The finding comes first
Simplified due diligence in Cyprus law is a permission, and its condition comes first. A firm may lighten the measures provided it has already satisfied…
Simplified due diligence in Cyprus law is a permission, and its condition comes first. A firm may lighten the measures provided it has already satisfied…
Cyprus law sets no timetable for a firm's own money laundering risk assessment. It says the assessment is kept up to date. "Annually" is ICPAC's word, and…
Most firms go back to a client's due diligence when something new happens: a new deal, a new owner, a bigger sum. Cyprus law also sends them back when…
Cyprus law requires the compliance officer to be senior. It does not require a board seat. Senior, as the Law defines it, means knowing enough about the…
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…
A client you never meet in person is not, by that fact alone, a higher-risk factor under Cyprus law. The factor is a remote relationship or transaction…
Cyprus AML law asks a firm for two different things about what its own staff know, and it is easy to do one of them and count it as both. Telling people…
Section 58 of the Law lists the things a firm's anti-money-laundering procedures have to cover. Client due diligence is the first item on that list. The…
Bolt a new tool onto a service your firm has sold for ten years, and nothing about that service is new. Cyprus law still wants the money laundering risk…
Cyprus AML law asks for an independent internal audit service only when your size and the nature of what you do call for one. It attaches no such…
Ask a firm where its client acceptance policy lives and you usually get a form: the questionnaire a new client fills in on day one. ICPAC's Directive uses…
The compliance officer's annual report is not a filing. Under ICPAC's Directive it goes to your own board, it should be used to formulate an action plan…
Your AML manual is a record of what your firm actually does. It is not a statement of what it means to do. ICPAC writes the duty in the past participle…
A sanctions hit has two endings. Either the person on your file is the person on the list, or they are not. Bad press has neither ending. It is not…
Cyprus law makes you end a client relationship on your own initiative for exactly one reason: you could not finish the customer due diligence. Not that…
Cyprus law names the kinds of transaction you have to examine. Nothing tells you what should actually stop one. You set the thresholds. You write the red…
Most people picture a suspicious transaction report as something you send to MOKAS. In Cyprus you almost certainly do not send it. You report to one named…
Three lists bind a firm in Cyprus, and a statute names them: EU restrictive measures, UN Security Council sanctions, and the Republic's own national…
Where the money came from and how the person came to have it are two different questions. Cyprus law asks both, of the customer and of the beneficial…
Most firms keep client files long after the relationship ends. They treat it as the safe side of the line. Cyprus law does not see it that way. Section 68…
Cyprus law lets you rely on another firm for three of the four due diligence measures: identify the customer, identify the beneficial owner and who…
Cyprus law says exactly what enhanced due diligence means in the cases it names, such as a high-risk third country or a politically exposed person. For…
A compliance officer opening a new file is not asking what risk is, but what they will have to show. The duty sits in L.188(I)/2007, not in a supervisor's…
A compliance officer schedules a periodic review. The Law schedules a measure; the review performs half of it. Section 61(1) of L.188(I)/2007 says the…
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