Συμμόρφωση AML/KYC στην Κύπρο

Cyprus AML framework

The Cyprus Prevention and Suppression of Money Laundering Activities Law (188(I)/2007, most recently significantly amended in 2021) transposes EU AML directives (4AMLD, 5AMLD, and 6AMLD) into Cyprus law. The Law is administered by MOKAS (Unit for Combating Money Laundering) with sector-specific supervision by CySEC (investment firms), Central Bank of Cyprus (banks), ICPAC (auditors and accountants), Cyprus Bar Association (lawyers), and CySEC/DROCIP (corporate service providers).

Obligated entities must implement risk-based AML/CFT programmes proportionate to their business.

Customer Due Diligence (CDD)

Obligated entities must perform CDD before establishing a business relationship, executing occasional transactions above thresholds, or when suspicion of ML/TF arises. CDD includes: identification and verification of customer identity, identification and verification of ultimate beneficial owner (UBO), understanding purpose and intended nature of the business relationship, and ongoing monitoring of transactions.

Enhanced Due Diligence (EDD) applies to higher-risk categories including politically exposed persons (PEPs), non-face-to-face relationships, correspondent banking, complex ownership structures, and higher-risk jurisdictions.

MLCO and reporting obligations

Obligated entities must appoint a Money Laundering Compliance Officer (MLCO) at senior management level responsible for AML compliance, staff training, transaction monitoring, and SAR filing. The MLCO must be notified to the relevant supervisor. Suspicious Activity Reports must be filed with MOKAS through the goAML portal without delay when suspicion of ML/TF arises. Tipping off the customer is a criminal offence.

Annual reporting obligations vary by sector, typically including AML questionnaires, transaction volumes, and compliance programme summaries.

Beneficial Ownership Registry

Cyprus maintains a Beneficial Ownership Registry at the Registrar of Companies. Every Cyprus company, partnership, and express trust must submit UBO information (individuals holding >25% of shares or voting rights, or exercising control by other means). Failure to submit accurate UBO information triggers €100 daily fines plus €200 initial penalty. UBO data is accessible to competent authorities and, on legitimate interest basis, to certain third parties under EU rules.

When to engage AML/KYC specialists

AML compliance is a specialist field beyond routine bookkeeping. Engage specialist advisors for: initial AML programme design and MLCO recruitment/support, transaction monitoring system implementation, staff training programmes, response to supervisory audits, remediation of identified deficiencies, and complex customer risk assessments. Some Cyprus firms offer outsourced MLCO services for smaller regulated entities.

Ανεξάρτητες εταιρείες με τεκμηριωμένη εμπειρία σε Συμμόρφωση AML/KYC, ταξινομημένες κατά αξιολόγηση.

Οι εταιρείες που προσφέρουν Συμμόρφωση AML/KYC έχουν γραφεία στις παρακάτω περιοχές.

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