A one-off job under €15,000 is not, by that fact alone, outside due diligence. In Cyprus law €15,000 is one of several amounts, each tied to a particular kind of firm or transaction. And one trigger carries no amount at all: suspicion.
The source is section 60 of L.188(I)/2007, which speaks to every obliged entity. ICPAC's AML Directive, issued under section 59(4) of the same Law, restates part of it for accountants. The Law is Greek, no official English version was in front of me, and every English rendering here is mine.
Start with what makes a job occasional, because the Law defines it. Section 2: «"μεμονωμένη συναλλαγή" σημαίνει οποιαδήποτε συναλλαγή εκτός από συναλλαγή η οποία διεξάγεται κατά τη διάρκεια επιχειρηματικής σχέσης». An occasional transaction means any transaction other than one carried out during a business relationship. A business relationship, in the same section, is one the firm expects, at the time contact is made, to have some duration. Plainly: the occasional transaction is the one-off, done outside any relationship. ICPAC's Directive defines the term in nearly the same words.
Now section 60. Its opening line is «Υπόχρεες οντότητες εφαρμόζουν τις διαδικασίες προσδιορισμού ταυτότητας και τα μέτρα δέουσας επιμέλειας ως προς τον πελάτη στις εξής περιπτώσεις» — obliged entities apply the identification procedures and customer due diligence measures in the following cases. The verb is «εφαρμόζουν». Apply. Case (β)(i) is the one everybody remembers: when they carry out an occasional transaction that «ανέρχεται σε ποσό ίσο ή μεγαλύτερο από δεκαπέντε χιλιάδες ευρώ (€15.000), ανεξάρτητα από το αν η συναλλαγή διενεργείται με μία μόνη πράξη ή με περισσότερες πράξεις μεταξύ των οποίων φαίνεται να υπάρχει κάποια σχέση» — amounts to €15,000 or more, regardless of whether it is carried out in a single operation or in several operations between which there appears to be some connection. Plainly: €15,000 counts across pieces that look connected, not per invoice.
The same section sets other amounts, and each comes with its own qualifier. Case (β)(ii): an occasional transaction that is a transfer of funds as defined in paragraph 9 of Article 3 of Regulation (EU) 2023/1113, for an amount over €1,000. Case (ε): for gambling service providers and the Casino, when collecting winnings, when placing the stake, or both, transactions of €2,000 or more, in one operation or in several between which there appears to be some connection. Case (ζ): for crypto-asset service providers, an occasional transaction that amounts to or exceeds €1,000, again single or connected. Plainly: €15,000 is the general figure for an occasional transaction. A transfer of funds in the Regulation's sense and a crypto-asset service provider's occasional transaction each have a lower one, and gambling providers and the Casino have a €2,000 rule whose text does not say occasional at all. Mind the wording, too: the transfer limb is over €1,000, the crypto limb is €1,000 or more.
Two more cases in the list carry no amount. Case (α) is entering into a business relationship. Case (δ) is doubt about the accuracy or adequacy of the documents, data or information gathered earlier to verify an existing client's identity.
And then case (γ), the one this card is about: «όταν υπάρχει υποψία νομιμοποίησης εσόδων από παράνομες δραστηριότητες ή χρηματοδότησης της τρομοκρατίας ανεξάρτητα από το ποσό της συναλλαγής και ανεξάρτητα από οποιαδήποτε παρέκκλιση, εξαίρεση ή κατώτατο όριο δυνάμει των διατάξεων του παρόντος Νόμου». When there is a suspicion of money laundering or terrorist financing, regardless of the amount of the transaction and regardless of any derogation, exemption or threshold under the provisions of this Law. Plainly: two «ανεξάρτητα», and the second one is wide. It does not only say the amount is irrelevant. It says no threshold, exemption or derogation anywhere in the Law switches this case off.
The Law draws the same line itself elsewhere. Section 61Γ(2) has the trustee of an express trust, or a person in an equivalent position in a similar arrangement, disclose that status to obliged entities and provide the beneficial-ownership information when entering into a business relationship or carrying out an occasional transaction that exceeds the thresholds in paragraphs (β), (ε), (στ) and (ζ) of section 60. Paragraph (στ) has since been deleted. Paragraph (γ) is not on the list. It has no threshold to exceed.
One limit, so the point is not overstated. Section 61(7) lets an obliged entity not complete the measures where completing them may constitute an offence under section 48, the disclosure offences, and in that case it informs the Unit immediately. ICPAC's 5.3.4 says the same in its own terms, naming the tipping-off offence.
ICPAC's restatement is narrower than the section it restates. At 5.3.1 the Directive says firms must apply CDD before entering into a business relationship or carrying out an occasional transaction, and lists four cases: a business relationship; an occasional transaction equal to or higher than €15,000, single or in operations which appear to be linked; a suspicion of money laundering or terrorist financing, regardless of the amount; and doubts about previously obtained CDD. The €1,000 and €2,000 limbs are not there, and the suspicion line carries the amount clause but not the words about derogations, exemptions and thresholds. For those, the Law is the text. ICPAC adds two things of its own: a definition of suspicion as suspecting something wrong without proof or evidence, where the person reporting does not have to be 100% certain; and, at 5.3.2, suspicions first in its list of what can trigger a CDD update for an existing client.
What neither text gives you is a rule for when operations "appear" connected, or over what period. The Law uses the phrase and stops. That judgement is the firm's.
So, and this part is mine and not a requirement anywhere: do not let the intake form ask "is it over €15,000?" as the only gate. Ask whether this is a one-off or a relationship; which of the section 60 amounts apply to your kind of firm; whether this job looks connected to others for the same client; and whether anything about it makes you suspicious. A yes to the last question brings due diligence in at any amount, and section 62(1) puts the identity check before the transaction, not after it.
Under the threshold, the amount stops deciding for you. Suspicion never had an amount to begin with.
Not legal advice. Verify against the primary source before acting.
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