Read the CySEC Circular C686
Memo #12-2025
CySEC Circular No: C686
Date: 10/03/2025
Subject: Financial Action Task Force’s Public Consultation on Complex Proliferation Financing and Sanctions Evasion Schemes project
Purpose: To inform the Regulated Entities that the FATF launched a public consultation on Complex Proliferation Financing and Sanctions Evasion Schemes project.
In Summary:
CySEC has issued the Circular C686 on 10/03/2025 to inform the Crypto Asset Service Providers (‘CASPs’), 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 and the Small Alternative Investment Fund Managers (‘Small AIFMs’), that the Financial Action Task Force (the ‘FATF’) launched on 26/02/2025 a public consultation on Complex Proliferation Financing and Sanctions Evasion Schemes project.
In October 2020, the FATF adopted amendments to Recommendations 1 and 2 (R.1 and R.2) and their Interpretive Notes (INR.1 and INR.2) to require countries, financial institutions, designated non-financial businesses and professions (the ‘DNFBPs’) and virtual asset service providers (the ‘VASPs’) to identify, assess, and understand their proliferation financing risks i.e. the risk of potential breaches, non-implementation or evasion of the targeted financial sanctions (the ‘TFS’) detailed in R.7, and to take effective mitigation measures which are commensurate to the identified risks.
The FATF is undertaking a study aimed at improving country and private sector understanding of current Proliferation Financing (the ‘PF’) risks.
The resulting report will focus on providing a comprehensive up-to-date understanding of typologies in complex sanctions evasion schemes relevant to PF and identifying enforcement challenges and best practices, which helps to inform countries’ PF risk assessment and risk mitigation.
Responses to the questions can be provided by completing the online form by COB Paris time, Friday 21/03/2025.
The CySEC encourages the Regulated Entities to respond to the said consultation paper.
The FATF public consultation on Complex Proliferation Financing and Sanctions Evasion Schemes project can be found on the following link:
Read the CySEC Circular C686
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