FIRMCY Insights

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Regulator commentary, weekly briefings and country/sanctions analysis from FIRMCY · RSS
Change logCountry & sector riskCountry riskFrom FIRMCYPractice notesRegulator commentarySanctions movementsSpotlightWeekly briefing
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…

16 August 2026 · Regulator commentary

Category three is the line

AMLA has harmonised the reasoning behind an enforcement decision rather than the price of one, and the provision that will decide most Cyprus files puts a…

15 August 2026 · Regulator commentary

One jurisdiction out of 149 is fully compliant

Six years after the FATF brought virtual-asset service providers inside the global AML framework, most of the world has still not finished implementing…

12 August 2026 · Country risk

USA AML

The USA line in a Cyprus country-risk section is usually the emptiest one in the file: everyone assumes the answer, so nobody writes it down. As of the…

11 August 2026 · Spotlight

TCSP: the product is the structure

Trust and company service providers sit in an unusual position: the sector's everyday product — companies, trusts, multi-jurisdiction structures — is the…

11 August 2026 · Spotlight

Large sums, one transaction

Real estate is repeatedly assessed as high-risk for money laundering for a structural reason: property absorbs large sums in a single transaction, holds…

11 August 2026 · Spotlight

Designed to break the audit trail

Virtual assets move value across borders in minutes, can be held pseudonymously, and sit outside the traditional banking rails — a combination regulators…

11 August 2026 · Regulator commentary

Risk is never a single number

Money-laundering risk is never a single number. Under the FATF risk-based approach, the EU AML Directives and Cyprus Law 188(I)/2007, a firm must run a…

11 August 2026 · Sanctions movements

1122 list changes in 14 days

The last 14 days on the sanctions lists, 28 July – 10 August 2026: 1122 changes — 323 additions, 130 removals and 669 amendments across the EU, OFAC, UK…

11 August 2026 · Practice notes

Risk rarely sits on the front company

Screening a single name tells you about that name. But money-laundering risk in a corporate client rarely sits on the front company — it sits somewhere in…

11 August 2026 · Regulator commentary

Geography comes first

Geographic risk comes before everything else in an AML file: is the client, the owner, or the money connected to a listed jurisdiction? Four public lists…

10 August 2026 · Weekly briefing

The week in AML

The CBA's 8th edition ASP guidance is the only item this week that touches a file you'll actually sign. Published 04/08/2026, it's the most significant…

10 August 2026 · From FIRMCY

firm.cy is now on Telegram

firm.cy is now on Telegram. Daily sanctions-list changes across the EU, OFAC, UK and UN lists, the weekly dissection, and CPD training announcements …

9 August 2026 · Sanctions movements

19 removals, zero all-clears

19 names came off the sanctions lists in the week of 3–7 August 2026. 7 of them came off under the EU's Iran programme (EU-IRN). A removal is not an…

8 August 2026 · Sanctions movements

The week dissected: 681 changes

The week dissected, 3–7 August 2026: 39 additions, 19 removals and 623 amendments across the EU, OFAC, UK and UN lists. Who the entries concern: 539…

7 August 2026 · From FIRMCY

The lists changed 9 of the last 11 days

Screening a client once is a snapshot; the lists keep moving. Since firm.cy began publishing the daily sanctions changelog on 28 July, the lists have…

7 August 2026 · Country & sector risk

Three lists set geographic risk

Geographic risk starts from three public lists, and they are not the same list. The FATF black list (call for action): 3 jurisdictions — Iran, North…

7 August 2026 · From FIRMCY

Screening that stands up to a regulator

We built FIRMCY for our own AML files first. Ioannou & Sharpe is a licensed Cyprus law firm — an obliged entity like the firms we act for — and the…

6 August 2026 · Change log

9 EU added

9 added, 19 removed on the sanctions lists on 6 August 2026. The bulk landed in the EU's Iran programme (EU-IRN, 10 entries). Top country by count: Iran…

5 August 2026 · Country risk

Greece AML

"Greece, EU member, low risk" is a conclusion, not an assessment — and supervisors have stopped accepting the difference. Greek exposure runs through…

4 August 2026 · Sanctions movements

252 added, 103 removed this week

The week on the sanctions lists, 27 July – 2 August 2026: 252 additions, 103 removals and 46 amendments across the EU, OFAC, UK and UN lists. The movement…

3 August 2026 · Weekly briefing

The week in AML

New EU Commission and UN Security Council restrictive measures. Three developments require attention this week. The European Commission and the UN…

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