The Cyprus Securities and Exchange Commission has issued the Circular C132 with additional instructions regarding the publicly available list of persons that are included in the Panama Papers.
These instructions concern the following regulated entities:
- Cyprus Investment Firms
- Administrative Service Providers
- UCITS Management Companies
- Alternative Investment Fund Managers
- Self Managed Alternative Investment Funds
- Self Managed Alternative Investment Fund with Limited Number of Persons
- External Managed Alternative Investment Fund with Limited Number of Persons
If any of the aforementioned entities has identified any business relationship with any of the persons included in the Panama papers, then it is subject to the following obligations:
- Review and update the KYC documents and any information included in their profile;
- Proceed to the review and thorough examination of ther clients’ activities and transactions in order to determine whether these may be related to any money laundering activities;
- Proceed to the reassessment of their clients’ risk categorisation and to their reclassification, if required.
Following the Panama Papers incident, the regulations regarding the prevention of money laundering activities have been strengthened, hence, it is essential that all concerned entities remain in compliance with the additional requirements.
