2019s Regulatory Policy on Fitness and Propriety. 5.1.4. The Authority reserves the right to approve or reject such an appointment in accordance with all applicable Acts in the jurisdiction and any relevant regulatory measures issued by the Authority from time to time. Policies and Procedures 5.1.5. A Regulated Person should establish and maintain appropriate recruitment policies and procedures commensurate with the size, complexity, structure, nature of business and risk profile of its operations that have been approved by the Governing Body. 5.1.6. A Regulated Person should review its recruitment policies and procedures, at least annually, and update them if necessary, to ensure that they continue to align with business and staffing needs and industry developments. 5.1.7. The Authority expects that at a minimum, the recruitment policies and procedures should capture the following to ensure they are appropriate and comprehensive: a) the Regulated Person\u2019s overarching and fundamental objective of recruitment and selection and onboarding procedures; b) the Regulated Person\u2019s commitment to fair and transparent recruitment processes; c) an appropriate record of job descriptions for all advertised roles. These job descriptions should provide all candidates with a clear understanding of the role; purpose, accountabilities, and responsibilities, along with the requirements, knowledge, skills, and experience required for the role; and d) include a methodology for assessing the fitness and propriety of candidates offered contracts of employment or functions within the Regulated Persons. Considerations include, but are not limited to: honesty, integrity and reputation; competence and capability; and financial soundness. R Rule and Statement of Guidance Recruitment and Selection Standards for Trusts and Corporate Service Providers and Company Managers Cayman Islands Monetary Authority Page 8 of 13 5.1.8. A Regulated Person should be able to demonstrate that it has evaluated how a candidate\u2019s knowledge, skills, experience, and qualifications meet the requirements for the role, as outlined in the job description. In addition, the Regulated Person should be able to demonstrate that they have taken reasonable steps to verify the candidate\u2019s relevant information before onboarding the candidate. 5.1.9. A Regulated Person should be able to demonstrate that it has adequately assessed and verified candidates\u2019 references, membership in professional bodies (if applicable), criminal records, regulatory censure, financial soundness, professional reprimands, sanctions, conflicts of interest, legal proceedings and any other formal censure, discipline, or public criticism at the recruitment stage, as part of its fitness and propriety assessment on the candidate. 5.1.10. A Regulated Person should ensure that its recruitment, selection and employment practices are fair, transparent and in compliance with all applicable Acts in the Cayman Islands and any relevant regulatory measures issued by the Authority from time to time. 5.1.11. A Regulated Person should ensure there is adequate staffing to meet the requirements of the Regulated Person\u2019s business plan to support the licence held2. 5.2. Post-Recruitment Supervision of Key Persons 5.2.1. A Regulated Person should ensure Key Persons remain competent, fit and proper and able to effectively carry out their roles and responsibilities and that the level of competence is commensurate with the size, complexity, structure, nature of business and risk profile of its operations. 5.2.2. A Regulated Person must notify the Authority immediately on becoming aware of significant changes that adversely affect the fitness and propriety of its approved Key Persons. 5.2.3. A Regulated Person must notify the Authority of a cessation of its approved Key Persons within twenty-one (21) days. 5.2.4. A Regulated Person should annually review the competence, qualifications, knowledge, and skills of its Key Persons to ensure that their level of competence remains commensurate with the size, complexity, structure, nature of business and risk profile of its operations. Appropriate measures should be taken to address any gaps identified. 5.2.5. A Regulated Person should consider and assess changes in Key Persons\u2019 performance and behaviour, at least annually, and put measures and controls in place to address any misconduct or underperformance. 5.2.6. A Regulated Person should ensure that the responsibilities and authority of each Key Person are clearly documented and communicated. 2Where outsourced service providers are utilised to meet staffing needs, Regulated Persons should refer to the Statement of Guidance on Outsourcing for Regulated Entities. R R Rule and Statement of Guidance Recruitment and Selection Standards for Trusts and Corporate Service Providers and Company Managers Cayman Islands Monetary Authority Page 9 of 13 5.2.7. Job descriptions should be reviewed as appropriate to ensure they are up-to-date, accurate, clear, and helpful to candidates and current Key Persons. 