CH-03 · regulatory walkthrough

CySEC AML walkthrough

Date-anchored timeline of AML obligations affecting CySEC-regulated brokerage operators, from the AML Law L.13(I)/2018 baseline through the EU AMLR transition in July 2027. Action-required notes per milestone help operators map their compliance roadmap.

CySEC AML walkthrough — 2018 to 2027+

Date-anchored timeline of CySEC AML obligations affecting brokerage operators, from the AML Law L.13(I)/2018 baseline through the EU AMLR transition in July 2027.

Baseline obligation
Currently in force
Upcoming requirement
Missed-deadline risk
  1. Baseline obligation

    AML Law L.13(I)/2018 enacted

    Citation: CySEC Law 13(I)/2018

    Action required: Implement baseline KYC + AML procedures; designate MLRO; quarterly reporting to CySEC.

  2. Baseline obligation

    5AMLD transposed into Cyprus law

    Citation: EU Directive 2018/843

    Action required: Enhanced PEP screening; UBO register access; high-risk-country obligations.

  3. Currently in force

    6AMLD enforcement (criminal liability)

    Citation: EU Directive 2018/1673

    Action required: Criminal liability extends to legal entities; document chain-of-custody on all AML decisions.

  4. Currently in force

    CySEC sanctions regime expansion

    Citation: CySEC Circular C612

    Action required: Russia/Belarus sanctions screening extended; ComplyAdvantage Mesh or equivalent recommended.

  5. Currently in force

    Sumsub × ComplyAdvantage Mesh launch

    Action required: Sumsub customers gain native sanctions/PEP/adverse-media via Mesh. Reduces standalone ComplyAdvantage need.

  6. Upcoming requirement

    EU AMLR full transition deadline

    Citation: EU Regulation 2024/1624

    Action required: Unified EU AML rulebook supersedes 5AMLD/6AMLD. Plan compliance migration starting H2 2026.