REGULATORY Archives - Andria Papageorgiou

Circular C589 – MONEYVAL’s report on money laundering and financing of terrorism risks in the world of virtual assets

We would like to draw your attention to Circular C589 (the “Circular”), issued by the Cyprus Securities and Exchange Commission (the “CySEC”) on the 18^th of July 2023, for the purposes of informing Regulated Entities, as these defined therein, about MONEYVAL’s Report on money laundering and financing of terrorism risk in the world of virtual assets (the “Report”).

A. Purpose:

The Report purports to present in an integrated manner an overview of the money laundering and financing of terrorism risks in the world of virtual assets (the “VAs”) and their service providers in MONEYVAL members. In order to do this, the Report includes the following:

horizontal analysis of MONEYVAL’s members’ level of compliance with the Financial Action Task Force (the “FATF”) Recommendation 15;
an overview of the measures taken to regulate and supervise virtual asset service providers (the “VASPs”) sector; and
features of the identified risks that criminals use VASPs and VAs to launder proceeds of crimes (i.e. exchanges, exchange offices, aggregators, and other cryptocurrency platforms including e-gaming, sports betting, and NTFs).

In particular, the Report integrates and analyses data obtained from MONEYVAL members across multiple issues, relating to (a) how members regulated the activity of issuance of Vas and operation of VASPs; (b) whether the Law Enforcement Authorities (LEAs) have adequate powers and tools to investigate, locate and impose interim measures in respect of Vas; (c) the types of VA platforms used for financial support of criminal activity; (d) examples of cases investigated by the relevant authorities with description of criminal schemes involving the virtual asset elements that have been identified; and (e) other data relevant to the goals of the study.

B. Main Provisions:

In view of the above, the Report has been structured into the following four (4) sections:

1. Horizontal review of compliance with FATF Recommendation 15:

FATF has published documents that are aimed at helping jurisdictions and the private sector to comply with the new AML/CFT requirements for VAs and VASPs (available here and here). Due to the peculiarities of the sector and the relatively recent adoption of the standard, the vast majority of MONEYVAL members have not yet fully implemented these requirements (i.e. of the 23 jurisdictions that have been assessed since June 2021 for their compliance with Recommendation 15, the majority require major or moderate improvements). In particular, further improvements are needed in assessing ML/TF risks, supervision, and the application of AML/CFT preventative measures.

2. Assessment of VA and VASP risks:

As already mentioned above, not all members have assessed the ML/TF risks posed by VAs and VASPs, or if such risk assessment has been conducted in many cases it lacks depth. In the case of Andorra that carried out its second national risk assessment back in 2020, it is noted that the risk assessment at the national level would start with an inventory (i.e. when VASPs must be licensed or registered, leaving the authorities with the tasks of estimating if and to which extent unregistered entities are still servicing clients in the respective jurisdiction) of the registered entities in the jurisdiction and determining the materiality of the VASP sector. However, in practice, jurisdictions experience challenges in identifying unregistered or unlicensed VASP activity in their jurisdiction.

In view of the above and following the first inventory of VASPs, a more in-depth analysis of the sector was undertaken. There is a risk that if the work conducted by Andorra indicates that there are no businesses operating domestically that should be registered, then VAs and VASPs become less of a focus. An assessment must be made about the use of VAs in the country even if there are no registered VASPs (for instance, whether customers in the domestic jurisdiction are obtaining services in another jurisdiction).

3. Risk-Based Approach Supervision of the VASP Sector:

The relevant section of the Report outlines the different approaches taken by members to license or register domestic VASPs and to implement a risk-based supervisory framework for the VASP sector. In brief, the following are noted:

VAs is defined as a digital representation of value that can be digitally traded or transferred and can be used for payment or investment purposes and do not include digital representations of FIAT currencies, securities, and other financial assets that are already covered elsewhere in the FATF Recommendations.
VASP is any natural or legal person that provides as a business activity one or more of the following activities or operations for or on behalf of another natural or legal person: (i) exchange between virtual assets and FIAT currencies; (ii) exchange between one or more forms of virtual assets; (iii) transfer of virtual assets; (iv) safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets; and (v) participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset.
The analysis shows that not all members included natural persons in the definition of VASPs.
A risk-mitigating measure for VASP activity is the application of market entry controls and of adequate risk-based supervision for AML/CFT purposes in the sector.
Recommendation 15 allows countries to choose between licensing or registration of VASPs, providing that at a minimum, VASPs would be required to be licensed or registered in the jurisdiction(s) where they were created.
MONEYVAL members have implemented different approaches to supervision (i.e. licensing or registration authority is not always the same authority that conducts the AML/CFT supervision of VASPs).
In supervising the VASP sector most of the MONEYVAL members are at the beginning of implementation. Not all supervisors are comprehensively resourced in terms of staffing and knowledge, and the risk-based approach is rarely tailored to a sector-specific risk assessment.
The volume and flow of cross-border transactions is one important element that supervisors should consider when determining the risk of the VASP sector and conducting supervision activities.
The availability of sanctions for VASP supervisors in MONEYVAL members differs in the scope and mounts of the sanctions that can be applied.

