An Overview of AML Legislation and Recent Developments in Cyprus
By Sude Dogan, Lawitt Buro Intern
Cyprus continues to strengthen its position as a reputable financial and business hub in the Eastern Mediterranean. With global transparency and compliance standards becoming increasingly stringent, Cyprus has actively aligned its framework with the evolving EU Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) directives.
For clients operating in or through Cyprus, understanding these developments is vital. The AML landscape is not only expanding but also becoming more technology-driven, risk-sensitive, and enforcement-focused. Below, we outline what has changed, what it means for businesses, and how Lawitt Buro helps clients stay ahead of the curve.
1. The Current AML Landscape in Cyprus
Cyprus’s AML regime is primarily governed by the Prevention and Suppression of Money Laundering Activities Law of 2007 (as amended). The law applies to all “Obliged Entities,” including banks, investment firms, accountants, auditors, lawyers, real estate agents, Trust and Company Service Providers (TCSPs), and, more recently, Crypto-Asset Service Providers (CASPs).
The system is built on three pillars:
1) Risk-Based Approach (RBA): Businesses must assess their own exposure to money laundering risks and allocate compliance resources accordingly.
2) Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD): Know Your Customer (KYC) obligations remain the cornerstone of compliance, especially for high-risk clients or jurisdictions.
3) Suspicious Transaction Reporting (STR): Obliged entities must report suspicious activity promptly to MOKAS, Cyprus’s Financial Intelligence Unit.
While these principles are familiar, recent reforms significantly reshape how they must be implemented in practice.
2. Key Recent Developments and What They Mean for Clients
A. AML Law for Crypto-Assets – Law 96(I)/2025
The new law, enacted in June 2025, incorporates the EU’s Markets in Crypto-Assets (MiCA) framework into Cypriot law, extending AML obligations to digital transactions.
What this means for clients:
How Lawitt Buro helps:
We assist clients in the crypto and fintech sectors to design AML policies tailored to their operations, ensure licensing compliance with CySEC, and implement robust internal risk assessments aligned with MiCA standards.
B. UBO Confirmation Campaign (2025)
From October to December 2025, all Cyprus-registered companies must confirm or update their beneficial ownership details with the Registrar of Companies.
Client impact:
Our role:
Lawitt Buro provides hands-on support for clients in reviewing, verifying, and submitting their UBO data to ensure uninterrupted compliance and business continuity.
C. Criminalisation of Sanctions Violations
The Criminalisation of Violation of Restrictive Measures Law 2025 brings sanctions breaches under the scope of criminal law.
Client impact:
How we assist:
Our team offers sanctions screening, policy drafting, and due diligence advisory to help clients avoid inadvertent breaches and mitigate reputational and criminal risks.
D. Central Bank AML Directive (2025)
The Central Bank of Cyprus (CBC) introduced a new AML Directive effective June 2025, focusing on governance, technology, and proportionality.
What’s new:
Client impact:
Our role:
We assist clients in revising internal AML manuals, training senior management, and conducting compliance audits to meet the CBC’s expectations.
E. Restriction on Large Cash Transactions
A December 2024 law caps cash payments above €10,000 for goods, services, and real estate transactions.
Client impact:
How we help:
Lawitt Buro advises clients on transaction structuring and compliance procedures to ensure smooth and lawful operations in light of this restriction.
3. The Road Ahead – The EU AML/CTF Single Rulebook
Looking forward, the EU’s Single AML Rulebook, expected by 2027, will unify AML standards across all Member States. A new EU Anti-Money Laundering Authority (AMLA) will directly supervise high-risk cross-border entities.
What clients should prepare for:
Lawitt Buro’s approach:
We are already working with clients to align their policies with future EU AMLA expectations. Our team conducts readiness assessments and regulatory strategy sessions to help clients transition smoothly under the upcoming regime.
4. Conclusion
Cyprus’s AML framework continues to evolve rapidly, reflecting its commitment to transparency and compliance excellence. For clients, these changes bring both new responsibilities and opportunities—from strengthening governance to enhancing trust in international transactions.
At Lawitt Buro, we combine our deep understanding of the regulatory environment with practical legal and compliance support. Whether through policy design, due diligence, or regulatory representation, we help businesses not only meet their AML obligations but also turn compliance into a strategic advantage.
By Sude Dogan, Lawitt Buro Intern
Cyprus continues to strengthen its position as a reputable financial and business hub in the Eastern Mediterranean. With global transparency and compliance standards becoming increasingly stringent, Cyprus has actively aligned its framework with the evolving EU Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) directives.
For clients operating in or through Cyprus, understanding these developments is vital. The AML landscape is not only expanding but also becoming more technology-driven, risk-sensitive, and enforcement-focused. Below, we outline what has changed, what it means for businesses, and how Lawitt Buro helps clients stay ahead of the curve.
