Public, fail-closed Cyprus AML/CFT research preview checked on 29 September 2026. The Law 25(I)/2026 Gazette copy, CBC R.A.D. 120/2025 Greek original and seven official HTML pages are retained as internal research evidence; a limited set of topic locators remains under review. Their current legal effect, the full Law 188(I)/2007 chain, activity-to-supervisor scope, reporting operations, sanctions routes and most control provisions remain unresolved. Retention does not imply public redistribution rights. This is not a legal opinion, completeness finding or compliance approval.
Preview of legislation and requirement mapping for Cyprus
Requirement
Source type
Authority
Supporting provision
Review pending
Determine the legal entity, regulated activity, authorisation and competent authority before assigning an AML control set.
legislation
Central Bank of Cyprus
CBC AML/CFT supervisory page, section 'Legal and regulatory framework', paragraph beginning 'According to section 59(1)(a)', and CBC Directive paragraph 4 (PDF p. 8; Gazette p. 799) as context for the Directive's CBC-supervised addressees. Neither resolves the current Greek law or an entity-level assignment.
Review pending
Verify the current governance, risk-assessment and control provisions for the entity's actual Cyprus supervisory route.
legislation
Central Bank of Cyprus
CBC Directive R.A.D. 120/2025 paragraphs 6, 10 and 14 (PDF pp. 8-11 and 15-16; Gazette pp. 799-802 and 806-807), concerning governance/control responsibility, internal audit, and Compliance Officer appointment/notification. These are limited candidate locators; the current Law 188 chain and entity-level application remain unresolved.
Review pending
Map the legal trigger, customer category and any permitted alternative before turning onboarding into a document checklist.
legislation
Central Bank of Cyprus
CBC Directive R.A.D. 120/2025 paragraph 12 (PDF p. 13; Gazette p. 804) addresses customer-acceptance policy; paragraphs 24 and 26 remain separate candidate locators. Paragraph 12 is not treated as the complete statutory CDD trigger. Law 188 currentness and exceptions remain unresolved.
Review pending
Confirm which person or entity must be identified, what must be verified, which evidence methods are permitted and what exceptions apply.
legislation
Central Bank of Cyprus
CBC Directive R.A.D. 120/2025, paragraph 26(1)-(4) (PDF pp. 36-37; Gazette pp. 827-828), on identification and verification. The current Law 188 interaction and complete permitted-method/exception analysis remain unresolved.
Review pending
Map who qualifies as a PEP, which family members or close associates are included, and how status affects the relationship.
legislation
Central Bank of Cyprus
CBC Directive R.A.D. 120/2025, paragraph 46(1)-(2) (PDF pp. 58-59; Gazette pp. 849-850), concerning PEP identification and related measures. The current Law 188 definition and full measure set remain unresolved.
legislation / Review pending
Confirm the Cyprus obliged-person and supervisory perimeter from the actual activity
Unverified research interpretation
Determine the legal entity, regulated activity, authorisation and competent authority before assigning an AML control set.
Research explanation under review
A retail bank, payment or e-money provider, investment firm and crypto-asset service provider may sit under different legal and supervisory provisions. The current statutory activity map has not been reconstructed here. Selecting one of the reader scenarios does not decide that the entity is obliged, licensed in Cyprus or supervised by CBC, CySEC or another body.
Applicability
Business lines
retail banking, payments emoney
Customer types
individual, company, trust
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
CBC AML/CFT supervisory page, section 'Legal and regulatory framework', paragraph beginning 'According to section 59(1)(a)', and CBC Directive paragraph 4 (PDF p. 8; Gazette p. 799) as context for the Directive's CBC-supervised addressees. Neither resolves the current Greek law or an entity-level assignment.
Source changed
Central Bank of Cyprus
Source diagnostics
Lifecycle
Source changed
Language
en
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
official authority scope page
Version
CBC page checked 28 September 2026; it states its Law 188 section 59(1)(a) remit for financial activities of CBC-supervised entities, including credit, payment, electronic-money, currency-exchange, leasing and credit-acquiring institutions.
This is a regulator-stated, page-level perimeter summary, not a substitute for the current Greek Law 188 text or an entity-specific authorisation analysis. It does not establish CySEC CASP scope.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 4457711a0404
: unchanged, document 4457711a0404
: unchanged, document 4457711a0404
: unchanged, document 4457711a0404
: unchanged, document 4457711a0404
Conditions
Treat business line, customer type and lifecycle stage as a research scenario only until the entity, location, licence and actual services are mapped to the current Greek primary text.
