Anti‐Money Laundering (AML) is no longer about minimum compliance. With the EU AML Regulation (AMLR) and the Anti‐Money Laundering Authority (AMLA) set to take full effect in July 2027, Cyprus based firms are expected to begin aligning their frameworks well in advance.
CX Financia supports all obliged entities in Cyprus, including those supervised by CySEC, ICPAC, the Central Bank of Cyprus (CBC), and the Cyprus Bar Association (CBA). We work closely with each firm to embed practical, risk-based AML systems that stand up to scrutiny from any supervisory authority.
End‐to‐End AML & KYC Advisory
We advise firms across high-risk and regulated sectors, including investment firms, funds, CASPs, payment institutions, accountants, and law firms. Every engagement is tailored to your client base, risk profile, and business model, with direct alignment to:
- FATF’s Risk-Based Approach
- AMLR’s Single Rulebook (2027-ready)
- 6AMLD obligations
- National supervisory expectations (CySEC, ICPAC, CBC, CBA)
AML/CFT Manuals and Operational Procedures
We design AML/CFT Manuals that are not only regulator-compliant, but also operationally implementable. Our support includes:
- Tailored policies and controls for your services, delivery channels, and geographies
- Procedures that cover onboarding, monitoring, reporting, record-keeping, and escalation
- Full alignment with the AML Regulation, 6AMLD, and Cyprus supervisory directives
- Structured walkthroughs and team briefings to ensure procedures are understood and applied
Our aim is to ensure that your manual isn’t just written but truly functions as a live governance tool.
KYC, CDD and Enhanced Due Diligence (EDD)
We help design robust and risk-sensitive client due diligence procedures that ensure effective onboarding and periodic review. Services include:
- Risk classification systems that support your CDD process
- EDD procedures for PEPs, high-risk jurisdictions, CASP involvement, and complex ownership
- Source of Wealth (SOW) and Source of Funds (SOF) validation protocols
- Review of file quality and internal documentation to withstand inspection
Transaction Monitoring and Suspicious Activity Reporting (SARs)
We support the development and refinement of AML monitoring environments tailored to your business’s transaction patterns.
- Calibration of automated and manual monitoring tools
- Review and enhancement of red flag trigger logic
- SAR drafting and submission support to MOKAS
- Internal reporting and audit trail documentation for each stage of review
Inspection readiness is not only about documents, it’s about demonstrating understanding, control, and consistency.
AML Inspection Readiness for ICPAC, CySEC, CBC, and CBA
We help firms prepare for on-site inspections, thematic reviews, and follow-up visits by any supervisory authority.
- Review and testing of AML framework effectiveness
- Walkthroughs of onboarding, EDD, monitoring, and SAR files
- Simulation of regulator questions and AMLCO interviews
- Board reporting and governance evidence prep
- Corrective action planning, if gaps are identified
Inspection readiness is not only about document, it’s about demonstrating understanding, control, and consistency.
Regulatory Reporting and Disclosures
We support all statutory and supervisory AML reporting requirements for Cyprus-regulated entities. Our focus is on creating a consistent, regulator-ready reporting trail that aligns with your internal systems and AML manual.
- Annual AMLCO Reports – drafted and reviewed to meet CySEC, ICPAC, CBC, and CBA expectations
- Firm-Wide ML/TF Risk Assessments – tailored to your services, client types, delivery channels, and risk appetite
- Sanctions Logs – guidance on maintaining up-to-date screening records and internal approvals
- Inspection Readiness Files – ensuring your internal documentation matches what’s reported tothe Board and regulators
We help ensure your AML recordkeeping demonstrates not just compliance, but control, clarity, and consistency.
Frequently Asked Questions
What is the difference between AML advisory and an AML audit?
AML advisory helps design and maintain your control framework: manuals, onboarding flows, monitoring, SAR handling, and reporting. AML audits independently assess how effective those systems are in practice. Regulators expect both to be performed and documented separately.
How does AMLA affect Cyprus‐regulated firms in 2026?
Although AMLA’s direct supervision begins in 2028, all firms must comply with the EU’s harmonised AML Regulation from July 2027. Supervisors in Cyprus are already adopting aligned expectations in 2026. Early preparation reduces enforcement exposure.
Can CX Financia act as our Outsourced AML Compliance Officer (AMLCO)?
Yes. We provide qualified and regulator-approved AMLCOs to firms supervised by CySEC, ICPAC, CBC, and CBA. We oversee your AML operations, board reporting, internal audits, and direct liaison with regulators when required.
What do I need before my next AML inspection?
- A 2026-ready AML Manual aligned with AMLR, 6AMLD, and your supervisor’s latest guidance
- Clear CDD and EDD documentation, approvals, and internal audit trails
- A current firm-wide ML/TF risk assessment tailored to your actual activity
- Evidence of AML board briefings, reports, and SARs
We offer inspection-readiness reviews to ensure all key documents and files are audit-ready.