Vietnam Equity Holding – Application of the Cayman Islands Anti-Money Laundering Regime

Over the past few months the Board has been liquidating the Company’s investments.  This has been a successful process and the Board has managed to liquidate a majority of these investments resulting in a substantial amount of cash being available for redemption payments. The Board intends to make these payments shortly.

Redemptions by investors holding through nominees

Over the past year, there have been significant changes to the Cayman Islands anti-money laundering regime applicable to the Company. In particular, where it appears to the Board that underlying investors (“Underlying Investors“) have invested through financial institutions that act as their nominee (“Nominees“), the Board is obliged to satisfy itself that the Nominees hold documentary evidence verifying the identity and address of the Underlying Investors.

Further to the letter you were sent by email on 16 October 2018 (the “Prior Letter“), included as an Annex to this letter, you have been made aware that the Company is required to comply with the Anti-Money Laundering Regulations (2018 Revision) and its associated guidance notes (the “Regulations“).

The Prior Letter required you to provide the identification and verification information obtained in your role as Nominee in respect of the principal and any beneficial owner(s). You have not responded to the Prior Letter.

The Board believes that most Underlying Investors in the Company have invested through Nominees. Accordingly, the Company requires all financial institutions that have invested in the Company to:

  • (i) confirm in writing that they are not acting as a Nominee (i.e. that they are investing as principal on their own behalf and not on the instructions of an Underlying Investor); or
  • (ii) complete the form attached as Schedule 1, providing details of each Underlying Investor for whom they act as Nominee, and provide any verification of such information obtained by them.

Under regulation 18 of the Regulations where a person carrying out relevant financial business in the Cayman Islands, such as the Company, is unable to obtain information required by the Regulations to satisfy relevant customer due diligence measures the person shall not perform any transactions with or for that customer or shall terminate the relationship.

No redemption payments will be paid to any person that appears to be acting as a Nominee, until that person has provided all the information requested in Schedule 1 to the following email address:

Please do not hesitate to contact us for further information.

Yours sincerely

Alpay Ece

Director Vietnam Equity Holding