Exceptions
No institution or fintech is assigned to a supervisor by its product label.
Evidence diagnostics
Record ID
cy-supervisory-perimeter
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Map governance and business-wide AML/CFT risk controls to the responsible supervisor
Unverified research interpretation
Verify the current governance, risk-assessment and control provisions for the entity's actual Cyprus supervisory route.
Research explanation under review
The official CBC Directive is a primary source candidate for CBC-supervised firms; CySEC and other sectors may have distinct or additional instruments. Exact board, MLRO, approval, assessment and review duties have not been extracted from the original Greek text and must not be inferred from a generic AML checklist.
Applicability
Business lines
retail banking, payments emoney
Customer types
individual, company, trust
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
CBC Directive R.A.D. 120/2025 paragraphs 6, 10 and 14 (PDF pp. 8-11 and 15-16; Gazette pp. 799-802 and 806-807), concerning governance/control responsibility, internal audit, and Compliance Officer appointment/notification. These are limited candidate locators; the current Law 188 chain and entity-level application remain unresolved.
Source check failed
Central Bank of Cyprus
Source diagnostics
Lifecycle
Source check failed
Language
el
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
supervisory directive primary greek text
Version
Official Gazette Part III(I), R.A.D. 120/2025, No. 5943, 2 May 2025, as identified by CBC. Official Greek 94-page PDF retrieved 29 September 2026; SHA-256 verified. OCR is a research aid, not a verified legal transcription.
CBC's official notice confirms the Gazette identity and links the Greek original. The seven paragraph references are limited locators checked across complete page spans; they do not resolve currentness, commencement, legal interpretation or entity-level applicability.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
Conditions
The scenario applies only after the institution's legal category and competent authority are confirmed.
Exceptions
The 2018 national assessment is historical context, not a current firm or customer risk rating.
Evidence diagnostics
Record ID
cy-governance-risk-programme
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Establish the applicable CDD trigger and customer-identification rule
Unverified research interpretation
Map the legal trigger, customer category and any permitted alternative before turning onboarding into a document checklist.
Research explanation under review
The source inventory identifies the AML Law and CBC Directive as the primary review targets, but their current trigger points, occasional-transaction conditions, reliance rules and exceptions have not been reconciled. No threshold, universal identity-data set or document package is asserted for a Cyprus scenario.
Applicability
Business lines
retail banking, payments emoney
Customer types
individual, company, trust
Stages
onboarding, ongoing
Supporting provision
CBC Directive R.A.D. 120/2025 paragraph 12 (PDF p. 13; Gazette p. 804) addresses customer-acceptance policy; paragraphs 24 and 26 remain separate candidate locators. Paragraph 12 is not treated as the complete statutory CDD trigger. Law 188 currentness and exceptions remain unresolved.
Source check failed
Central Bank of Cyprus
Source diagnostics
Lifecycle
Source check failed
Language
el
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
supervisory directive primary greek text
Version
Official Gazette Part III(I), R.A.D. 120/2025, No. 5943, 2 May 2025, as identified by CBC. Official Greek 94-page PDF retrieved 29 September 2026; SHA-256 verified. OCR is a research aid, not a verified legal transcription.
CBC's official notice confirms the Gazette identity and links the Greek original. The seven paragraph references are limited locators checked across complete page spans; they do not resolve currentness, commencement, legal interpretation or entity-level applicability.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
Conditions
Treat the scenario as an analysis prompt only; verify the relationship/transaction trigger and statutory customer category in the current Greek text.
Exceptions
No cash, product, customer or transaction threshold is supplied by this draft.
Evidence diagnostics
Record ID
cy-cdd-identification
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
cdd
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Separate identity information from the method used to verify it
Unverified research interpretation
Confirm which person or entity must be identified, what must be verified, which evidence methods are permitted and what exceptions apply.
Research explanation under review
A source-backed verification rule must distinguish collecting identity data from independently establishing that it is reliable. The primary Cyprus directive is available as an image-based Greek scan, but no OCR or provision-level review is included here. This package therefore does not prescribe passports, utility bills, electronic identity or a fixed evidence combination.
Applicability
Business lines
retail banking, payments emoney
Customer types
individual, company, trust
Stages
onboarding, ongoing, investigation
Supporting provision
CBC Directive R.A.D. 120/2025, paragraph 26(1)-(4) (PDF pp. 36-37; Gazette pp. 827-828), on identification and verification. The current Law 188 interaction and complete permitted-method/exception analysis remain unresolved.
