The country-risk section of most files records where Cyprus stands on the four lists; almost none record when you checked. That date is the part that matters. The FATF call-for-action and increased-monitoring lists, the EU high-risk third-country list and Annex I of non-cooperative tax jurisdictions all change several times a year, so a status from March is a different fact by September. When a client, a beneficial owner or a payment corridor touches Cyprus, the file needs the position and the date it was verified, or the snapshot has no timestamp. This week, open the files you are defending and write the check date next to each of the four statuses.
https://firm.cy/aml-country/cyprus
Not legal advice. Verify against the primary source before acting.
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