5.2.8. Reviews of job descriptions should evaluate and make accommodations for the needs of Key Persons, such as additional skills or qualifications, where they have entered a new role, or where their role has changed or expanded in scope. Reviews should also consider any changes in the size, complexity, structure, nature of business and risk profile of the Regulated Person\u2019s operations. 5.2.9. A Regulated Person should have effective systems and processes to ensure that Key Persons are appropriately supervised. These systems and processes should be documented and communicated to all Key Persons. 5.2.10. To support the adequate supervision of Key Persons, the policies and procedures that the Regulated Person has in place should be appropriate to the knowledge, skills and pertinent experience of each Key Person and should include the following: a) overarching reporting lines; b) reporting relationships between a Key Person and a supervisor; c) internal escalation processes for staff-related matters; d) changes in reporting lines; e) multiple reporting lines; and f) the method and frequency of advising Key Persons of such reporting relationships.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_6\", \"num\": \"6.\", \"text\": \"Directorship Services Obligations 6.1. The Governing Body should undertake self-assessments of the performance of the Governing Body collectively and its individual members to ensure they remain competent to carry out the recruitment, supervision, and training standards of the Regulated Person. 6.2. Where a Regulated Person licensed under the CMA is acting as or fulfilling the function of, or arranging for another person to act as or fulfil the function of, director or alternate director of a company, the Regulated Person, licensed under the CMA, should ensure the director or alternate director understands his or her duty to: a) act openly, honestly and in good faith, at all times, and exercise independent judgment, always acting in the best interests of the client. b) carefully consider all decisions and understand the potential negative implications for the client company, its shareholders or its customers. c) maintain a thorough knowledge and understanding of the client\u2019s business and update his\/her knowledge periodically, consistent with changes in the industry, regulatory landscape or business of the client. d) satisfy himself or herself that an appropriate and timely course of action is being taken to address any concerns raised. e) satisfy himself or herself that the client, its governing body, its service providers, and advisors are acting in accordance with the client\u2019s constitutional documents and any other documents directing the Rule and Statement of Guidance Recruitment and Selection Standards for Trusts and Corporate Service Providers and Company Managers Cayman Islands Monetary Authority Page 10 of 13 management and operation of the client and\/or its advisors or service providers.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_7\", \"num\": \"7.\", \"text\": \"Ongoing Training and Continuing Professional Development 7.1. A Regulated Person should have a documented CPD Policy which sets out ongoing training and CPD requirements for all employees including Key Persons, which should be commensurate with the size, complexity, structure, nature of business and risk profile of its operations. 7.2. A Regulated Person\u2019s CPD Policy should be reviewed and approved by the Governing Body at least every three years, or earlier if needed, to ensure that the CPD Policy continues to meet the training needs of the Regulated Person. 7.3. In developing the CPD Policy, a Regulated Person should make accommodations for Key Persons whose roles have changed or expanded in scope, or who have entered new roles. Similarly, a Regulated Person should consider changes to any legal and regulatory requirements, market developments and any other changes impacting the role of the Key Person. 7.4. A Regulated Person may rely upon both internal training resources as well as appropriate external sources in developing a training and CPD programme. A Regulated Person should satisfy itself with the quality of the training materials and the standard of the training programmes when selecting CPD activities and ensure that the contents of such courses are commensurate with the Key Person\u2019s role and responsibilities. 