USA AML

The most under-documented exposure in a Cyprus AML file isn't an offshore centre. It's the United States.

Clients treat the USA as the safe answer, so the country-risk section gets one line and no work. In practice the file should carry four separate positions — FATF call-for-action, FATF increased monitoring, the EU high-risk third-country list, and Annex I of non-cooperative tax jurisdictions — each with the date you checked it. Those lists are republished several times a year, and a position with no check date is the part that fails when the auditor asks.

This week, open one US-connected file and confirm all four sit in it, dated.

Read: https://firm.cy/aml-country/united-states

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

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