Read the CySEC Circular C723
Memo #47-2025
CySEC Circular No: C723
Date: 06/08/2025
Subject: EBA’s Opinion on money laundering and terrorist financing risks affecting the EU’s financial sector
Purpose: To inform the Regulated Entities that the EBA has published its fifth Opinion on money laundering and terrorist financing risks affecting the EU’s financial sector.
In Summary:
CySEC has issued the Circular C723 on 01/08/2025 to inform 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, Small Alternative Investment Fund Managers (‘Small AIFMs’) and the Crypto Asset Service Providers, that the European Banking Authority (the ‘EBA’) has published its fifth Opinion on money laundering and terrorist financing risks affecting the EU’s financial sector (the ‘Opinion’).
The Opinion is based on data from January 2022 to December 2024.
According to the EBA, since its fourth Opinion on ML/TF risks, the financial sector has faced a dynamic and increasingly complex ML/TF risk landscape. The rapid evolution of financial technologies and new financial products such as crypto assets, and the growing interconnection of financial products and services across sectors, have introduced new vulnerabilities.
Circular C723 refers to a number of observations that the EBA has highlighted in its Opinion.
The CySEC notes that the EBA's Opinion constitutes an important source of information which Regulated Entities must consider when identifying and assessing ML/TF risks on the basis of section 58A of the Prevention and Suppression of Money Laundering and Terrorist Financing Laws of 2007- 2025, in order to improve the effectiveness and efficiency of their AML/CFT systems and controls.
The CySEC further notes that it expects that Regulated Entities take due account of and consult the Opinion.
The EBA’s fifth Opinion can be found on the following link:
Read the CySEC Circular C723
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