7.5. Where a Key Person holds a relevant professional qualification, designation, or is a member of a relevant professional body or association that requires the completion of a certain number of CPD hours, the Regulated Person should ensure that the Key Person complies with such CPD requirements. A Regulated Person may, as appropriate, use a Key Person\u2019s professional development hours, earned in meeting the CPD obligations of their professional qualification or membership, towards meeting the minimum number of training hours specified in the Regulated Person\u2019s own CPD Policy.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_8\", \"num\": \"8.\", \"text\": \"Activities Relevant for Training and Continuing Professional Development 8.1. CPD activities may include, but are not limited to, a varied mix of the following: a) training courses and activities provided by the Regulated Person; b) industry workshops; c) lectures and exam training; d) conferences and seminars; e) university courses; f) certification courses; g) distance learning which requires active participation; h) self-study with Independent Assessments; and i) publication of research papers and journal articles. 8.2. Relevant CPD topics for Key Persons should be commensurate with the Key Person\u2019s role and responsibilities, and include inter alia, the following topics, which may be relevant to the Regulated Person\u2019s specific business operations: Rule and Statement of Guidance Recruitment and Selection Standards for Trusts and Corporate Service Providers and Company Managers Cayman Islands Monetary Authority Page 11 of 13 a) Enterprise-wide Risk Management; b) Anti-money Laundering and Countering Terrorist Financing Risk; c) Other relevant financial, operational and emerging risks; d) Applicable Compliance, Legislative and Regulatory Standards; e) Business Conduct and Ethical Standards; f) New Financial Products in the Industry and the Associated Risks; g) Management Information Systems and Technological literacy; h) General Management and Governance; and i) Financial Reporting and Quantitative Analysis. 9. Record Keeping 9.1. A Regulated Person must keep all recruitment and selection records in accordance with requirements outlined in the Rule and Statement of Guidance \u2013 Nature, Accessibility and Retention of Records for Licensees Conducting the Business of Company Management. 9.2. A Regulated Person should keep the appropriate records related to their recruitment processes. Records should include, at a minimum: a) records relating to hiring decisions including decisions to refuse or reject a candidate; b) records relating to complaints about the hiring process or appeals to any decisions taken to transfer, promote, demote; c) advertisements or notices to the public or Key Persons about openings, promotions, and\/or training opportunities; d) job descriptions for existing and advertised positions; e) job applications, resumes, interview notes and records; f) records relating to fitness and propriety checks; and g) dates hired, promoted, demoted, transferred. 9.3. A Regulated Person should also keep proper records of CPD activities, including the details of the training conducted and the attendance records for persons who have completed the training. 9.4. Records should demonstrate how the training relates to and supports persons remaining competent in their role. 9.5. As a best practice, a Regulated Person should encourage Key Persons to keep proper records of their own CPD activities including, as applicable: a) name of course attended; b) topic or subject matter; c) date of attendance; d) number of hours; and e) assessment results.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_10\", \"num\": \"10.\", \"text\": \"Enforcement 10.1. Whenever there has been a breach of the Rules included in this document, the Authority\u2019s policies and procedures, as contained in its Enforcement Manual, will apply in addition to any other powers provided in the relevant Acts and the MAA. 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Enforcement ................................................................................................................................................ 11\n11. Effective Date ............................................................................................................................................. 12\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 3 of 13\nList of Acronyms\n\nBTCA\nBanks and Trust Companies Act\nCIMA\nCayman Islands Monetary Authority\nCMA\nCompanies Management Act\nCPD\nContinuing Professional Development\nGIFCS\nGroup of International Finance Centre Supervisors\nMAA\nMonetary Authority Act\nRSOG\nRule and Statement of Guidance\nSRTC\nStandard on the Regulation of Trust and Corporate Service Providers\nTCSPs\nTrust and Corporate Service Providers\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 4 of 13\n\nRule and Statement of Guidance\n\n Recruitment and Selection Standards for Trust and Corporate\nService Providers and Company Managers\n\n1.\nIntroduction\n\n1.1.