Summary of CySEC's Circular C494

Memo #10-2022
CySEC Circular No: C494
Date: 30/03/2022
Subject: Information on potential Russian Sanctions Evasion Attempts
Purpose: To inform Regulated Entities for informative material issued from competent authorities in relation to Russian sanctions evasion attempts.

In Summary:

CySEC has issued the Circular C494 on 29/03/2022 to inform CIFs, ASPs, UCITS Management Companies, Internally managed UCITS, AIFMs, Internally managed AIFs, Internally managed AIFLNPs, Companies with sole purpose the management of AIFLNPs, Crypto Asset Service Providers and Small AIFMs under Law 81(I)/2020, that the United States Financial Crimes Enforcement Network (FinCEN) and the UK financial regulatory authorities, have issued informative material in relation to potential Russian sanctions evasion attempts and red flags.
 
Specific, a paper issued by the FinCEN alerts all financial institutions to be vigilant against efforts to evade the extensive and continuously updated Sanctions/Restrictive Measures against Russia in response to the crisis in Ukraine, as imposed by the Council of the European Union (EU) and other competent organizations. This paper includes a useful list of red flags to assist in identifying potential sanctions evasion activity.

Also, the UK financial regulatory authorities have issued a Joint statement on sanctions and the cryptoasset sector.

The paper issued by the FinCEN can be found on the following link:

The Joint statement issued by the UK financial regulatory authorities can be found on the following link:
 
CySEC urges Regulated Entities to be aware of these red flags, as highlighted in the informative material issued from competent authorities, when implementing their due diligence measures, especially for ongoing monitoring of accounts and transactions.

Read the CySEC Circular C494

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