Source check failed
Central Bank of Cyprus
Source diagnostics
Lifecycle
Source check failed
Language
el
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
supervisory directive primary greek text
Version
Official Gazette Part III(I), R.A.D. 120/2025, No. 5943, 2 May 2025, as identified by CBC. Official Greek 94-page PDF retrieved 29 September 2026; SHA-256 verified. OCR is a research aid, not a verified legal transcription.
CBC's official notice confirms the Gazette identity and links the Greek original. The seven paragraph references are limited locators checked across complete page spans; they do not resolve currentness, commencement, legal interpretation or entity-level applicability.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
Conditions
The individual, representative, company or legal arrangement must be identified from the verified customer relationship and applicable law.
Exceptions
No prescribed document list or universal remote-onboarding method is asserted.
Evidence diagnostics
Record ID
cy-identity-verification
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
verification
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Verify the Cyprus PEP definition and connected-person scope before screening
Unverified research interpretation
Map who qualifies as a PEP, which family members or close associates are included, and how status affects the relationship.
Research explanation under review
The Law 188 amendment chain includes changes through 2026, but this package has not reconciled current PEP definitions, foreign/domestic treatment, family-member scope, former office-holder treatment or supervisor-specific guidance. A screening result is not itself the legal classification or risk decision.
Applicability
Business lines
retail banking, payments emoney
Customer types
individual, company, trust
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
CBC Directive R.A.D. 120/2025, paragraph 46(1)-(2) (PDF pp. 58-59; Gazette pp. 849-850), concerning PEP identification and related measures. The current Law 188 definition and full measure set remain unresolved.
Source check failed
Central Bank of Cyprus
Source diagnostics
Lifecycle
Source check failed
Language
el
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
supervisory directive primary greek text
Version
Official Gazette Part III(I), R.A.D. 120/2025, No. 5943, 2 May 2025, as identified by CBC. Official Greek 94-page PDF retrieved 29 September 2026; SHA-256 verified. OCR is a research aid, not a verified legal transcription.
CBC's official notice confirms the Gazette identity and links the Greek original. The seven paragraph references are limited locators checked across complete page spans; they do not resolve currentness, commencement, legal interpretation or entity-level applicability.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
Conditions
Establish the relevant individual, role, time period, connected person and in-scope institution before assigning legal PEP status.
Exceptions
No PEP database match, title or score is treated as a legal decision by itself.
Evidence diagnostics
Record ID
cy-pep-identification
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Map the actual enhanced due-diligence triggers and measures
Unverified research interpretation
Identify which risk conditions require enhanced measures, approvals or additional evidence under the relevant current Cyprus rule.
Research explanation under review
This package does not state a universal risk score, high-risk-country trigger, source-of-wealth package, approval level or review interval. Those details must be reconciled against current Greek legislation, the relevant supervisor's binding direction and applicable EU instruments.
Applicability
Business lines
retail banking, payments emoney
Customer types
individual, company, trust
Stages
onboarding, ongoing, investigation
Supporting provision
CBC Directive R.A.D. 120/2025, paragraph 42 (PDF pp. 51-54; Gazette pp. 842-845), addressing enhanced due diligence. The complete current triggers, measures and approval requirements under Law 188 and other sector rules remain unresolved.
Source check failed
Central Bank of Cyprus
Source diagnostics
Lifecycle
Source check failed
Language
el
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
supervisory directive primary greek text
Version
Official Gazette Part III(I), R.A.D. 120/2025, No. 5943, 2 May 2025, as identified by CBC. Official Greek 94-page PDF retrieved 29 September 2026; SHA-256 verified. OCR is a research aid, not a verified legal transcription.
CBC's official notice confirms the Gazette identity and links the Greek original. The seven paragraph references are limited locators checked across complete page spans; they do not resolve currentness, commencement, legal interpretation or entity-level applicability.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
: unchanged, document 65c3e6227ccd
Conditions
Treat each risk factor as a prompt for legal and factual assessment, not an automatic high-risk classification or prescribed control.
Exceptions
No national-risk rating or historic NRA finding is converted into a customer outcome.
Evidence diagnostics
Record ID
cy-enhanced-due-diligence
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Identify the measure-specific sanctions rules and responsible authority
Unverified research interpretation
Keep sanctions-law research separate from AML, PEP and MOKAS suspicious-reporting analysis; no screening action is prescribed by this package.
Research explanation under review
Official Cyprus authority pages identify Laws 149(I)/2025 and 150(I)/2025 and describe sanctions institutions, but the Greek Gazette texts and live measure-specific instruments are not in this package. No firm screening duty, match standard, freeze/reject action, reporting recipient or licence route is concluded here.