\nThis document establishes the Cayman Islands Monetary Authority\u2019s (the\n\u201cAuthority\u201d or \u201cCIMA\u201d) rules and guidance on the recruitment and selection\nstandards for Trust and Corporate Service Providers (\u201cTCSPs\u201d) and Company\nManagers.\n\n1.2.\nThe Rule and Statement of Guidance (\u201cRSOG\u201d) should be read in conjunction\nwith:\n\na)\nCIMA-issued measures: Regulatory Policy on Fitness and Propriety; Rule\nand Statement of Guidance on Internal Controls for Regulated Entities;\nRule on Corporate Governance for Regulated Entities; Regulatory Policy\non Criteria for Approving Changes in Ownership and Control; the\nStatement of Guidance on Outsourcing for Regulated Entities; Nature,\nAccessibility, and Retention of Records for Licensees Conducting the\nBusiness of Company Management; and\n\nb)\nall applicable Acts in the Cayman Islands and any other relevant\nregulatory measures issued by the Authority from time to time.\n\n1.3.\nWhere applicable, any Acts referred to in this document include related\nregulations as amended from time to time.\n\n1.4.\nTo highlight the Authority\u2019s rules within the compendium, a rule is written in\nlight blue and designated with the letter \u201cR\u201d in the right margin.\n\n1.5.\nThis RSOG is not intended to be prescriptive or exhaustive; rather, it sets out\nthe Authority\u2019s minimum expectations relating to the recruitment, selection,\ncompetence, continuing professional development, and training processes of\nRegulated Persons.\n\n2.\nStatutory Authority\n\n2.1.\nThis RSOG is consistent with the Authority\u2019s statutory objectives as prescribed\nin Section 34 of the Monetary Authority Act (\u201cMAA\u201d), which provides that the\nAuthority may issue rules, statements of principles, or statements of guidance:\n\n\u201c34(1) After private sector consultation and consultation with the Minister\ncharged with responsibility for Financial Services, the Authority may\u2013\n\n(a)\nissue or amend rules or statements of principle or guidance concerning\nthe conduct of licensees and their officers and employees, and any other\npersons to whom and to the extent that the regulatory acts may apply;\n\n(c)\nissue or amend rules or statements of principle or guidance to reduce\nthe risk of financial services business being used for money laundering\nor other criminal purposes.\u201d\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 5 of 13\n3.\nScope of Application\n\n3.1.\nThis RSOG applies to:\n\na)\nHolders of a Trust Licence, Restricted Trust Licence or Nominee Trust\nLicence that have been issued under the Banks and Trust Companies\nAct (\u201cBTCA\u201d);\n\nb)\nHolders of a Companies Management Licence or Corporate Services\nLicence that have been issued under the Companies Management Act\n(\u201cCMA\"); and\n\nc)\nPersons licensed under other regulatory acts, that are allowed to engage\nin  the business of company management pursuant to the CMA.\n\n3.2.\nThe Authority will assess Regulated Persons\u2019 compliance with this RSOG in a\nmanner commensurate with the size, complexity, structure, nature of business\nand risk profile of their operations.\n\n3.3.\nThe Authority acknowledges that Regulated Persons that are part of a group\nmay be subject to group-wide practices, and that such Regulated Persons may\nrely on the group for certain recruitment and selection standards. Where a\nRegulated Person is part of a group, it may rely on the group\u2019s framework\nprovided that the Regulated Person\u2019s Governing Body is satisfied that the\nframework is commensurate with the size, complexity, structure, nature of\nbusiness and risk profile of its operations and legal requirements in the Cayman\nIslands, including those outlined in this RSOG. Where gaps are identified, a\ntailored recruitment and selection standards framework that complies with the\nlegal requirements in the Cayman Islands is required for Regulated Persons.\n\n4.\nDefinitions\n\n4.1.\nThe following definitions are provided for the purpose of this RSOG:\n\n4.1.1. \u201cCompetence\u201d relates to the level of a person\u2019s professional or formal\nqualifications, knowledge, skills, and pertinent experience. Competence\nalso includes a person\u2019s capacity to enable the proper performance of\nhis\/her role and to maintain and enhance knowledge and skills through\ntraining and continuing professional development.\n\n4.1.2. \u201cContinuing Professional Development (\u201cCPD\u201d)\u201d encompasses a\nwide range of company-developed ongoing training regimes and\nexternal non-degree bearing training and development courses offered\nto professionals with a view to maintain and\/or enhance their knowledge\nand skills.\n\n4.1.3. \u201cContinuing Professional Development Policy (\u201cCPD Policy\u201d)\u201d\nrefers to the documented policy developed by a Regulated Person which\noutlines its expectations for training and continuing professional\ndevelopment of its employees.