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 Circular C808 to inform regulated entities about a public hearing organised by the Anti-Money Laundering Authority (AMLA). The hearing concerns draft Regulatory Technical Standards (RTS) under Article 11(6) of Regulation (EU) 2024/1620, which will establish rules for a central EU-wide AML/CFT database. This is a clarification and invitation to participate, not a new regulatory obligation. The hearing takes place on 3 November 2026, with registration closing at the same time.
CySEC Circular C808 – 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 managing AIFLNPs, Crypto Asset Service Providers, Small AIFMs under Law 81(I)/2020, Crowdfunding Service Providers
- Deadline: Registration closes on 3 November 2026 at 14:00 CET
- Key requirement: Attend AMLA’s public hearing on draft RTS for a central AML/CFT database
What Does This Circular Require?
What firms must do. You should attend the public hearing organised by AMLA on 3 November 2026 to provide input on the draft Regulatory Technical Standards (RTS) under Article 11(6) of Regulation (EU) 2024/1620. These RTS will define the rules for a central AML/CFT database, including the type of information supervisors will transmit, procedures, formats, and timelines.
Legal basis. Regulation (EU) 2024/1620, Article 11(6)
Regulatory objective. To establish a centralised EU AML/CFT database that enables supervisory authorities to report and retrieve information, identify risks and trends, and support effective supervision and oversight of the EU AML/CFT system.
While attending regulatory public hearings helps compliance teams anticipate cross-border data-sharing expectations, maintaining ongoing internal compliance requires structured education for your compliance officers and risk personnel. To strengthen your firm’s operational 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 fall within the scope of AML/CFT obligations.
- 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
These entities are all subject to AML/CFT supervision under EU and national law.
Edge cases and exceptions:
- Small AIFMs: Although subject to lighter regulatory regimes, they are included in the scope of this circular and should consider attending the hearing.
Practical Implementation: What Firms Should Do
In practice, this circular is an invitation rather than a mandatory requirement. CySEC recommends that you attend the public hearing to understand how the central AML/CFT database will operate and to provide feedback on the draft RTS. This is an opportunity to influence the design of the database, including what information will be collected, how it will be transmitted, and the timelines involved.
A common oversight is assuming that the hearing is only relevant to compliance officers. However, senior management and risk teams should also participate, as the database will impact supervisory practices and risk assessments across the EU. CySEC expects regulated entities to engage proactively with AMLA’s consultation process to ensure the final RTS are practical and effective for all stakeholders.
While central supervisory databases store risk profiles and enforcement records visible to European regulators, investment firms must ensure their localized governance structures operate impeccably. Preparing your core operational framework for heightened EU-wide supervisory visibility begins with our tailored advisory solutions for Investment Firm Licensing (CySEC CIF).
Furthermore, fund managers navigating third-country group structures or cross-border distribution must ensure that fund risk classifications remain consistent across jurisdictions. While central reporting standardizes supervisory oversight, managing fund governance and regulatory filings is detailed under our dedicated guidance on Fund & AIFM Licensing (AIF / RAIF / AIFM).
Key Dates and Deadlines
How to Participate in the Public Hearing
- Review the draft RTS and supporting documents available on AMLA’s website.
- Register for the public hearing before 14:00 CET on 3 November 2026 via the link provided by AMLA.
- Prepare questions or feedback on the draft RTS, focusing on how the central database will impact your operations and supervisory reporting.
- Attend the virtual public hearing on 3 November 2026 from 14:00 to 16:00 CET.
- Submit any written feedback to AMLA following the hearing, if applicable.
Compliance Officer Checklist
- Confirm your entity is within the scope of the circular.
- Review AMLA’s draft RTS and related materials.
- Register for the public hearing before the deadline.
- Identify key stakeholders (compliance, risk, senior management) to attend or contribute.
- Prepare feedback or questions on the draft RTS.
- Attend the hearing and consider submitting written feedback post-event.
Evidence to Retain
- Registration confirmation for the public hearing.
- Notes or minutes from the hearing, including any feedback provided.
- Copies of any written submissions made to AMLA following the hearing.
Why This Matters
The central AML/CFT database will become a cornerstone of EU-wide AML/CFT supervision. By attending the public hearing, you can influence the design of the database, ensuring it aligns with your operational realities and reduces unnecessary compliance burdens. Non-participation may result in RTS that do not adequately address your entity’s needs, potentially leading to inefficiencies or increased compliance costs once the database is operational.
While supervisory databases centralize information without imposing new direct reporting layers on firms, ensuring internal compliance policies stand up to cross-border comparison is essential. While AMLA drives system-level integration, building flexible, future-proof compliance policies is covered in detail through our specialized Financial Regulation Courses.
Frequently Asked Questions
Is attendance at the public hearing mandatory?
No, attendance is not mandatory. CySEC recommends that regulated entities attend to provide input on the draft RTS, but there is no legal obligation to do so.
What is the purpose of the central AML/CFT database?
The database will serve as a single point for EU supervisory authorities to report and retrieve AML/CFT information, enabling better risk identification, trend analysis, and oversight of the EU AML/CFT system.
Who can register for the public hearing?
Any representative of a regulated entity within the scope of the circular, including compliance officers, risk managers, and senior management, can register.
What topics will the draft RTS cover?
The draft RTS will specify the type of information supervisors must transmit to the database, the procedures and formats for transmission, and the timeline for reporting.
How can I access the draft RTS?
The draft RTS and additional information are available directly on the European Commission EUR-Lex Portal or via the official site of the Anti-Money Laundering Authority (AMLA).
Will the public hearing be recorded?
The circular does not state whether the public hearing will be recorded or made available after the event; participants are encouraged to attend the live session.
How CX Financia Can Support You
At CX Financia, we help firms navigate evolving AML/CFT regulatory landscapes. Led by Xenia Neofytou, Executive Director – Regulatory Licensing & Compliance Governance, our team can assist you in reviewing the draft RTS and preparing structured feedback for AMLA.
While participating in consultations is key for strategic insight, maintaining audit-ready controls and risk assessments requires constant advisory backing. To ensure your firm’s compliance, risk management, and internal audit procedures remain fully aligned with upcoming EU-wide standards, explore our comprehensive solutions under Regulatory Compliance & AML Advisory. Contact us today to discuss how we can support your participation in this critical consultation process.
Read the CySEC Circular C808
Read more at Regulatory Updates
Disclaimer
This article provides general information based on CySEC Circular C808 and is not intended as regulatory or legal advice. For specific guidance tailored to your entity, consult a qualified professional or contact CySEC directly