AML Definitions

This is the report prepared and submitted annually by the Compliance Officer to ICPAC

Includes all initiatives, policies and processes that the Firm should adopt in order to combat Money Laundering.

Central register of beneficial owners of companies and other legal entities hosted at the Cyprus Companies Registrar

The Firm’s policy that specifies when the Firm accepts and when declines a business relationship with a Client

A simplified KYC process for obtaining Client related information to establish a better knowledge, understanding and insight of a Client.

The Information Triad, a model designed to guide policies for information security within an organization

The Cyprus program that is in act at the time of assessment, aiming investment stimulus

The person appointed in the Firm, as per the relevant legislation, being responsible for the implementation of an AML and ATF Management System within the Firm.

A digital representation of value that is not issued or guaranteed by a central bank or a public authority, is not necessarily attached to a legally established currency and does not possess a legal status of currency or money, but is accepted by natural or legal persons as a means of exchange and which can be transferred, stored, and traded electronically, and it is not (a) fiat currency, or (b) electronic money, or (c) financial instruments, as these are specified in Part III of the First Appendix to the Investment Services and the Activities and Regulated Markets Law

Includes all initiatives, policies and processes that the Firm should adopt in order to combat Terrorism Financing.

An enhanced KYC process for obtaining Client related information to establish a better knowledge, understanding and insight of a Client. It includes all of CDD analysis plus Sources of Wealth analysis

A global money laundering and terrorist financing watchdog. The FATF works to generate the necessary political will to bring about national legislative and regulatory reforms

Any form of an entity, other than a physical person, that has legal rights and obligations

Money laundering is the illegal process of concealing the origins of money obtained illegally by passing it through a complex sequence of banking transfers or commercial transactions

The Financial Intelligence Unit of the Republic, responsible for Combating Money Laundering and established under section 54 of the Law, also known as the Unit or the FIU

The permanent monitoring body of the Council of Europe entrusted with the task of assessing compliance with the principal international standards to counter money laundering and the terrorist financing of terrorism and the effectiveness of their implementation

Any of the entities mentioned in section 2A of the Law, including all ICPAC members

1. A natural person who is or who has been entrusted with prominent public functions and includes the following: (a) heads of State, heads of government, ministers and deputy or assistant ministers; (b) members of parliament or of similar legislative bodies; (c) members of the governing bodies of political parties; (d) members of supreme courts, of constitutional courts or of other high-level judicial bodies, the decisions of which are not subject to further appeal, except in exceptional circumstances; (e) members of courts of auditors or of the boards of central banks; (f) ambassadors, chargés d'affaires and high-ranking officers in the armed forces; (g) members of the administrative, management or supervisory bodies of State-owned enterprises; (h) directors, deputy directors and members of the board or equivalent function of an international organization. (e) mayors

2. The family members of PEPs which includes the following: (a) the spouse, or a person considered to be equivalent to a spouse, of a politically exposed person; (b) the children and their spouses, or persons considered to be equivalent to a spouse, of a politically exposed person; (c) the parents of a politically exposed person;

3. The persons known to be close associates of PEPs which means: (a) natural persons who are known to have joint beneficial ownership of legal entities or legal arrangements, or any other close business relations, with a politically exposed person; (b) natural persons who have sole beneficial ownership of a legal Entity or legal arrangement which is known to have been set up for the de facto benefit of a politically exposed person.

is a process that allows you to identify potential risks of money laundering and terrorist financing and develop strategies to mitigate them

Suspicious Activity (SA) arises from suspicion relating to general behavior of the person in question which creates the knowledge or belief that he or she may be involved in illegal activities out of which revenue might be generated.

Refers to the origin of the particular funds or assets which are the subject of the business relationship between the firm and its client 

Refers to the origin of the entire body of wealth (i.e. total assets) of the client at present values

Suspicious Transaction (ST) arise from the suspicion created by a specific transaction, which creates the knowledge or belief that the transaction may relate to the legitimization of proceeds from illegal activities.

Is the provision of funds or providing financial support to individual terrorists or non-state actors

A written legal arrangement with which the settlor transfers property to one or more trustees who hold it for the benefit of one or more persons/beneficiaries.