\n\n4.1.4. \u201cKey Person\u201d refers to any person who is acting in a Controlled\nFunction as defined under the Authority\u2019s Policy on Fitness and Propriety\nand includes, but is not limited to, a Director, Partner, Money Laundering\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 6 of 13\nReporting Officer and Anti-Money Laundering Compliance Officer of a\nTCSP.\n\n4.1.5. The \u201cGoverning Body\u201d of a Regulated Person is the Board of Directors\nwhere the Regulated Person is a corporation, the General Partner where\nthe Regulated Person is a partnership, the manager (or equivalent)\nwhere the Regulated Person is a Limited Liability Company, and the\nTrustee or the Board of Trustees where the Regulated Person is a trust\nbusiness.\n\n4.1.6. \u201cRegulated Person\u201d for the purpose of this RSOG means a natural or\na legal person, or arrangement that has been approved, licensed,\nregistered\nor\nsupervised\nby\nthe\nAuthority\npursuant\nto\nthe\nrelevant regulatory Acts under the Scope of Application.\n\n4.1.7. \u201cTCSPs\u201d refer to those who undertake any one or more of the following\nactivities pursuant to the BTCA or the CMA as applicable:\n\na)\nacting as a Corporate or Partnership formation agent;\nb)\nacting as (or arranging for another person to act as) a Director,\nSecretary or Official of a Company or a Partner of a Partnership\nor as a Foundation Official;\nc)\nproviding administration or management of a Trust, Company,\nPartnership, Foundation or for any other legal person or legal\narrangement;\nd)\nproviding\nregistered\noffice,\nbusiness\naddress\nfor\naccommodation, correspondence for administrative address for\na Company, Partnership, Foundation or for any other person;\ne)\nacting as a Resident Agent1 for the purposes of meeting the\nrequirements\nto\nhold\nbeneficial\nownership\nor\ninterest\ninformation;\nf)\nacting as (or arranging for another person to act as) a Trustee\nof an Express Trust;\ng)\nacting as (or arranging for another person to act as) a Nominee\nShareholder for another legal person;\nh)\nPersons who act as Executors and Administrators; and\ni)\nestablishing and maintaining beneficial ownership registers on\nbehalf of companies and limited liability companies incorporated\nor formed in the Islands, offering an information technology\nsolution to those companies and limited liability companies to\nmake extracts of information on the beneficial ownership\nregister searchable by the competent authority established\nunder Part XVIIA of the Companies Act and responding to\nrequests from the competent authority about whether a\ncompany, a limited liability company or a subsidiary of the same\nis exempted from the application of that Part or of Part 12 of the\nLimited Liability Companies Act.\n\n1Consistent with Section 3(1) (ba) of the CMA, Resident Agent means an agent establishing and maintaining beneficial ownership\nregisters on behalf of companies and limited liability companies incorporated or formed in the Cayman Islands.\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 7 of 13\n\n5.\nRecruitment of Key Persons\n\n5.1.\nRecruitment Stage\n\nApproval of Candidates\n\n5.1.1. A Regulated Person must obtain the Authority\u2019s approval before the\nappointment of a Key Person.\n\n5.1.2. A Regulated Person should evaluate and assess candidates for the role of\na Key Person to ensure that they are fit and proper to perform the role\nfor which they are applying.\n\n5.1.3. The Authority will assess candidates for the role of Key Persons, as\nsubmitted by the Regulated Person, consistent with the Authority\u2019s\nRegulatory Policy on Fitness and Propriety.\n\n5.1.4. The Authority reserves the right to approve or reject such an\nappointment in accordance with all applicable Acts in the jurisdiction and\nany relevant regulatory measures issued by the Authority from time to\ntime.\n\nPolicies and Procedures\n\n5.1.5. A Regulated Person should establish and maintain appropriate\nrecruitment policies and procedures commensurate with the size,\ncomplexity, structure, nature of business and risk profile of its\noperations that have been approved by the Governing Body.\n\n5.1.6. A Regulated Person should review its recruitment policies and\nprocedures, at least annually, and update them if necessary, to ensure\nthat they continue to align with business and staffing needs and industry\ndevelopments.\n\n5.1.7. The Authority expects that at a minimum, the recruitment policies and\nprocedures should capture the following to ensure they are appropriate\nand comprehensive:\n\na)\nthe Regulated Person\u2019s overarching and fundamental objective\nof recruitment and selection and onboarding procedures;\nb)\nthe Regulated Person\u2019s commitment to fair and transparent\nrecruitment processes;\nc)\nan appropriate record of job descriptions for all advertised roles.