4. Law Enforcement and Operational Issues:

The capabilities and approaches of authorities in MONEYVAL countries to investigate ML/TF cases involving the use of VAs and to impose interim measures are examined in the relevant section of the Report. In particular, a number of case studies from the MONEYVAL region shed light on the use of VAs for money laundering purposes, such as the types of understanding crimes that are normally associated with such ML cases, as well as the modus operandi and typologies as to how such money laundering cases are perpetrated, are outlined within the Report. VAs are being used and can probably be used interchangeably with FIAT currencies when looking at typologies, as per the following investigated cases:

Theft of VAs through “typosquatting” – Isle of Man (in cooperation with UK and Netherlands);
Sale of fake VAs – Azerbaijan;
Use of money mules – Latvia;
Drug and arms dealing – Slovak Republic; and
Laundering of drug trafficking proceeds – Malta.

C. Next Steps:

CySEC considers the Report to be of assistance to the Regulated Entities engaging or seeking to engage in VA activities, in understanding their AML/CFT risks and obligations and how they can effectively comply with these obligations.

To this end, it is expected by CySEC that all Regulated Entities will study the Report and take its content into account when assessing AML/CFT risks, thereby improving the effectiveness of the measures and procedures applied.

Should you have any further questions, please do not hesitate to contact us at info@apapageorgiou.com.

Disclaimer: The information contained in this article is provided for informational purposes only, and should not be construed as financial or investment or legal advice on any matter. Andria Papageorgiou Law Firm is not responsible for any actions (or lack thereof) taken as a result of relying on or in any way using information contained in this article and in no event shall be liable for any damages resulting from reliance on or use of this information.

AML, Announcement, COMPLIANCE, CYSEC, News, REGULATORYAugust 4, 20230 comments

by Andria Papageorgiou

Navigating the Legal Landscape of Acquiring a Licensed Entity: A Comprehensive Guide

A. Introduction:

Acquiring a licensed entity is a complex and highly regulated process that requires careful navigation of legal intricacies. Such acquisitions involve not only the transfer of ownership but also compliance with specific licensing requirements and regulatory approvals. In this article, we will outline the essential steps involved in acquiring a licensed entity, ensuring a seamless and legally sound transaction.

B. The Process:

Step 1: Letter of Intent (LOI)

The acquisition process often begins with the potential buyer submitting a non-binding Letter of Intent to the target company. The LOI outlines the buyer’s preliminary offer and key terms of the proposed acquisition, such as purchase price, conditions, and timeline.

Step 2: Due Diligence (DD)

After accepting the LOI, the target company allows the buyer access to its financial, legal, operational, and other relevant information. This phase is called due diligence, during which the buyer investigates the target’s assets, liabilities, contracts, intellectual property, and other crucial aspects to assess the risks and opportunities of the acquisition. Engaging legal counsel and financial advisors during this phase is highly recommended to identify potential risks and evaluate the entity’s overall health.

Step 3: Negotiating the Purchase Agreement

Following successful due diligence, the parties proceed to negotiate a Definitive Agreement, often in the form of a Share Purchase Agreement (SPA). The Purchase Agreement is the cornerstone of any acquisition. This legally binding contract delineates the specific terms and conditions governing the transaction. It covers aspects such as the purchase price, payment terms, representations and warranties, indemnification provisions, and conditions precedent to closing. Both parties negotiate and finalize this agreement, often with the assistance of their respective legal counsel.

Step 4: Escrow Agreement

To add an extra layer of security, an Escrow Agreement may be established. In this agreement, a neutral third party (the escrow agent) holds the purchase price or a portion of it until all the closing conditions are met, ensuring that both parties fulfill their obligations before finalizing the transaction.

Step 5: Deposit or Earnest Money:

Upon reaching an agreement on the key terms in the SPA, the buyer typically pays a deposit or earnest money to the seller to demonstrate their seriousness about the acquisition and secure the deal. The deposit is usually held in escrow until the transaction is completed.

