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16 October 2026 · Regulator commentary

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…

16 October 2026 · Regulator commentary

One long job can count

Does a one-off job become a client relationship only when the work comes back? AMLA's final draft EU standard adds a second question for lawyers, tax…

9 October 2026 · Regulator commentary

185 failed submissions

Cyprus's financial intelligence unit, MOKAS, says a suspicious transaction report fails submission if its narrative is not more than 400 and less than…

9 October 2026 · Regulator commentary

Old files, earlier clock

Customers you already have are not grandfathered. AMLA's final draft EU standard on customer due diligence says their files must be brought in line within…

25 September 2026 · Regulator commentary

Third party, or part of you

The Cyprus Bar Association's new guidelines on third-party reliance turn on the arrangement you have with the person doing the client work. One kind makes…

25 September 2026 · Regulator commentary

When the work comes back

When does a one-off job become a client relationship? For the professions that provide services rather than move money, lawyers, accountants and tax…

18 September 2026 · Regulator commentary

The seat, not the exam

Until 14 September 2026 the Cyprus Bar Association's compliance officer directive was about the certificate: how to sit the exam, and who could be excused…

11 September 2026 · Regulator commentary

Your copy May be the old one

The most useful column in ICPAC's new circular is the one nobody reads: the amendment date. ICPAC issued Compliance Circular 28/2026 on 10 September 2026…

11 September 2026 · Regulator commentary

Lighter is not fewer

Low risk is not a discount on the file. In AMLA's draft EU standard, simplified due diligence still identifies the customer, still identifies and verifies…

4 September 2026 · Regulator commentary

No income is not an exit

Held an ICPAC ASP licence on 31 December 2025? A new annual questionnaire is yours to file unless two things were both true last year: no ASP income and…

4 September 2026 · Regulator commentary

Who has to build the form

A common EU form for reporting suspicions is out in draft, and it does not land on every firm the same way. If your FIU's platform generates your reports…

28 August 2026 · Regulator commentary

The firm files, so do you

The Cyprus Bar Association's 2025 compliance questionnaire is not one filing per firm. Circular 14/2026 addresses it to self-employed lawyers, to salaried…

28 August 2026 · Regulator commentary

Residual risk is derived

A risk assessment that opens with "we are a medium-risk firm" has skipped the part that matters. AMLA's draft guidelines put a three-phase method behind…

21 August 2026 · Regulator commentary

The derogation has a clock

Cyprus onboarding desks rarely argue about whether verification is required. They argue about when, and how long a client can sit on the books unverified…

21 August 2026 · Regulator commentary

A draft, and a deadline

A Cyprus compliance officer who has wanted someone at EU level to say what ongoing monitoring actually requires now has a text to read and a window to…

20 August 2026 · Regulator commentary

Exiting is only half of it

Every practice has the file that will not close. Two of the four documents arrive, then the client goes quiet. ICPAC's AML Directive is direct about how…

20 August 2026 · Regulator commentary

Dormancy is not deletion

Most Cyprus lawyers who wound down an administrative-services practice think of it as something they stopped doing. The Bar Association's standing…

16 August 2026 · Regulator commentary

UN lists bind on their own

Most compliance officers in Cyprus watch the EU list. ICPAC's Sanctions Directive is written on the assumption that you watch three. ICPAC issues the…

16 August 2026 · Regulator commentary

ICPAC can arrive unannounced

Most firms treat an ICPAC inspection as something they will get time to prepare for. Regulation 4.602 is drafted on the opposite assumption. ICPAC adopted…

16 August 2026 · Regulator commentary

The same customers, fewer CASPs

The firms leaving the market deserve more of your attention than the ones staying. CySEC issued Circular C790 on 7 July 2026, six days after the MiCA…

16 August 2026 · Regulator commentary

Three laws, one new unit

If your sanctions procedure still cites the 2016 implementation law, it cites a law that has been repealed. CySEC issued Circular C724 on 1 August 2025 to…

16 August 2026 · Regulator commentary

Two registers, fifteen days

The Cyprus Bar Association issued Circular 02/2026 on 7 January 2026, through its Supervision and Compliance Department, addressed to obliged entities. It…

16 August 2026 · Regulator commentary

Thirty days, not 31 March

The Cyprus Bar Association issued Circular 01/2026 on 7 January 2026, through its Supervision and Compliance Department, to all members and obliged…

16 August 2026 · Regulator commentary

One risk score, sixteen lists

AMLA is consulting on the rules that will decide how your supervisor rates your firm, and for a small Cyprus practice that rating will normally be…

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Not legal advice. FIRMCY publishes this analysis for general informational purposes; verify against the primary sources before acting.