\nThese job descriptions should provide all candidates with a clear\nunderstanding of the role; purpose, accountabilities, and\nresponsibilities, along with the requirements, knowledge, skills,\nand experience required for the role; and\nd)\ninclude a methodology for assessing the fitness and propriety of\ncandidates offered contracts of employment or functions within\nthe Regulated Persons. Considerations include, but are not\nlimited to: honesty, integrity and reputation; competence and\ncapability; and financial soundness.\n\nR\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 8 of 13\n5.1.8. A Regulated Person should be able to demonstrate that it has evaluated\nhow a candidate\u2019s knowledge, skills, experience, and qualifications meet\nthe requirements for the role, as outlined in the job description. In\naddition, the Regulated Person should be able to demonstrate that they\nhave taken reasonable steps to verify the candidate\u2019s relevant\ninformation before onboarding the candidate.\n\n5.1.9. A Regulated Person should be able to demonstrate that it has adequately\nassessed\nand\nverified\ncandidates\u2019\nreferences,\nmembership\nin\nprofessional bodies (if applicable), criminal records, regulatory censure,\nfinancial soundness, professional reprimands, sanctions, conflicts of\ninterest, legal proceedings and any other formal censure, discipline, or\npublic criticism at the recruitment stage, as part of its fitness and\npropriety assessment on the candidate.\n\n5.1.10. A Regulated Person should ensure that its recruitment, selection and\nemployment practices are fair, transparent and in compliance with all\napplicable Acts in the Cayman Islands and any relevant regulatory\nmeasures issued by the Authority from time to time.\n\n5.1.11. A Regulated Person should ensure there is adequate staffing to meet the\nrequirements of the Regulated Person\u2019s business plan to support the\nlicence held2.\n\n5.2.\nPost-Recruitment Supervision of Key Persons\n\n5.2.1. A Regulated Person should ensure Key Persons remain competent, fit\nand proper and able to effectively carry out their roles and\nresponsibilities and that the level of competence is commensurate with\nthe size, complexity, structure, nature of business and risk profile of its\noperations.\n\n5.2.2. A Regulated Person must notify the Authority immediately on becoming\naware of significant changes that adversely affect the fitness and\npropriety of its approved Key Persons.\n\n5.2.3. A Regulated Person must notify the Authority of a cessation of its\napproved Key Persons within twenty-one (21) days.\n\n5.2.4. A Regulated\nPerson should annually\nreview the\ncompetence,\nqualifications, knowledge, and skills of its Key Persons to ensure that\ntheir level of competence remains commensurate with the size,\ncomplexity, structure, nature of business and risk profile of its\noperations. Appropriate measures should be taken to address any gaps\nidentified.\n\n5.2.5. A Regulated Person should consider and assess changes in Key Persons\u2019\nperformance and behaviour, at least annually, and put measures and\ncontrols in place to address any misconduct or underperformance.\n\n5.2.6. A Regulated Person should ensure that the responsibilities and authority\nof each Key Person are clearly documented and communicated.\n\n2Where outsourced service providers are utilised to meet staffing needs, Regulated Persons should refer to the Statement of\nGuidance on Outsourcing for Regulated Entities.\nR\nR\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 9 of 13\n5.2.7. Job descriptions should be reviewed as appropriate to ensure they are\nup-to-date, accurate, clear, and helpful to candidates and current Key\nPersons.\n\n5.2.8. Reviews of job descriptions should evaluate and make accommodations\nfor the needs of Key Persons, such as additional skills or qualifications,\nwhere they have entered a new role, or where their role has changed or\nexpanded in scope. Reviews should also consider any changes in the\nsize, complexity, structure, nature of business and risk profile of the\nRegulated Person\u2019s operations.\n\n5.2.9. A Regulated Person should have effective systems and processes to\nensure that Key Persons are appropriately supervised. These systems\nand processes should be documented and communicated to all Key\nPersons.\n\n5.2.10. To support the adequate supervision of Key Persons, the policies and\nprocedures that the Regulated Person has in place should be appropriate\nto the knowledge, skills and pertinent experience of each Key Person\nand should include the following:\n\na)\noverarching reporting lines;\nb)\nreporting relationships between a Key Person and a\nsupervisor;\nc)\ninternal escalation processes for staff-related matters;\nd)\nchanges in reporting lines;\ne)\nmultiple reporting lines; and\nf)\nthe method and frequency of advising Key Persons of such\nreporting relationships.