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Cyprus establishes the National Sanctions Implementation Unit to ensure sanctions enforcement

16 Sep 2025
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The National Sanctions Implementation Unit (NSIU, known locally as EMEK) is now established under the Ministry of Finance in Cyprus (MoF), and has been set up on 25 July 2025 following the passing of the Establishment of the National Sanctions Implementation Unit and the Implementation of Restrictive Measures and National Sanctions in the Republic Law of 2025 (the NSIU Law).

The establishment of the NSIU is part of a broader package of amendments within the Cypriot sanctions framework which also includes the introduction of the Criminalisation of Violation and Restrictive Measures Law of 2025 (the Sanctions Enforcement Law) and the amendments to the Protection of Persons Reporting Violations of EU and National Law of 2022 (the Whistleblowing Law).

This NSIU Law consolidates and enhances the regulatory framework for sanctions enforcement, ensuring compliance with international and European Union obligations.

Key responsibilities of the NSIU

The NSIU assumes the roles previously held by the Advisory Committee on Economic Sanctions (SEOK) and the Unit for the Implementation of Sanctions in the Financial Sector (MEK).

Key features of the NSIU include:

  • Sanctions enforcement: Overseeing the application of EU sanctions and restrictive measures as well as UN Security Council sanctions.
  • Coordination: Collaborating with national and international authorities to ensure effective sanctions implementation.
  • Licensing and exemptions: Reviewing and approving requests for licenses or exemptions related to sanctions. Applicants who are not satisfied with the decision of their request may contest via a written objection.
  • Information exchange: Facilitating the exchange of information with domestic and international entities.
  • Monitoring and reporting: Evaluation and reporting of cases for potential sanctions violations as well as the preparation of reports related to its work, statistical reports, and reference reports.
  • Guidance: issuance of directives, circulars, guidelines, clarifications, and guidance on matters related to the implementation of sanctions in Cyprus.
Transitional provisions

The NSIU Law provides that:

  • existing licences and exemptions issued by SEOK or MEK are deemed to have been granted by the NSIU;
  • pending applications and ongoing investigations will be processed by the NSIU under the new legal framework; and
  • existing regulatory administrative acts, directives issued under the previous legal framework remain in force until amended or replaced.

The MoF will follow a further announcement with respect to new forms and submission guidelines for requests.

Compliance and penalties

The NSIU Law imposes strict obligations on individuals and entities to report and comply with sanctions and restrictive measures. Non-compliance may result in administrative fines, criminal penalties, or both, depending on the severity of the violation.

For further details, refer to the full text of the NSIU Law (available in Greek) here and the MoF’s press release here

Our previous blogpost on the overhaul of Cyprus sanctions enforcement apparatus can be found here