Applicability
Business lines
retail banking, payments emoney, crypto
Customer types
individual, company, trust
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
The NSIU English national legal-framework page and CySEC sanctions documentation page identify Laws 149(I)/2025 and 150(I)/2025. These authority summaries are discovery evidence, not the Greek Gazette texts or mapped firm-level obligations.
Source check failed
National Sanctions Implementation Unit / Ministry of Finance
Source diagnostics
Lifecycle
Source check failed
Language
en; Greek statutes control
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
official authority summary
Version
Official Gov.cy page is browser-readable and identifies Greek-language Laws 149(I)/2025 and 150(I)/2025; a linked Greek NSIU framework page states the framework took effect on 25 July 2025. Gazette originals, amendments/corrigenda and article-level effect were not retained or analysed in this package.
SHA-256
Not recorded
Source notes
This English page and its public Greek counterpart are discovery/scope evidence only. They do not establish a firm's screening, freeze, rejection, reporting or licensing duty and are not substitutes for the Greek Gazette originals, amendment chain or provision-level review. No page copy is retained because reuse permission was not established.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Conditions
Identify the measure, territory, person/entity, direct and indirect ownership/control facts and the institution's actual role before deciding what action is legally required.
Exceptions
No automatic freeze, rejection, account closure, disclosure or licence outcome is generated by this package.
Evidence diagnostics
Record ID
cy-sanctions-screening
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Verify record categories, retention triggers and permitted deletion
Unverified research interpretation
Map each AML record type to its legal retention period, start event, access controls and deletion or hold rule.
Research explanation under review
This package does not assert a universal retention period. CDD evidence, transaction records, internal analysis, FIU submissions, company register data and trust register data may have distinct legal bases and triggers. Verify the applicable primary law, privacy rules and sector instruments before setting a deletion clock.
Applicability
Business lines
retail banking, payments emoney
Customer types
individual, company, trust
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
Law 188(I)/2007 recordkeeping provisions and applicable CBC/CySEC instruments are review targets; exact categories, duration and commencement event are not verified.
Source changed
Cyprus Securities and Exchange Commission
Source diagnostics
Lifecycle
Source changed
Language
en; linked national instruments are generally Greek
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
changed
Evidence review
requires-revalidation
Type
official legislation index
Version
Live index directly retrieved by HTTPS on 2026-09-29T22:33:40Z; index only, not a current consolidated operative text.
The live index is evidence that CySEC lists Law 25(I)/2026 as the newest visible AML amendment. It does not establish that every prior amendment, corrigendum, commencement provision or cross-reference has been reconciled.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: changed, document 785a5cc517bb
: changed, document 93edc2bd96e2
: changed, document 10438cd6ff96
: changed, document 900e93618ccc
: changed, document 2389b5bbc415
Conditions
The record type, legal entity, regulator, purpose and start event must be mapped before applying a retention period.
Exceptions
No personal beneficial-owner extract, sanctions list or customer data is retained in this package.
Evidence diagnostics
Record ID
cy-recordkeeping
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Resolve failed CDD, restricted activity and exit as separate decisions
Unverified research interpretation
Verify when a relationship cannot start or continue, what activity may be restricted, and how that interacts with suspicious reporting and customer communications.
Research explanation under review
The package does not assert that incomplete CDD always requires immediate account closure or that a suspicious-report decision automatically closes an account. Current Law 188 provisions, any FIU direction or consent, payment/customer rights and sector rules must be reviewed before configuring a refusal or exit path.
Applicability
Business lines
retail banking, payments emoney
Customer types
individual, company, trust
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
Current Law 188(I)/2007 CDD failure, transaction restriction, FIU instruction and confidentiality provisions; exact subsections and sector/customer-law overlays are unresolved.
Source changed
Cyprus Securities and Exchange Commission
Source diagnostics
Lifecycle
Source changed
Language
en; linked national instruments are generally Greek
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
changed
Evidence review
requires-revalidation
Type
official legislation index
Version
Live index directly retrieved by HTTPS on 2026-09-29T22:33:40Z; index only, not a current consolidated operative text.
The live index is evidence that CySEC lists Law 25(I)/2026 as the newest visible AML amendment. It does not establish that every prior amendment, corrigendum, commencement provision or cross-reference has been reconciled.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: changed, document 785a5cc517bb
: changed, document 93edc2bd96e2
: changed, document 10438cd6ff96
: changed, document 900e93618ccc
: changed, document 2389b5bbc415
Conditions
Separate the inability to complete CDD, suspected activity, legal restriction/direction and ordinary commercial exit; confirm the rule for each before action.
