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Regulator commentary, weekly briefings and country/sanctions analysis from FIRMCY · RSS
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10 September 2026 · Practice notes

Bad press is not a match

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…

9 September 2026 · Country risk

Cyprus AML

The country-risk section of most files records where Cyprus stands on the four lists; almost none record when you checked. That date is the part that…

8 September 2026 · Practice notes

Risk is not the exit trigger

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…

8 September 2026 · Practice notes

Would a stranger agree

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…

8 September 2026 · Sanctions movements

253 list changes in 28 days

The last 28 days on the sanctions lists, 11 August – 7 September 2026: 253 changes — 178 additions, 18 removals and 57 amendments across the EU, OFAC, UK…

6 September 2026 · Sanctions movements

1 removals, zero all-clears

1 names came off the sanctions lists in the week of 31 August – 4 September 2026. 1 of them came off under programme US-RUSHAR. A removal is not an…

5 September 2026 · Sanctions movements

The week dissected: 11 changes

The week dissected, 31 August – 4 September 2026: 6 additions, 1 removals and 4 amendments across the EU, OFAC, UK and UN lists. Who the entries concern…

4 September 2026 · Insights

Weekly AML briefing

This week's AML briefing in one paragraph. This week's developments are limited to an ICPAC sanctions alert (no. 8/2026) and a technical alert, plus a CBA…

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…

4 September 2026 · Change log

6 OFAC added

6 added, 1 removed, 1 amended on the sanctions lists on 4 September 2026. The bulk landed in OFAC's Cuba programme (US-CUBA, 6 entries). Top country by…

3 September 2026 · Practice notes

Hand it up, say nothing

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…

3 September 2026 · Practice notes

Three bind, OFAC does not

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…

3 September 2026 · Change log

3 UK amended

3 amended on the sanctions lists on 3 September 2026. The bulk landed in programme GB-RUS (3 entries). Top country by count: Russia (1 entries). Bulk…

1 September 2026 · Practice notes

Two questions, not one

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…

1 September 2026 · Practice notes

Keep it, then delete it

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…

1 September 2026 · Sanctions movements

958 list changes in 28 days

The last 28 days on the sanctions lists, 4–31 August 2026: 958 changes — 239 additions, 43 removals and 676 amendments across the EU, OFAC, UK and UN…

31 August 2026 · Weekly briefing

The week in AML

The quiet weeks are the ones that catch files out. This week the only item that touches every obliged entity is the ICPAC alert 8/2026 — and it's the one…

30 August 2026 · Sanctions movements

14 removals, zero all-clears

14 names came off the sanctions lists in the week of 24–28 August 2026. 13 of them came off under OFAC's counter-terrorism programme (US-TERR). A removal…

29 August 2026 · Sanctions movements

The week dissected: 137 changes

The week dissected, 24–28 August 2026: 114 additions, 14 removals and 9 amendments across the EU, OFAC, UK and UN lists. Who the entries concern: 46…

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…

28 August 2026 · Change log

1 UN amended

1 amended on the sanctions lists on 28 August 2026. The bulk landed in Taliban sanctions (UN-SC1988, 1 entries). Top country by count: Afghanistan (1…

27 August 2026 · Practice notes

Rely on three, own all four

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…

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