+357 25 81 99 66


The Circular C132, issued by the Cyprus Securities and Exchange Commission (CySEC), contains additional guidelines concerning the legal and natural persons that are included in the leak documents of the Panamanian law firm Mossack Fonseca (Panama Papers).

Specifically, the instructions of Circular C132 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

It should be pointed out that a Directive issued by the Unit for Combating Money Laundering (MOKAS) clarifies the reporting obligations of the regulated entities regarding the publicly available list of legal and natural persons that are included in “Panama Papers.”

As a result, if any of the regulated entities mentioned above has identified any business relationship with legal or natural persons included into the Panama Papers, then they are obliged to:

  1. Review and update their customers’ identification documents and any data included in their profile;
  2. Examine the activities and transactions of their customers in order to identify whether these may be associated with any money laundering activities;
  3. Reassess, and if necessary, reclassify the risk categorisation of their customers according to the risk-based approach which they internally implement;

CySEC emphasises that it is expected from the regulated entities to assist the continuous monitoring of the issue relating to the Panama Papers and the ongoing monitoring of the business relationships with their clients as required by the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007-2016 and the CySEC Directive DI144- 2007-08 of 2012 for the Prevention of Money Laundering and Terrorist Financing.

In addition, the regulations concerning the prevention of money laundering activities have been reinforced. Therefore, it is important that the regulated entities comply with the additional requirements. For more details, please contact one of our lawyers. The legal team of Michael Chambers & Co. LLC may provide you with a proper administrative and legal guidance. If you wish to speak to one of our lawyers, then please contact us: info@chambers.law