\n\n6.\nDirectorship Services Obligations\n\n6.1.\nThe Governing Body should undertake self-assessments of the performance of\nthe Governing Body collectively and its individual members to ensure they\nremain competent to carry out the recruitment, supervision, and training\nstandards of the Regulated Person.\n\n6.2.\nWhere a Regulated Person licensed under the CMA is acting as or fulfilling the\nfunction of, or arranging for another person to act as or fulfil the function of,\ndirector or alternate director of a company, the Regulated Person, licensed\nunder the CMA, should ensure the director or alternate director understands his\nor her duty to:\n\na)\nact openly, honestly and in good faith, at all times, and exercise\nindependent judgment, always acting in the best interests of the client.\nb)\ncarefully consider all decisions and understand the potential negative\nimplications for the client company, its shareholders or its customers.\nc)\nmaintain a thorough knowledge and understanding of the client\u2019s\nbusiness and update his\/her knowledge periodically, consistent with\nchanges in the industry, regulatory landscape or business of the client.\nd)\nsatisfy himself or herself that an appropriate and timely course of action\nis being taken to address any concerns raised.\ne)\nsatisfy himself or herself that the client, its governing body, its service\nproviders, and advisors are acting in accordance with the client\u2019s\nconstitutional documents and any other documents directing the\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 10 of 13\nmanagement and operation of the client and\/or its advisors or service\nproviders.\n\n7.\nOngoing Training and Continuing Professional Development\n\n7.1.\nA Regulated Person should have a documented CPD Policy which sets out\nongoing training and CPD requirements for all employees including Key\nPersons, which should be commensurate with the size, complexity, structure,\nnature of business and risk profile of its operations.\n\n7.2.\nA Regulated Person\u2019s CPD Policy should be reviewed and approved by the\nGoverning Body at least every three years, or earlier if needed, to ensure that\nthe CPD Policy continues to meet the training needs of the Regulated Person.\n\n7.3.\nIn developing the CPD Policy, a Regulated Person should make accommodations\nfor Key Persons whose roles have changed or expanded in scope, or who have\nentered new roles. Similarly, a Regulated Person should consider changes to\nany legal and regulatory requirements, market developments and any other\nchanges impacting the role of the Key Person.\n\n7.4.\nA Regulated Person may rely upon both internal training resources as well as\nappropriate external sources in developing a training and CPD programme. A\nRegulated Person should satisfy itself with the quality of the training materials\nand the standard of the training programmes when selecting CPD activities and\nensure that the contents of such courses are commensurate with the Key\nPerson\u2019s role and responsibilities.\n\n7.5.\nWhere a Key Person holds a relevant professional qualification, designation, or\nis a member of a relevant professional body or association that requires the\ncompletion of a certain number of CPD hours, the Regulated Person should\nensure that the Key Person complies with such CPD requirements. A Regulated\nPerson may, as appropriate, use a Key Person\u2019s professional development\nhours, earned in meeting the CPD obligations of their professional qualification\nor membership, towards meeting the minimum number of training hours\nspecified in the Regulated Person\u2019s own CPD Policy.\n\n8.\nActivities\nRelevant\nfor\nTraining\nand\nContinuing\nProfessional\nDevelopment\n\n8.1.\nCPD activities may include, but are not limited to, a varied mix of the following:\n\na)\ntraining courses and activities provided by the Regulated Person;\nb)\nindustry workshops;\nc)\nlectures and exam training;\nd)\nconferences and seminars;\ne)\nuniversity courses;\nf)\ncertification courses;\ng)\ndistance learning which requires active participation;\nh)\nself-study with Independent Assessments; and\ni)\npublication of research papers and journal articles.\n\n8.2.\nRelevant CPD topics for Key Persons should be commensurate with the Key\nPerson\u2019s role and responsibilities, and include inter alia, the following topics,\nwhich may be relevant to the Regulated Person\u2019s specific business operations:\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 11 of 13\na)\nEnterprise-wide Risk Management;\nb)\nAnti-money Laundering and Countering Terrorist Financing Risk;\nc)\nOther relevant financial, operational and emerging risks;\nd)\nApplicable Compliance, Legislative and Regulatory Standards;\ne)\nBusiness Conduct and Ethical Standards;\nf)\nNew Financial Products in the Industry and the Associated Risks;\ng)\nManagement Information Systems and Technological literacy;\nh)\nGeneral Management and Governance; and\ni)\nFinancial Reporting and Quantitative Analysis.