Although CySEC has observed significant improvement in the internal procedures and measures applied by Regulated Entities to prevent ML and TF,
in compliance with the AML Law and AML Directive, CySEC has also identified common and recurring weaknesses and/or deficiencies in Regulated Entities’ compliance with the AML Law and AML Directive, in the following areas:
- Client Due Diligence
- Timing of verification of the Client’s identification
- Termination of the business relationship with Clients
- Ongoing monitoring of Clients’ accounts and transactions
- Internal suspicious reporting and reporting to MOKAS
CySEC’s expects that: Regulated Entities shall uphold their duty to maintain and improve the systems, controls and procedures for the prevention of ML and TF, since non-compliance with AML Law and AML Directive will be subject to the administrative sanctions. Please refer to the Circular for further details on each of the areas referred to, above.