3 removals, zero all-clears
3 names came off the sanctions lists in the week of 21–25 September 2026. 2 of them came off under programme US-DRCONGO. A removal is not an all-clear…
3 names came off the sanctions lists in the week of 21–25 September 2026. 2 of them came off under programme US-DRCONGO. A removal is not an all-clear…
The week dissected, 21–25 September 2026: 0 additions, 3 removals and 85 amendments across the EU, OFAC, UK and UN lists. Who the entries concern: 85…
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…
When does a one-off job become a client relationship? For the professions that provide services rather than move money, lawyers, accountants and tax…
2 removed, 1 amended on the sanctions lists on 24 September 2026. The bulk landed in programme US-DRCONGO (2 entries). Top country by count: Congo (2…
Is Italy on the FATF or EU high-risk lists? Four lists carry the answer: FATF's call-for-action and increased-monitoring lists, the EU's high-risk…
The last 28 days on the sanctions lists, 25 August – 21 September 2026: 359 changes — 203 additions, 27 removals and 129 amendments across the EU, OFAC…
5 names came off the sanctions lists in the week of 14–18 September 2026. 2 of them came off under programme US-RUSSIA-EO14024. A removal is not an…
The week dissected, 14–18 September 2026: 16 additions, 5 removals and 3 amendments across the EU, OFAC, UK and UN lists. Who the entries concern: 9…
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…
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…
3 removed on the sanctions lists on 17 September 2026. The bulk landed in programme US-RUSSIA-EO14024 (2 entries). Top country by count: Switzerland (1…
Everyone checks the FATF list; almost nobody records the EU tax-jurisdiction list with a date. That's the UAE file that gets rejected in review. Four…
The last 28 days on the sanctions lists, 18 August – 14 September 2026: 416 changes — 237 additions, 16 removals and 163 amendments across the EU, OFAC…
The week dissected, 7–11 September 2026: 61 additions, 0 removals and 60 amendments across the EU, OFAC, UK and UN lists. Who the entries concern: 79…
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…
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…
19 added, 59 amended on the sanctions lists on 11 September 2026. The bulk landed in programme US-SDGT (16 entries). Top country by count: Afghanistan (13…
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