Read the CySEC Circular C685
Memo #11-2025
CySEC Circular No: C685
Date: 27/02/2025
Subject: Guidance on Sanctions Screening Systems
Purpose: To notify the Regulated Entities that CySEC issued a practical guide on Guidance for maintaining effective and efficient Sanctions Screening Systems.
In Summary:
CySEC has issued the Circular C685 on 27/02/2025 to notify the Cyprus Investment Firms (‘CIFs’), Administrative Service Providers (‘ASPs’), UCITS Management Companies (‘UCITS MC’), Self-Managed UCITS (‘SM UCITS’), Alternative Investment Fund Managers (‘AIFMs’), Self-Managed Alternative Investment Funds (‘SM AIFs’), Self-Managed Alternative Investment Funds with Limited Number of Persons (‘SM AIFLNP’), Companies with sole purpose the management of AIFLNPs, Crypto Asset Service Providers (‘CASPs’), and the Small Alternative Investment Fund Managers (‘Small AIFMs’) that CySEC has issued a practical guide on Guidance for maintaining effective and efficient Sanctions Screening Systems.
The Guidance is available on CySEC’s website.
CySEC informs that during the period April-November 2024, CySEC conducted thematic inspections that included all types of Regulated Entities, to assess the effectiveness and efficiency of the Sanctions screening systems used by a sample of Regulated Entities.
Specifically, the thematic inspections focused on screening the UN and EU Sanctions Lists to identify designated persons, as well as relevant screening practices for U.S. and UK Sanctions Lists.
The purpose of publishing this Guidance is to share the outcomes and feedback of these thematic inspections to all Regulated Entities, clarify CySEC’s expectations on screening practices and provide guidance on best practices in testing, tuning and optimisation of screening systems for overall compliance.
The Guidance Paper outlines, among others, the best practices identified during these thematic inspections, as well as an overview of the weaknesses/deficiencies identified.
CySEC notes that Regulated Entities should consider the CySEC’s supervisory expectations set out in the Guidance Paper as a benchmark, so as to implement best practices identified in a risk-based and proportionate manner.
The CySEC’s practical guide on Guidance for maintaining effective and efficient Sanctions Screening Systems can be found on the following link: https://www.cysec.gov.cy/en-GB/Files/AML/98989.aspx/.
Read the CySEC Circular C685
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