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On 8 July 2026, the Cyprus Bar Association (CBA) published its first Guidelines on the Business-Wide Risk Assessment (BWRA), providing a practical framework for CBA supervised obliged entities to identify, assess and mitigate money laundering, terrorist financing and targeted financial sanctions risks.
BWRA is a core element of the risk-based approach under Article 10 of Regulation (EU) 2024/1624 (AMLR). It is a documented, entity-level assessment that should provide a holistic view of the risks arising from the business model, customers, services, transactions, delivery channels, geographical exposure and use of new technologies.
The CBA Guidelines provide practical direction ahead of the AMLR becoming applicable on 10 July 2027. CBA supervised obliged entities should use this period to develop and test a BWRA that is proportionate, well documented and aligned with the new regulatory framework.
The assessment should identify inherent risk, evaluate the design and effectiveness of controls and determine residual risk. Its methodology should reflect the entity's size, nature, complexity and risk profile, with clear criteria for likelihood, impact and risk scoring.
At a minimum, BWRA should address customer, geographic, service and transaction, delivery-channel and emerging risks. It should also consider new technologies, crypto-assets, staff competence, internal controls and exposure to sanctions evasion.
The results should determine the entity's risk appetite and inform its policies, customer due diligence, enhanced due diligence, monitoring, approval processes, staff training and remediation actions.
The Compliance Officer should lead the BWRA, with approval by the management body. The assessment must be tailored to the entity, kept available for supervisory review and fully understood by those responsible for its approval.
BWRA should be reviewed regularly and updated whenever material changes arise, including new services, customer types, jurisdictions, technologies, risk typologies or sanctions developments. The CBA recommends at least an annual review.
How Can Bybloserve Management Assist You?
Bybloserve Management closely monitors regulatory developments and provides informative updates on key AML/CFT and compliance matters affecting obliged entities. Our aim is to help clients stay informed of relevant guidance, upcoming requirements and practical compliance considerations.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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