1. The Current AML Landscape in Cyprus
Cyprus’s AML regime is primarily governed by the Prevention and Suppression of Money Laundering Activities Law of 2007 (as amended). The law applies to all “Obliged Entities,” including banks, investment firms, accountants, auditors, lawyers, real estate agents, Trust and Company Service Providers (TCSPs), and, more recently, Crypto-Asset Service Providers (CASPs).
The system is built on three pillars:
1) Risk-Based Approach (RBA): Businesses must assess their own exposure to money laundering risks and allocate compliance resources accordingly.
2) Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD): Know Your Customer (KYC) obligations remain the cornerstone of compliance, especially for high-risk clients or jurisdictions.
3) Suspicious Transaction Reporting (STR): Obliged entities must report suspicious activity promptly to MOKAS, Cyprus’s Financial Intelligence Unit.
While these principles are familiar, recent reforms significantly reshape how they must be implemented in practice.
2. Key Recent Developments and What They Mean for Clients
A. AML Law for Crypto-Assets – Law 96(I)/2025
The new law, enacted in June 2025, incorporates the EU’s Markets in Crypto-Assets (MiCA) framework into Cypriot law, extending AML obligations to digital transactions.
What this means for clients:
- CASPs, EMIs, and PSPs must now meet stricter onboarding and transaction monitoring standards.
- The “Travel Rule” applies to crypto transfers above €1,000, requiring sender and recipient details—similar to traditional bank transfers.
- CySEC now has expanded supervisory powers.
How Lawitt Buro helps:
We assist clients in the crypto and fintech sectors to design AML policies tailored to their operations, ensure licensing compliance with CySEC, and implement robust internal risk assessments aligned with MiCA standards.
B. UBO Confirmation Campaign (2025)
From October to December 2025, all Cyprus-registered companies must confirm or update their beneficial ownership details with the Registrar of Companies.
Client impact:
- Non-compliance may result in administrative penalties or even strike-off from the register.
Our role:
Lawitt Buro provides hands-on support for clients in reviewing, verifying, and submitting their UBO data to ensure uninterrupted compliance and business continuity.
C. Criminalisation of Sanctions Violations
The Criminalisation of Violation of Restrictive Measures Law 2025 brings sanctions breaches under the scope of criminal law.
Client impact:
- This law increases exposure for companies dealing with high-risk jurisdictions or international transactions. Directors and compliance officers may face personal liability for violations.
How we assist:
Our team offers sanctions screening, policy drafting, and due diligence advisory to help clients avoid inadvertent breaches and mitigate reputational and criminal risks.
D. Central Bank AML Directive (2025)
The Central Bank of Cyprus (CBC) introduced a new AML Directive effective June 2025, focusing on governance, technology, and proportionality.
What’s new:
- Longer review intervals for low-risk clients.
- Acceptance of digital verification and alternative documentation.
- Stronger accountability for Boards and AML Compliance Officers.
Client impact:
- Financial institutions and payment providers must update their compliance frameworks to reflect these governance and verification changes.
Our role:
We assist clients in revising internal AML manuals, training senior management, and conducting compliance audits to meet the CBC’s expectations.
E. Restriction on Large Cash Transactions
A December 2024 law caps cash payments above €10,000 for goods, services, and real estate transactions.
Client impact:
- Real estate developers, agents, and high-value traders must ensure payments above this limit are processed through financial institutions.
How we help:
Lawitt Buro advises clients on transaction structuring and compliance procedures to ensure smooth and lawful operations in light of this restriction.
3. The Road Ahead – The EU AML/CTF Single Rulebook
Looking forward, the EU’s Single AML Rulebook, expected by 2027, will unify AML standards across all Member States. A new EU Anti-Money Laundering Authority (AMLA) will directly supervise high-risk cross-border entities.
What clients should prepare for:
- A shift from national-level discretion to uniform EU supervision.
- Increased focus on technology-driven compliance and cross-border cooperation.
- More stringent requirements for staff training, governance, and internal reporting.
Lawitt Buro’s approach:
We are already working with clients to align their policies with future EU AMLA expectations. Our team conducts readiness assessments and regulatory strategy sessions to help clients transition smoothly under the upcoming regime.
4. Conclusion
Cyprus’s AML framework continues to evolve rapidly, reflecting its commitment to transparency and compliance excellence. For clients, these changes bring both new responsibilities and opportunities—from strengthening governance to enhancing trust in international transactions.
At Lawitt Buro, we combine our deep understanding of the regulatory environment with practical legal and compliance support. Whether through policy design, due diligence, or regulatory representation, we help businesses not only meet their AML obligations but also turn compliance into a strategic advantage.