\n\n9.\nRecord Keeping\n\n9.1.\nA Regulated Person must keep all recruitment and selection records in\naccordance with requirements outlined in the Rule and Statement of Guidance\n\u2013 Nature, Accessibility and Retention of Records for Licensees Conducting the\nBusiness of Company Management.\n\n9.2.\nA Regulated Person should keep the appropriate records related to their\nrecruitment processes. Records should include, at a minimum:\n\na)\nrecords relating to hiring decisions including decisions to refuse or reject\na candidate;\nb)\nrecords relating to complaints about the hiring process or appeals to any\ndecisions taken to transfer, promote, demote;\nc)\nadvertisements or notices to the public or Key Persons about openings,\npromotions, and\/or training opportunities;\nd)\njob descriptions for existing and advertised positions;\ne)\njob applications, resumes, interview notes and records;\nf)\nrecords relating to fitness and propriety checks; and\ng)\ndates hired, promoted, demoted, transferred.\n\n9.3.\nA Regulated Person should also keep proper records of CPD activities, including\nthe details of the training conducted and the attendance records for persons\nwho have completed the training.\n\n9.4.\nRecords should demonstrate how the training relates to and supports persons\nremaining competent in their role.\n\n9.5.\nAs a best practice, a Regulated Person should encourage Key Persons to keep\nproper records of their own CPD activities including, as applicable:\n\na)\nname of course attended;\nb)\ntopic or subject matter;\nc)\ndate of attendance;\nd)\nnumber of hours; and\ne)\nassessment results.\n\n10.\nEnforcement\n\n10.1. Whenever there has been a breach of the Rules included in this document, the\nAuthority\u2019s policies and procedures, as contained in its Enforcement Manual,\nwill apply in addition to any other powers provided in the relevant Acts and the\nMAA.\n\nR\n\nRule and Statement of Guidance\n Recruitment and Selection Standards for Trusts\nand Corporate Service Providers and Company Managers\n\nCayman Islands Monetary Authority\n\nPage 12 of 13\n11.\nEffective Date\n\n11.1. This Rule and Statement of Guidance will come into effect within six (6)\nmonths of the date that it is published in the Gazette.\n\nCayman Islands Monetary Authority\n\nPage 13 of 13","akn_extracted_at":"2026-06-22 15:40:07.971341+00","cms_id":"2024-0082","law_type":"subordinate","year":"2024","number":"82","title":"Rules and Statement of Guidance \u2013 Recruitment and Selection Standards for Trust and Corporate Service Providers and Company Managers \u2013 October 2024","status":"in_force"},"provenance":{"files":[{"file_id":"5198","expr_id":"303","kind":"akn_xml","filename":"2024-0082_SL 82 of 2024.akn.xml","source_url":null,"storage_path":"\/Users\/q\/kyleg-data\/working\/SUBORDINATE\/2024\/2024-0082\/2024-0082_SL 82 of 2024.akn.xml","content_md5":"5096394a590ddacb63169929967302c1","byte_size":"27462","http_last_modified":null,"fetched_at":"2026-06-22 15:40:08.087163+00"},{"file_id":"605","expr_id":"303","kind":"pristine_pdf","filename":"2024-0082_SL 82 of 2024.pdf","source_url":"\/cms\/images\/LEGISLATION\/SUBORDINATE\/2024\/2024-0082\/2024-0082_SL 82 of 2024.pdf","storage_path":"\/Users\/q\/kyleg-data\/pristine\/SUBORDINATE\/2024\/2024-0082\/2024-0082_SL 82 of 2024.pdf","content_md5":"485eaedc48220dd9b050bfab0577f161","byte_size":"542547","http_last_modified":null,"fetched_at":"2026-06-21 23:09:36.33624+00"},{"file_id":"606","expr_id":"303","kind":"working_pdf","filename":"2024-0082_SL 82 of 2024.pdf","source_url":"\/cms\/images\/LEGISLATION\/SUBORDINATE\/2024\/2024-0082\/2024-0082_SL 82 of 2024.pdf","storage_path":"\/Users\/q\/kyleg-data\/working\/SUBORDINATE\/2024\/2024-0082\/2024-0082_SL 82 of 2024.pdf","content_md5":"485eaedc48220dd9b050bfab0577f161","byte_size":"542547","http_last_modified":null,"fetched_at":"2026-06-21 23:09:36.33624+00"}],"paragraph_count":101,"latest_history":null},"quality":{"expr_id":"303","doc_id":"303","quality_state":"known_issue","quality_score":"59","needs_human_review":"t","deterministic_categories":"{duplicate_text,page_header_footer_noise,title_mismatch}","llm_categories":"{truncated_text,other}","repair_actions":"{collapse_duplicate_text,manual_review,reextract_full_text,strip_page_furniture,verify_title_metadata}","finding_severity_counts":"{\"low\": 1, \"medium\": 1}","finding_summary":"Sample appears mostly clean but shows truncation in definitions section and possible header duplication; human review recommended to confirm completeness.","assessed_at":"2026-06-22 15:29:46.129529+00","updated_at":"2026-06-22 15:29:46.129529+00"}}