On 6 September 2019, the Cyprus Securities and Exchange Commission issued a circular for regulated entities to consider the Office of Foreign Assets Control’s Specially Designated Nationals List when assessing the money laundering and terrorist financing risks associated with business relationships and occasional transactions with clients. 

This is a re-issuance of CySEC’s Circular 266 on which we published an extensive article on 3 August 2018.

CySEC’s decision to highlight US sanctions compliance should be considered as “atypical” for an EU member state not under US jurisdiction.

CySEC’s Circular can be found here.

Harneys’ article can be found here.