Exceptions
No blanket automatic account closure, customer notice, freeze or report is prescribed by this draft.
Evidence diagnostics
Record ID
cy-failed-cdd-offboarding
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Apply funds-transfer information duties only to an in-scope PSP role
Unverified research interpretation
Classify the payment provider and its payer, payee or intermediary role before applying the funds-transfer provisions.
Research explanation under review
The retained Regulation (EU) 2023/1113 text distinguishes payer PSP, payee PSP and intermediary PSP duties. This requirement is limited to defined money transfers within Article 2 and the provider categories in Article 3; it is not a general CDD checklist for every bank, payment or e-money product. Cyprus-specific competent-authority routing remains under review.
Applicability
Business lines
retail banking, payments emoney
Customer types
individual, company, trust
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
Regulation (EU) 2023/1113, Articles 2(1)-(5), 3(5)-(6) and 3(9); payer PSP duties in Articles 4-6; payee PSP duties in Articles 7-9; intermediary PSP duties in Articles 10-13; common provisions in Articles 23-26; application date in Article 40.
Apply only if the entity acts in a relevant payer PSP, payee PSP or intermediary PSP role, the transaction is a money transfer within Articles 2 and 3, and the specific role's article group applies.
Exceptions
Check the exclusions, special cases and Member State options in Article 2(2)-(5) for the actual transaction. Do not infer that every bank, payment institution or e-money transfer is covered or that the Cyprus entity's supervisory route is established.
Evidence diagnostics
Record ID
cy-funds-transfer-information
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
CySEC AML/CFT main legislation index
Source changed
Cyprus Securities and Exchange Commission
Source diagnostics
Lifecycle
Source changed
Language
en; linked national instruments are generally Greek
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
changed
Evidence review
requires-revalidation
Type
official legislation index
Version
Live index directly retrieved by HTTPS on 2026-09-29T22:33:40Z; index only, not a current consolidated operative text.
The live index is evidence that CySEC lists Law 25(I)/2026 as the newest visible AML amendment. It does not establish that every prior amendment, corrigendum, commencement provision or cross-reference has been reconciled.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: changed, document 785a5cc517bb
: changed, document 93edc2bd96e2
: changed, document 10438cd6ff96
: changed, document 900e93618ccc
: changed, document 2389b5bbc415
Mapped requirements
Amending Law 25(I)/2026, Official Gazette No. 5079, 20 March 2026
Source check failed
Republic of Cyprus Official Gazette, copy hosted by CySEC
Source diagnostics
Lifecycle
Source check failed
Language
el
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
primary legislation official gazette copy
Version
Two-page Greek Gazette instrument. The face identifies Law 25(I)/2026 and Gazette No. 5079 dated 20 March 2026. Direct HTTPS bytes were streamed and SHA-256 checked on 28 September 2026; a local copy is retained for internal research.
The text says it is read with the 2007 to (No. 2) 2025 law series. Sections 2-4 amend AML Law sections 61A, 61B and 61C. The amendment text was read directly; commencement, the full underlying register rules, residual exceptions and later application are not independently reconciled.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document f0e882ca4fed
: unchanged, document f0e882ca4fed
: unchanged, document f0e882ca4fed
: unchanged, document f0e882ca4fed
: unchanged, document f0e882ca4fed
Mapped requirements
No mapped requirement is available in this selected reading view.
CBC Prevention of Money Laundering and Terrorist Financing Directive of 2025, R.A.D. 120/2025
Source check failed
Central Bank of Cyprus
Source diagnostics
Lifecycle
Source check failed
Language
el
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
supervisory directive primary greek text
Version
Official Gazette Part III(I), R.A.D. 120/2025, No. 5943, 2 May 2025, as identified by CBC. Official Greek 94-page PDF retrieved 29 September 2026; SHA-256 verified. OCR is a research aid, not a verified legal transcription.
CBC's official notice confirms the Gazette identity and links the Greek original. The seven paragraph references are limited locators checked across complete page spans; they do not resolve currentness, commencement, legal interpretation or entity-level applicability.
Circular dated 21 May 2026; confirmed in the public CySEC circular index and official PDF endpoint on 29 September 2026. It lists CySEC-supervised sectors, including CASPs, and says revised STR, SAR and AIF-A/AIF-T guidance is in authenticated goAML Help.
