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Circular C266 (Regarding the Specially Designated Nationals List update)

Through the Circular, CySEC wishes herein to draw the attention of the Regulated Entities to the update of the Specially Designated Nationals List (“SDN List”) issued by the Department of the US Treasury’s Office of Foreign Assets Control (“OFAC”) on 06.04.18 relevant press release is accessible here. According to the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), the legislation under which sanctions are issued, sanctions may be enforced against any person (natural/legal) and/or entity which is involved in a significant transaction, or which facilitates the carrying out of such a transaction, with any person subject to such sanctions.

CySEC’s expects that:

  1. Regulated Entities study the provisions of the sanctions implemented under CAATSA including the SDN List, and assess the extent to which Regulated Entities are affected by those measures; and
  2. Regulated Entities assess the risks they undertake in case they are involved in a significant transaction with any person subject to such sanctions. Regulated Entities should avoid the commencement of any business relationship with a prospective client who is subject to sanctions and in case a person subject to sanctions is an existing client, to carefully examine the actions they may need to take.
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