Read the CySEC Circular C724
Memo #48-2025
CySEC Circular No: C724
Date: 06/08/2025
Subject: New legal framework for Restrictive Measures/Sanctions in the Republic of Cyprus
Purpose: To inform the Regulated Entities that three new pieces of legislation were published regarding the issue of Restrictive Measures/Sanctions.
In Summary:
CySEC has issued the Circular C724 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 on Friday, 25/07/2025, three new pieces of legislation (one of which is an amending law) were published in the Official Gazette of the Republic of Cyprus, regarding the issue of Restrictive Measures/Sanctions.
These pieces of legislation, which together constitute the new legal framework for Restrictive Measures/Sanctions, are now, after their publication in the Official Gazette, in force.
The three new pieces of legislation are:
1) The Criminalization of the Violation of the Restrictive Measures of the European Union Law of 2025 (L. 149(Ι)/2025).
2) The Establishment of the National Sanctions Implementation Unit Law of 2025 (L. 150(Ι)/2025).
3) The Protection of Persons Reporting Breaches of Union and National Law (Amending) Law of 2025 (L. 148(Ι)/2025).
Circular C724 analyses in brief the three new pieces of legislation.
In accordance with the Circular C724, the CySEC calls the Regulated Entities to harmonise the existing measures and procedures in place that are designed and implemented for the detection of actions that are in breach or may potentially be in breach of the provisions of the Restrictive Measures and/or Sanctions, in accordance with the new legal framework for Restrictive Measures/Sanctions that is in force in the Republic of Cyprus.
The Criminalization of the Violation of the Restrictive Measures of the European Union Law of 2025 (L. 149(Ι)/2025) can be found on the following link: https://www.cylaw.org/nomoi/arith/2025_1_149.pdf
The Establishment of the National Sanctions Implementation Unit Law of 2025 (L. 150(Ι)/2025) can be found on the following link: https://www.cylaw.org/nomoi/arith/2025_1_150.pdf
The Protection of Persons Reporting Breaches of Union and National Law (Amending) Law of 2025 (L. 148(Ι)/2025) can be found on the following link: https://www.cylaw.org/nomoi/arith/2025_1_148.pdf
Read the CySEC Circular C724
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