C781's public PDF and index confirm publication and identify CASPs among its addressees, but the PDF is not retained because CySEC states all rights reserved. A generic public goAML user guide is not a substitute for the revised sector-specific materials in authenticated Help. Current guide contents, schemas, acknowledgement/rejection handling and actual MOKAS receipt remain unverified. No real filing was attempted.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 5ed53fba491e
: unchanged, document 5ed53fba491e
: unchanged, document 5ed53fba491e
: unchanged, document 5ed53fba491e
: unchanged, document 5ed53fba491e
Mapped requirements
No mapped requirement is available in this selected reading view.
CySEC AML/CFT circular index
Source changed
Cyprus Securities and Exchange Commission
Source diagnostics
Lifecycle
Source changed
Language
en
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
changed
Evidence review
requires-revalidation
Type
official supervisory index
Version
Live index checked 28 September 2026; it lists C781 dated 21 May 2026 and later AMLA-related circulars through C800 dated 8 September 2026.
Index evidence does not replace the original circulars or the current sector-specific MOKAS guides.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: changed, document 3e821e5a7df8
: changed, document 17a5eeb471b2
: changed, document 2c48c5ce3c7e
: changed, document 7ebfef824565
: changed, document 5014ebde5715
Mapped requirements
No mapped requirement is available in this selected reading view.
MOKAS goAML public portal
Source check failed
Money Laundering Combating Unit (MOKAS)
Source diagnostics
Lifecycle
Source check failed
Language
en
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
official reporting portal
Version
Official portal landing page and a generic public goAML Web User Guide – Reporting Instructions are browser-readable as of 29 September 2026. C781's revised sector-specific guides remain identified as authenticated Help materials; that Help area and operational responses were not accessed.
SHA-256
Not recorded
Source notes
The landing page says portal access requires registration as a Reporting Entity. The browser-readable generic guide does not establish that it is current or sector-specific and is not treated as C781's revised guidance. Registration, authenticated Help, current sector forms, report acceptance, acknowledgement, correction, urgent escalation and outage routes remain untested. No portal or guide copy is retained because reuse permission was not established.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
NSIU legislative framework page
Source check failed
National Sanctions Implementation Unit / Ministry of Finance
Source diagnostics
Lifecycle
Source check failed
Language
en; Greek statutes control
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
official authority summary
Version
Official Gov.cy page is browser-readable and identifies Greek-language Laws 149(I)/2025 and 150(I)/2025; a linked Greek NSIU framework page states the framework took effect on 25 July 2025. Gazette originals, amendments/corrigenda and article-level effect were not retained or analysed in this package.
SHA-256
Not recorded
Source notes
This English page and its public Greek counterpart are discovery/scope evidence only. They do not establish a firm's screening, freeze, rejection, reporting or licensing duty and are not substitutes for the Greek Gazette originals, amendment chain or provision-level review. No page copy is retained because reuse permission was not established.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
CySEC sanctions and restrictive-measures documentation page
Source changed
Cyprus Securities and Exchange Commission
Source diagnostics
Lifecycle
Source changed
Language
en; referenced national statutes are Greek
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
changed
Evidence review
requires-revalidation
Type
official authority summary
Version
Official CySEC page surfaced in the live index/search on 28 September 2026; underlying Law 149(I)/2025 and Law 150(I)/2025 were not re-opened as Gazette originals.
Use only as a route to primary sanctions legislation. No current list, ownership/control test, freeze/reject decision, report recipient, licence or derogation route is mapped from this page.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: changed, document 20e6ed51808a
: changed, document 0de5ea04c278
: changed, document 81ea1f3c9581
: changed, document 4dff9bdf15b9
: changed, document e2171772c4a5
Mapped requirements
No mapped requirement is available in this selected reading view.
CyTBOR directive index
Source changed
Cyprus Securities and Exchange Commission
Source diagnostics
Lifecycle
Source changed
Language
en; underlying directives are Greek
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
changed
Evidence review
requires-revalidation
Type
official register legislation index
Version
Official index identified in the source inventory checked 28 September 2026; it lists a 2026 amending directive and an unofficial consolidation through R.A.D. 243/2026.
The consolidation is not treated as an authentic original. The 2026 amending Gazette text, commencement, registration/update requirements, access rules and exceptions remain unmapped.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: changed, document 5bdfcd24e562
: changed, document 8e6aa4965442
: changed, document 92dd8b94ede7
: changed, document d907d982718f
: changed, document c8760f12cfbc
Mapped requirements
No mapped requirement is available in this selected reading view.
