Published on: 14 October 2026 | By: Xenia Neofytou, B.Sc. (Hons), FCCA
Founder & Managing Director, CX Financia | CySEC Advanced Certificate Holder
Introduction
On 13 October 2026, the Cyprus Securities and Exchange Commission (CySEC) issued CySEC Circular C806 to inform regulated entities that the Anti-Money Laundering Authority (AMLA) has finalised three sets of Regulatory Technical Standards (RTS) under Regulation (EU) 2026/1624 (AMLR). This is a clarification and reminder of an upcoming obligation: once adopted and published in the Official Journal of the EU, the RTS will apply six months after their entry into force. You must review the published material and prepare to update your AML/CFT policies, systems and procedures accordingly.
CySEC Circular C806 – At a Glance
- Issued date: 13 October 2026
- Applies to: CIFs, ASPs, UCITS Management Companies, internally managed UCITS, AIFMs, internally managed AIFs, internally managed AIFLNPs, companies with sole purpose the management of AIFLNPs, Crypto Asset Service Providers, Small AIFMs under Law 81(I)/2020, Crowdfunding Service Providers
- Key requirement: Study AMLA’s final RTS and prepare to adopt the new standards once they enter into force
What Does This Circular Require?
What firms must do. You must study the published final reports and factsheets on AMLA’s website and proceed with the necessary changes to your policies, checks, systems and procedures to align with the new RTS.
Legal basis. Regulation (EU) 2026/1624 (AMLR), specifically articles 28(1), 19(9), 16(4) and 17(3)
Regulatory objective. To ensure consistent application of customer due diligence, criteria for identifying business relationships and transactions, and group-wide AML/CFT requirements across the EU.
While establishing compliance frameworks under new technical standards requires clear operational policies, maintaining ongoing compliance depends heavily on specialized expertise and ongoing staff education. To strengthen your firm’s internal controls and regulatory readiness, explore our specialized training programmes under Anti-Money Laundering Seminars.
Who Is in Scope?
The circular applies to all regulated entities under CySEC supervision that are subject to AML/CFT obligations under the AMLR.
- CIFs
- ASPs
- UCITS Management Companies
- Internally managed UCITS
- AIFMs
- Internally managed AIFs
- Internally managed AIFLNPs
- Companies with sole purpose the management of AIFLNPs
- Crypto Asset Service Providers
- Small AIFMs under Law 81(I)/2020
- Crowdfunding Service Providers
The circular maps to all sectors supervised by CySEC that fall within the scope of the AMLR.
Edge cases and exceptions:
- Small AIFMs under Law 81(I)/2020: Must comply despite lighter regulatory regime
- Crypto Asset Service Providers: Subject to the same RTS as traditional financial entities
Practical Implementation: What Firms Should Do
In practice, you should download the final reports and factsheets from AMLA’s website and conduct a gap analysis against your current AML/CFT framework. Identify where your policies, customer due diligence processes, and group-wide measures do not yet meet the new standards.
CySEC expects you to begin preparing internal guidance, training materials, and system updates now, even though the RTS are not yet in force. Common mistakes include waiting until the RTS are published in the Official Journal before taking action, or assuming that existing procedures are already compliant without verification.
While these standards set uniform rules across the EU, financial institutions and investment firms face distinct operational obligations depending on their license structure. While CySEC oversight mandates rigorous customer due diligence, ensuring overall supervisory preparedness across your entire operation starts with our tailored advisory services under Investment Firm Licensing (CySEC CIF).
Furthermore, funds and asset managers operating under lighter regulatory regimes or third-country group structures must pay close attention to group-wide governance standards. While the RTS enforce standardized cross-border controls, managing the scope of compliance across fund structures relies on sound structuring, as outlined in our dedicated guidance on Fund & AIFM Licensing (AIF / RAIF / AIFM).
Key Dates and Deadlines
How to Apply This Correctly
- Download the final reports and factsheets for each RTS from AMLA’s website.
- Conduct a gap analysis comparing your current AML/CFT policies, procedures, and systems against the new standards.
- Document all gaps and prepare an action plan to address them, including timelines and responsible personnel.
- Update your internal policies, customer due diligence processes, and group-wide AML/CFT measures to align with the RTS.
- Develop or update training programmes for relevant staff to ensure awareness and understanding of the new requirements.
- Monitor the Official Journal of the EU for the publication of the adopted RTS and note the application date.
Compliance Officer Checklist
- Final reports and factsheets for all three RTS downloaded and reviewed
- Gap analysis completed and documented
- Action plan prepared with clear timelines and responsibilities
- Policies and procedures updated to reflect the new RTS
- Training materials developed or updated for relevant staff
- Process in place to monitor the Official Journal for RTS publication
Evidence to Retain
- Copies of the downloaded final reports and factsheets from AMLA’s website
- Documented gap analysis and action plan
- Updated AML/CFT policies and procedures
- Training records and materials for staff
- Records of monitoring activities for the Official Journal publication
Why This Matters
The new RTS will introduce binding, detailed requirements for customer due diligence, transaction monitoring, and group-wide AML/CFT measures. Non-compliance after the application date may result in supervisory action, including fines or other enforcement measures. Proactively aligning with the RTS ensures you avoid last-minute disruptions and demonstrate robust AML/CFT controls to CySEC and AMLA.
While technical standards mandate direct compliance, the underlying legal framework forms part of a broader shift in European regulatory supervision. While national competent authorities drive immediate implementation, maintaining long-term compliance across evolving directives is covered under our specialized Financial Regulation Courses.
Frequently Asked Questions
Are the RTS already in force?
No. The RTS have been finalised by AMLA and submitted to the European Commission. They will apply six months after being adopted and published in the Official Journal of the EU, available on EUR-Lex.
Do we need to submit anything to CySEC under Circular C806?
No. The circular is a reminder to study the published material and prepare for the RTS. There is no submission requirement to CySEC at this stage.
What are the three sets of RTS about?
The RTS cover: (1) Customer Due Diligence, (2) Criteria for identifying business relationships, occasional and linked transactions, and (3) Group-wide minimum requirements and additional measures for subsidiaries and branches in third countries. Official reports and factsheets can be directly accessed via the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA).
Do the RTS apply to Small AIFMs under Law 81(I)/2020?
Yes. The circular explicitly includes Small AIFMs under Law 81(I)/2020 in the list of regulated entities that must comply with the RTS.
What should we do now?
You should study the final reports and factsheets, conduct a gap analysis, and prepare to update your policies, systems, and procedures to align with the new standards.
When will the RTS be published in the Official Journal?
The circular does not specify a date. You must monitor the Official Journal of the EU for the publication of the adopted RTS.
How CX Financia Can Support You
At CX Financia, we help firms navigate evolving AML/CFT regulations through our Regulatory Compliance, AML/CFT, and Risk Management services. Our team can assist you in conducting gap analyses, updating policies and procedures, and training staff to ensure seamless alignment with the new RTS.
While updating internal documentation is critical, ensuring your ongoing compliance operations withstand supervisory scrutiny requires continuous technical support. To ensure your firm maintains audit-ready frameworks, explore our full range of solutions under Regulatory Compliance & AML Advisory.
Read the CySEC Circular C806
Read more at Regulatory Updates
Disclaimer
This article provides general information based on CySEC Circular C806 and is not intended as regulatory advice. For specific guidance tailored to your firm, consult a qualified compliance professional or legal advisor.