On 22 March 2022, the Cyprus Bar Association (CyBAR) issued a circular about the sanctions and restrictive measures imposed to Russia due to the invasion of Ukraine.

CyBAR urges its members to implement appropriate policies to ensure compliance with the restrictive measures and sanctions decided and published by competent authorities, including carrying out continuous audits of the sanctions lists prior to taking any action that falls within their duties, as administrative service providers or legal advisors.

CyBAR has advised law firms and trust companies in Cyprus to monitor the lists of financial sanctions before offering services or executing transactions for customers, or for third parties, in order to avoid acting on behalf of individuals or legal entities subject to sanctions. In addition, CyBAR encourages firms to:

• Take the appropriate measures to adopt and implement a “sanctions compliance programme” and carry out continuous risk assessment of their customers
• Take immediate action on the implementation of measures and sanctions for legal entities and natural persons that are adopted by the Council of the EU
• Inform the Department of Supervision of Compliance of CyBAR by Friday 8 April 2022 at aml@cba.org.cy in the event of provision of services to legal entities and natural persons and persons related to them that have been sanctioned. Note: CyBAR extended the original deadline of 31 March in their circular issued on 31 March
• In case of imposition of additional restrictive measures and sanctions against Russia and/or Belarus due to the crisis in Ukraine, to inform the CyBAR within 10 days from the publication of the relevant measures/sanctions, as defined in the second bullet point above

Breaches of imposed financial sanctions may lead to criminal prosecution and sanctions by CyBAR.

CyBAR’s Circular of 22 March (in Greek) can be found here.

CyBAR’s Circular of 31 March extending the reporting deadline (in Greek) can be found here.