The CVRM Law constitutes the final product of Cyprus’ implementation of Directive (EU) 2024/1226 of 24 April 2024, which seeks to harmonise criminal enforcement of sanctions across the EU. Our prior blog on this Directive can be found here.

• Scope: The CVRM Law applies to violations committed within or outside Cyprus, including acts by citizens of Cyprus or entities registered in Cyprus, as well as offences benefiting businesses operating in Cyprus. It also extends to offences committed on ships or aircrafts which are registered in Cyprus or having the Cypriot flag.
  
  
• Offences: criminal offences include:
  • Providing funds or resources to sanctioned individuals or entities.
  • Failing to freeze funds or economic resources as mandated by EU measures.
  • Facilitation of the entry into, or transit through, the territory of a Member State by designated natural persons.
  • Providing misleading to conceal the fact that a designated person or entity is the ultimate owner of funds or economic resources that should be frozen.
  • Circumventing restrictive measures through fraudulent means.
  • Conducting prohibited transactions, such as trade or financial services, with sanctioned parties.
  • Noncompliance with conditions of licences granted by competent authorities for the conduct of activities which, in the absence of such a licence, would be prohibited.
    
    
• Penalties:
  • For individuals: Fines up to €100,000 and/or imprisonment up to 5 years, depending on the offence's severity and value.
  • For legal entities: Fines up to €40 million or 5% of global turnover, alongside potential revocation of licences, exclusion from public funding or bans on business activities.
  • Aggravating factors include offences committed within criminal organisations or by public officials.
    
    
• Exemptions: Humanitarian assistance and activities supporting basic human needs are explicitly excluded from criminalisation, ensuring that the law does not hinder essential aid efforts.
  
  
• Cooperation with relevant persons:
  • The CVRM Law mandates close cooperation of the Cyprus Police with the competent authorities of other member states, with EU bodies such as Eurojust, Europol and the European Public Prosecutor's Office to combat cross-border sanctions violations effectively.
    
    
• Repeal of previous Law: The prior Cypriot Sanctions Law of 2016 (Law 58 (I) of 2016) has been repealed, with its provisions incorporated into this updated framework. The CVRM Law is in force as of the date of gazetting, which is 25 July 2025.

The CVRM Law strengthens Cyprus' commitment to enforcing EU restrictive measures and ensuring humanitarian principles are upheld.

The CVRM Law, published in the official gazette, can be found here (only in Greek)