Cyprus

Global sanctions guide

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  1. Does Cyprus have a sanctions regime in place? 

Yes.

  1. Does Cyprus implement UN sanctions? 

Yes.

  1. Does Cyprus implement an autonomous sanctions regime? 

Sanctions are adopted and implemented in accordance with International Law. As a member of the UN and a member state of the EU, Cyprus has an obligation to enforce/implement:

  • International Sanctions by a relevant Decision/Resolution adopted by the UNSC under chapter VII of the UN Charter
  • Restrictive Measures adopted by the Council of the EU via relevant Decisions and Regulations, within the framework of Common Foreign and Security Policy (“CFSP”)
  1. What is the nature of the sanctions regime in Cyprus? 

As a member of the UN and EU, Cyprus has measures such as arms and trade embargoes (restrictions to imports/ exports). Financial restrictions, freezing of assets and visa or travel bans are some of the means most commonly used to achieve the objectives, according to the situation at hand.

The CFSP is subject to specific rules and procedures. It shall be defined and implemented by the European Council and the Council of the EU, on the basis of unanimity, except where the Treaties provide otherwise (Article 24 of the Treaty on European Union, TEU).

Decisions and Regulations of the Council of the EU in the framework of CFSP (autonomous restrictive measures and incorporation of UNSC sanctions) constitute in their entirety part of EU Law, which supersedes the national legislation of member states. Therefore, these legal acts are legally binding on all EU member states, with Regulations being directly applicable by member states (ie they require no implementing legislation).

As is set out by Article 297 (2) of the TEC, Decisions and Regulations of the Council of the EU, which are adopted in the framework of CFSP, are then published in the EU Official Journal and take effect on the date specified therein.

  1. Does Cyprus maintain a list of sanctioned individuals and entities? 

No, it follows the UN and EU lists.

  1. Are there any other lists related to sanctions? 

No.

  1. Does Cyprus have a licensing or authorisation system in place? 

Yes, the Central Bank of Cyprus is the competent authority for the transfer of funds, and for applications and notifications of the granting of licences with respect to such transfers of funds, which fall within the scope of the Decisions and Regulations of the EU Council (restrictive measures) and the Decisions/Resolutions of the UNSC (sanctions). The Ministry of Finance’s Advisory Body on Financial Sanctions is the competent authority for the notification of the granting of a license or the intention to grant a license and of the approval of a request or the intention to approve a request, with respect to the release of funds and financial resources. Trade Services (Imports/Exports Licensing Section) is the competent authority for export control for dual-use goods, arms and military equipment.

  1. What are the consequences for a breach of sanctions in Cyprus? 

In Cyprus infringements of EU Regulations constitute a criminal offense and are dealt with on the basis of invoking Articles 136 and 137 of the Criminal Code (Chapter 154).

  1. Who are the relevant regulators in Cyprus and what are their contact details?

The role of the Ministry of Foreign Affairs with regard to both UNSC sanctions and EU restrictive measures is, by-and-large, coordinative.  It must be noted that the Ministry of Foreign Affairs is neither responsible for issuing approvals/licences and/or official opinions/advice on sanctions’ issues, nor for interpreting the legal acts by which UNSC sanctions and EU restrictive measures are adopted.

Ministry of Foreign Affairs, Presidential Palace Avenue, 1447 Nicosia Cyprus

T: (+357) 22 651000
E: minforeign1@mfa.gov.cy
www.mfa.gov.cy

Law Office of the Republic of Cyprus, Unit for Combating Money Laundering (MOKAS), The Unit for Combating Money Laundering, Law Office of the Republic of Cyprus, PO Box 23768, 1686 Nicosia Cyprus

T: (+357) 22 446 021
F: (+357) 22 317 063
E: mokas@mokas.law.gov.cy  /  epanayiotou@mokas.law.gov.cy
http://www.law.gov.cy/mokas

Central Bank of Cyprus, Department of Licensing and Regulatory Compliance, PO Box 25529, 1395 Nicosia Cyprus

T: (+357) 22 714 300
F: (+357) 22 374 940
E: BSRD.compliance@centralbank.gov.cy
http://www.centralbank.gov.cy/

Ministry of Finance, Advisory Body on Financial Sanctions, Corner of Michael Karaoli & Gregori Afxentiou, 1439 Nicosia, Cyprus

