Cyprus: Money Laundering

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Article
Business-Wide Risk Assessment (BWRA): New Cyprus Bar Association Guidance And The 2027 AMLR Deadline
The Cyprus Bar Association has issued its first Guidelines on Business-Wide Risk Assessment (BWRA), establishing a comprehensive framework for supervised entities to identify and mitigate money laundering, terrorist financing and sanctions risks. These guidelines provide practical direction for compliance with the new EU Anti-Money Laundering Regulation ahead of its July 2027 implementation deadline, outlining methodologies for risk assessment, control evaluation and ongoing monitoring requirements.
Cyprus Government
Frangos Law
Article
Jenec And The Limits Of Automatic De-risking In EU Banking Law
The Court of Justice of the European Union has ruled that banks cannot automatically refuse to open basic payment accounts solely because an applicant appears on a third-country sanctions list, such as OFAC. While such designations constitute relevant risk factors, financial institutions must conduct individual, proportionate assessments demonstrating that AML and sanctions-related risks cannot be adequately managed through appropriate measures.
Cyprus Finance
EN
Elias Neocleous & Co LLC
Article
Jenec: The Limits Of Automatic De-Risking In EU Banking Law
On 11 June 2026, the Court of Justice of the European Union (the “Court”) delivered its judgment in Case C-81/24, Jenec. The case concerned the relationship between the right of access to a payment account with basic features under Directive 2014/92/EU (the “Payment Accounts Directive”) and the AML/CFT obligations imposed on financial institutions under Directive (EU) 2015/849 (the “AML Directive”).
Cyprus Finance
EN
Elias Neocleous & Co LLC
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