Cyprus AML Compliance Overview (5AMLD and 6AMLD)

Implications of 5AMLD and 6AMLD for Cyprus

Directive	Status in Cyprus	Main Implications
5AMLD	✅ Fully implemented (Law 13(I)/2021)	UBO Register, crypto sector regulation, enhanced due diligence, wider access to ownership data
6AMLD	❌ Not yet transposed	Criminalization of ML, company liability, wider predicate offences, tougher sanctions

Practical Compliance Measures

Area	Required Actions Now (5AMLD)	Prepare for Future (6AMLD)
KYC/Customer Due Diligence	Enhanced verification, ongoing checks	Extend monitoring to new predicate offences
AML Policies & Procedures	Updated policies, onboarding adjustments	New internal rules covering corporate criminal liability
Crypto Businesses	Register with CySEC, apply AML rules	Prepare additional reports for upcoming direct EU oversight
Training	Staff training on new risk indicators	Criminal risk exposure training for management and staff
Internal Controls	Implement UBO monitoring, STR reporting	Systems to detect/report all predicate offences
Corporate Governance	Appoint AML compliance officers, internal audits	Prove active monitoring and prevention of internal money laundering

AML Compliance Checklist (5AMLD/6AMLD)

✔️	Area	Checkpoint	5AMLD Compliance	6AMLD Preparation
	UBO Register	Submitted and updated beneficial ownership data?	✅	-
	KYC Processes	Updated for high-risk country clients?	✅	🔄 (Add new predicate crimes risk)
	Virtual Assets	Registered with CySEC if operating in crypto?	✅	-
	STR Reporting	Internal procedures active?	✅	🔄 (Extend to all 22 predicate offences)
	Internal Training	AML/CTF training completed in last 12 months?	✅	🔄 (Add corporate liability training)
	Risk Assessment	Updated institutional risk review?	✅	🔄 (Environmental crime, cybercrime risk)
	Criminal Liability Controls	Internal rules to prevent ML facilitation?	❌	🔄 (Mandatory under 6AMLD)
	Board Involvement	Regular AML compliance reporting to Board?	✅	🔄 (Formalize reporting)

✅ = Mandatory now
🔄 = Start preparing now

Internal "AML Readiness Report" Template

Company Name:

Reporting Period:

1. UBO Register

Are all UBO records updated and submitted?
Date of last update:

2. Customer Due Diligence

Are customer KYC files up-to-date?
EDD applied to high-risk third countries?

3. Suspicious Transaction Reporting (STR)

STRs filed to MOKAS this period:
Number of internal reports escalated:

4. Staff Training

Date of last AML training session:
Topics covered:

5. Internal Controls & Governance

Last internal AML audit performed:
Findings and corrective actions taken:

6. Preparation for 6AMLD

Initial risk assessment updated for 6AMLD predicate offences?
Policies adapted for corporate criminal liability?