T: (+357) 22 601 172
F: (+357) 22 602 748
E: registry@mof.gov.cy
http://www.mof.gov.cy

Customs and Excise Department, Ministry of Finance, Customs and Excise Department, Corner of Michael Karaoli & Gregori Afxentiou, 1439, Nicosia, Cyprus

T: +357 22 601 705, +357 22 601 670, +357 22 601 680
F: +357 22 302 018
E:  headquarters@customs.mof.gov. cy, andronikou@customs.mof.gov.cy, sconstantinou@customs.mof.gov.cy, rconstantinou@customs.mof.gov.cy

www.mof.gov.cy/ce

Ministry of the Interior, Civil Registry and Migration Department 1457, Nicosia, Cyprus

T: +357 22 804 405
F: +357 22 403 961
E: migration@crmd.moi.gov.cy

www.moi.gov.cy/moi/crmd/crmd.nsf

Department of Lands and Surveys, Ministry of the Interior, Headquarters of the Department of Lands and Surveys, 29 Michalakopoulou, 1455 Nicosia, Cyprus

T: +357 22 804 900, +357 22 804 817
F: +357 22 804 928
E: ccharalambous@dls.moi.gov.cy

www.moi.gov.cy/dls nsf

Ministry of Transport, Communications and Works, Ministry of Communications and Works Department of Merchant Shipping, Acheon 28, 1424 Nicosia, Cyprus

T: +357 22 800 288
F: +357 22 776 266
E: maritimeadmin@dms.mcw.gov.cy

www.mcw.gov.cy/mcw/mcw.nsf/ index_en/index_en?OpenDocument

Department of Civil Aviation, Ministry of Communications and Works Central Offices of Department of Civil Aviation, Pindarou Street 27, Alpha Business Center, 1429 Nicosia, Cyprus

T: +357 22 404 122, +357 22 404 136
F: +357 22 766 547
E: mioannou@dca.mcw.gov.cy, sstephanou@dca.mcw.gov.cy

Ministry of Energy, Commerce, Industry and Tourism, Department of Registrar of Companies and Official Receiver, Corner of Makarios III Avenue & Karpenisiou Street, “XENIOS” Building, 1427 Nicosia, Cyprus

 

T: +357 22 404 301, +357 22 404 302
F: +357 22 304 887
E: deptcomp@drcor.mcit.gov.cy, eterion@drcor.mcit.gov.cy

www.mcit.gov.cy/drcor

Trade Services (Imports/Exports Licensing Section), Ministry of Energy, Commerce, Industry and Tourism, Trade Services (Imports/Exports Licensing Section), 6 Andrea Araouzou Street, 1421 Nicosia, Cyprus

T: +357 22 867 100, +357 22 867 332, +357 22 867 197
F: +357 22 375 120, +357 22 375 443
E: xxenopoulos@mcit.gov.cy, pevgeniou@ mcit.gov.cy

www.mcit.gov.cy/ts

Energy Service, Ministry of Energy, Commerce, Industry and Tourism, Energy Service, 6 Andrea Araouzou Street, 1421 Nicosia, Cyprus

T: +357 22 867 100
F: +357 22 375 120, +357 22 304 759
E: perm.sec@mcit.gov.cy

www.mcit.gov.cy/mcit/mcit.nsf/dmlenergyservice.gr

Ministry of Justice and Public Order, 125 Athalassas Avenue, 1461 Nicosia, Cyprus

T: +357 22 805 920/1
F: +357 22 805 969
E: registry@mjpo.gov.cy

www.mjpo.gov.cy

Cyprus Police, European Union and International Police Cooperation Directorate, Cyprus Police, Cyprus Police Headquarters

 

T: +357 22 607 825
F: +357 22 607 894
E: euipcd@police.gov.cy

www.police.gov.cy

Cyprus Securities and Exchange Commission, Cyprus Exchange and Securities Commission, 27 Diagorou Str, 1097 Nicosia, PO Box 24996, 1306 Nicosia

T: +357 22 50 6600
F: +357 22 50 6700
E: info@cysec.gov.cy

www.cysec.gov.cy/en-GB/home/

 

Contributor law firm

Eversheds LLP, One Wood Street, London, United Kingdom. EC2V 7WS