Department of Registrar of Companies and Intellectual Property
Source diagnostics
Lifecycle
Source changed
Language
en
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
official register operational notice
Version
Public browser-readable official notice dated 16 September 2026: annual confirmation window is 1 October through 31 December 2026. It covers companies, European public limited companies and partnerships; the window had not begun on 29 September 2026.
SHA-256
Not recorded
Source notes
Operational notice only. It is not substituted for the current Greek company-register law/directive chain and does not establish the trust-register process.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 1048eb0b77e2
: unchanged, document 1048eb0b77e2
: unchanged, document 1048eb0b77e2
: unchanged, document 1048eb0b77e2
: unchanged, document 1048eb0b77e2
Mapped requirements
No mapped requirement is available in this selected reading view.
Ministry of Finance national AML/CFT risk assessment page
Source check failed
Ministry of Finance / AML/CFT Advisory Authority
Source diagnostics
Lifecycle
Source check failed
Language
en; report language and current edition require confirmation
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
official risk assessment index
Version
Public browser-compatible Gov.cy page confirms the first whole-country assessment covered work conducted in 2015-2017 and that a concise report was published in 2018. No later whole-country NRA was identified through the official English and Greek risk-assessment indexes checked on 29 September 2026; this search is not proof none exists.
SHA-256
Not recorded
Source notes
The official index exposes the 2018 concise whole-country assessment; the separate official Greek index lists the 2021 virtual-assets assessment. Historical material is not a current customer risk rating or substitute for the institution's own risk assessment. No page or report copy is retained because reuse terms were not established. The absence of a later report in this bounded search is not evidence that none exists.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
CBC AML/CFT supervisory perimeter page
Source changed
Central Bank of Cyprus
Source diagnostics
Lifecycle
Source changed
Language
en
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
official authority scope page
Version
CBC page checked 28 September 2026; it states its Law 188 section 59(1)(a) remit for financial activities of CBC-supervised entities, including credit, payment, electronic-money, currency-exchange, leasing and credit-acquiring institutions.
This is a regulator-stated, page-level perimeter summary, not a substitute for the current Greek Law 188 text or an entity-specific authorisation analysis. It does not establish CySEC CASP scope.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 4457711a0404
: unchanged, document 4457711a0404
: unchanged, document 4457711a0404
: unchanged, document 4457711a0404
: unchanged, document 4457711a0404
Mapped requirements
MOKAS publications, guidelines and e-reporting index
Source changed
Money Laundering Combating Unit (MOKAS)
Source diagnostics
Lifecycle
Source changed
Language
en and el
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
official fiu index
Version
Index observed in the 28 September 2026 research inventory; individual current instructions were not all retrieved or reconciled.
Discovery route only. It does not establish current sector-specific report forms, goAML receipts, correction or outage procedures.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 2b8ce76acc15
: unchanged, document 2b8ce76acc15
: unchanged, document 2b8ce76acc15
: unchanged, document 2b8ce76acc15
: unchanged, document 2b8ce76acc15
Mapped requirements
No mapped requirement is available in this selected reading view.
NSIU reporting and disclosure obligations information page
Source check failed
National Sanctions Implementation Unit / Ministry of Finance
Source diagnostics
Lifecycle
Source check failed
Language
en; controlling legal instruments include Greek national texts and measure-specific EU/UN instruments
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
official sanctions reporting guidance
Version
Public browser-readable NSIU page dated 24 April 2026. It describes reporting/disclosure for specified articles of Regulations (EU) 269/2014 and 833/2014, names an email route and attached templates, and says templates are due to be revised; current templates and route operation are not independently validated.
SHA-256
Not recorded
Source notes
This page is expressly tied to specified Russia-regulation articles, including reporting templates and an email submission route; its notice that templates are due for revision prevents treating them as confirmed current operational forms. It does not establish a universal sanctions report, deadline, freeze, rejection or licensing outcome. Exact measure scope, current legal text, template version and route operation remain open. No page or attachment copy is retained because reuse permission was not established.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
Company beneficial-owner register directive index
Source changed
Department of Registrar of Companies and Intellectual Property
Source diagnostics
Lifecycle
Source changed
Language
en; underlying instruments are Greek
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
official register legislation index
Version
Public browser-readable DRCIP index confirmed on 29 September 2026. It lists the 2021 corporate BOR directive and multiple amending-directive entries, including 2024 entries, while displaying a conflicting latest-amendment date; the linked current Greek originals were not retained.
