Off one list, not the table

The Cyprus Bar Association has told its members that Vietnam and Panama are off the EU's list of non-cooperative tax jurisdictions, and in the same circular it prints a table that still lists Vietnam, under two other lists. Coming off one list moves one column, not the row.

Circular 17/2026, dated 9 October 2026, went to all members from the Bar Association's Supervision and Compliance Department. It informs them of the revision of the EU tax list, according to an announcement of the Council of the European Union, and names the two removals. It is in Greek; the translations here are mine.

The circular then links four more sources: the EU list of high-risk third countries; the FATF list of, in its words, non-cooperative and other jurisdictions under monitoring; the Global Terrorism Index 2026; and the Basel index on money laundering. Its Table 1, titled a consolidated list of high-risk countries and other jurisdictions, has 37 rows and three columns: EU high risk, FATF, and the EU list of non-cooperative jurisdictions for tax purposes. The two indices have no column, so the table is not a summary of everything the circular points to.

Vietnam is row 11. It carries a mark in the EU high-risk column and one in the FATF column, and none in the tax column. Eight rows are marked in the tax column; Vietnam's is not one of them. Panama is not in the table at all. That is all the table shows about either, and this note reads nothing further into it.

One caution on the FATF column. Its header reads FATF non-coop. The circular's own link describes the FATF list as non-cooperative and other jurisdictions under monitoring. A mark in that column is a mark in that column; the table does not say which kind of FATF listing sits behind it.

The practical point is about how a firm records the news. A client file that notes Vietnam as delisted is right about one column. The Bar Association's own table, sent with the news, still names Vietnam under the other two. Whatever weight a firm gives those two lists in its own risk assessment, the tax delisting does not remove them.

The circular is careful about what it requires. On using the lists, it writes «Καλούνται όλα τα μέλη του Π.Δ.Σ. όπως λαμβάνουν υπόψιν τους τις πιο κάτω λίστες»: all members of the Bar Association are called on to take the lists below into account, in applying due diligence procedures and measures generally, and specifically in setting their client acceptance policy and the assessment of their clients' risk. It names no enhanced measure, no statutory provision and no consequence for any column.

Its last sentence is firmer. The lists, it says, are amended at regular intervals, and «υποχρεούστε όπως παρακολουθείτε και εφαρμόζετε οποιεσδήποτε μελλοντικές αναθεωρήσεις»: you are obliged to monitor and apply any future revisions. Called on to take the lists into account; obliged to monitor and apply their revisions. Both verbs are the Bar Association's.

That makes the table a snapshot. It is what the circular printed, and the circular itself says the lists behind it are amended at regular intervals. A firm that copies the 37 rows into its onboarding checklist has copied a date as much as a list.

A delisting moves one column, not the row. And the next revision will be the member's to follow, because that is the part the Bar Association wrote as an obligation.

Not legal advice. Verify against the primary source before acting.

Sources

• PRIMARY.

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