Read the CySEC Circular C656
Memo #41-2024
CySEC Circular No: C656
Date: 09/08/2024
Subject: Common weaknesses/deficiencies and good practices identified during the inspections performed in relation to the prevention of money laundering and terrorist financing
Purpose: To share some examples of good practices, as well as some weaknesses/deficiencies commonly identified during inspections performed.
In Summary:
CySEC has issued the Circular C656 on 08/08/2024 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’), about some examples of good practices applied across Regulated Entities, as well as some weaknesses/deficiencies commonly identified during CySEC’s inspections performed related to the assessment of Regulated Entities compliance with the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007, as amended (‘the Law’) and CySEC’s Directive for the Prevention and Suppression of Money Laundering and Terrorist Financing, as amended (‘the Directive’).
This Circular C656 includes good practices and common weaknesses/deficiencies identified by CySEC. Common weaknesses/deficiencies identified in:
• Risk management and procedures manual for the prevention of ML/TF (the ‘Manual’).
• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) Measures.
• AML/CFT Risk Assessments.
• Source of funds and Transactions Monitoring.
• Reporting of suspicious transactions/activities to the Unit for Combating Money Laundering (‘MOKAS’).
• Record Keeping.
CySEC notes that it expects all Regulated Entities to carefully consider the contents of Circular C656 and take the necessary steps to gain assurance that their policies, controls, and procedures are commensurate with their risk profile and comply with the relevant legal and regulatory requirements.
Read the CySEC Circular C656
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