SHA-256
Not recorded
Source notes
The index is a retrieval lead only; its displayed amendment metadata is internally inconsistent. DRCIP terms require prior express written consent to copy or republish, which is not recorded, so no index or linked-document bytes are retained. The Greek base directive, complete amendment chain, Law 25 interaction and filing/access rules remain unresolved. This index alone does not block CDD performed without register reliance; a register-access journey remains open.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 933cb71a83a7
: unchanged, document 933cb71a83a7
: unchanged, document 933cb71a83a7
: unchanged, document 933cb71a83a7
: unchanged, document 933cb71a83a7
Mapped requirements
No mapped requirement is available in this selected reading view.
CySEC Policy Statement PS-02-2026 on the Cyprus Trusts Beneficial Owners Registry
Source changed
Cyprus Securities and Exchange Commission
Source diagnostics
Lifecycle
Source changed
Language
en; related register instruments are Greek
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
changed
Evidence review
requires-revalidation
Type
supervisory policy statement index
Version
Policy Statement PS-02-2026 was listed for 4 June 2026; the full text and its legal effect against Law 25(I)/2026 and the current CyTBOR directive were not analysed.
Policy and consultation material is not treated as a substitute for the operative Greek statute or directive.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: changed, document 4e991b1a464f
: changed, document 69be939a76c1
: changed, document b656cd3850b5
: changed, document 6114b19eead6
: changed, document f0f0c0c62dfd
Mapped requirements
No mapped requirement is available in this selected reading view.
Cyprus virtual-assets and VASP national risk-assessment announcement
Source check failed
Ministry of Finance / AML/CFT Advisory Authority
Source diagnostics
Lifecycle
Source check failed
Language
en; report language and current edition require confirmation
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
sector risk assessment announcement
Version
Public browser-readable Ministry announcement and linked official PDF confirm a virtual-assets/VASP assessment finalised in November 2021. Its stated assessment scope and assumptions are historical; subsequent update and post-MiCA applicability were not established.
SHA-256
Not recorded
Source notes
The report is public and expressly scoped to virtual-asset activities/products/services and VASPs, but is based on earlier assessment work and assumptions. Historical sector-risk context only; it is not a current risk rating, post-MiCA CASP perimeter determination or customer-level risk decision. No report copy is retained because reuse terms were not established.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets
No mapped requirement is available in this selected reading view.
Country authority or guidance body
House of Representatives and Government Printing Office
Cyprus
Role and responsibilities
The Official Gazette is the controlling publication route for Cyprus legislation and regulatory administrative acts. The complete current AML amendment and corrigendum chain is not captured in this package.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Central Bank of Cyprus
Cyprus
Role and responsibilities
CBC publishes an AML/CFT Directive for entities within its supervisory perimeter. The current activity-by-activity perimeter and full legal effect of the directive require reconciliation against Greek primary legislation.
Related sources in this handbook
Country authority or guidance body
Cyprus Securities and Exchange Commission
Cyprus
Role and responsibilities
CySEC publishes AML/CFT legislation, secondary instruments and circulars for its supervised sectors. This package does not assign an entity to CySEC or determine the complete boundary with other supervisors.
Related sources in this handbook
Country authority or guidance body
Money Laundering Combating Unit (MOKAS)
Cyprus
Role and responsibilities
CySEC identifies MOKAS as the Cyprus Financial Intelligence Unit. Current sector reporting instructions are referenced by C781 as available through authenticated goAML Help; their contents and receipt/error routes were not verified here.
Related sources in this handbook
Country authority or guidance body
National Sanctions Implementation Unit
Cyprus
Role and responsibilities
An official government source identifies the NSIU as a sanctions implementation and coordination body. The underlying Greek laws and division of duties by measure and sector remain to be independently reconciled.
Related sources in this handbook
Country authority or guidance body
Department of Registrar of Companies and Intellectual Property
Cyprus
Role and responsibilities
Publishes company beneficial-owner register notices and service information. Register procedures and the underlying current Greek legal instruments are not fully mapped here.
Related sources in this handbook
Country authority or guidance body
CySEC and the Cyprus Trusts Beneficial Owners Registry
Cyprus
Role and responsibilities
CySEC publishes the CyTBOR register and directive index for express trusts and similar legal arrangements. The current directive chain, access conditions and operational procedures require review.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Ministry of Finance and AML/CFT Advisory Authority
Cyprus
Role and responsibilities
Official Ministry material identifies a historical national AML/CFT risk assessment. A later comprehensive assessment and its present status were not verified in this bounded review.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