Step 6: Regulatory Compliance

The SPA includes conditions that must be met before the transaction can be completed. These closing conditions may involve obtaining necessary regulatory approvals, third-party consents, or fulfilling other specific requirements. For acquisitions involving licensed entities, regulatory compliance is of paramount importance. Depending on the industry and jurisdiction, the buyer may need to obtain approvals from relevant regulatory bodies. This process may include submitting applications/notifications, providing supporting documents, and demonstrating compliance with applicable laws and regulations.

Step 7: Transfer of Licenses and Permits

Acquiring a licensed entity entails the transfer of relevant licenses and permits from the seller to the buyer. This process may vary significantly based on the industry and location. Generally, the buyer needs to apply for the transfer of licenses, demonstrating that they meet all necessary qualifications and comply with regulatory requirements.

Step 8: Employee Considerations

The acquisition may impact the employees of the target entity. Ensuring a smooth transition involves understanding labor laws, employee contracts, severance arrangements, and potential union issues. Compliance with labor regulations is crucial to avoid any legal liabilities arising from the acquisition.

Step 9: Closing the Transaction

With all regulatory approvals secured, licenses transferred, and other contractual obligations met, the parties proceed to the closing of the transaction. At this stage, the purchase price is paid, and the legal ownership of the licensed entity is transferred from the seller to the buyer.

C. Conclusion:

Acquiring a licensed entity involves navigating a complex legal procedure to ensure compliance and mitigate risks. By conducting thorough due diligence, negotiating a comprehensive Purchase Agreement, and obtaining the necessary regulatory approvals, potential buyers can increase the chances of a successful and legally sound acquisition. Engaging experienced legal counsel throughout the process is crucial for a seamless acquisition experience and to protect the interests of all parties involved.

Should you have any further questions, please do not hesitate to contact us at info@apapageorgiou.com.

Acquisitions, COMPLIANCE, Corporate, News, REGULATORYJuly 25, 20230 comments

by Andria Papageorgiou

Updates surrounding Markets in Crypto-Assets Regulation (MiCA)

Following the recent approval of the Markets in Crypto Assets Regulation (the “MiCA”) in June 2023 and the corresponding implementing measures that needs to be prepared, we would like to draw your attention on the following news and press releases published by the European Banking Authority (the “EBA”) and the European Securities and Markets Authority (the “ESMA”) on the 12^th of July 2023:

A. EBA’s publications:

Consultation Paper on Complaints handling procedures for issuers of asset-referenced tokens (EBA/CP/2023/13);
Consultation Paper on information for the assessment of a proposed acquisition of qualifying holdings in issuers of asset-referenced tokens under MiCA (EBA/CP/2023/14);
Consultation Paper on EU market access of issuers of asset-referenced tokens (EBA/CP/2023/15); and
Statement on timely preparatory steps towards the application of MiCA to asset-referenced and e-money tokens.

B. ESMA’s Consultation Paper:

Consultation Paper on Technical Standards specifying certain requirements of MiCA (ESMA74-449133380-425)

In brief, allow us to summarise the following:

A. EBA’s News and Press:

1. Consultation Paper on Complaints handling procedures for issuers of asset-referenced tokens (EBA/CP/2023/13):

Scope: To ensure prompt, fair and consistent handling of complaints by holders of asset-referenced tokens (the “ARTs”) and other interested parties.
Main Provisions: It sets out definitions of complaints and complainants, requirements related to the complaints management policy and function, provision of information to holders of ARTs and on templates and recording. They then proceed with requirements about the procedure to investigate complaints and to communicate the outcome of the investigations to complainants and specific provisions for complaints handling involving third-party entities.
Next Steps: Comments to the Consultation Paper EBA/CP/2023/13 can be sent by clicking on the “send your comments” button on the EBA’s consultation page. The deadline for the submission of comments is on the 12^th of October 2023.

2. Consultation Paper on information for the assessment of a proposed acquisition of qualifying holdings in issuers of asset-referenced tokens under MiCA (EBA/CP/2023/14):

Scope: To regulate access to the EU market of ARTs by applicant issuers and persons intending to exercise significant influence on these undertakings via the acquisition of qualifying holdings.

Main Provisions:

- Under MiCAR, the offer to the public or the admission to the trading of an ART is reserved for legal persons or other undertakings established in the EU subject to the authorisation and approval of the publication of a white paper. The draft RTS on information for authorisation lay down the information requirements to be included when applying for such an authorisation. The information requirements cover the business model, and internal governance, including ICT risk management, liquidity, the reserve of assets, sufficiently good repute of the members of the management body, and of shareholders with qualifying holdings.
- The draft ITS set out the standard application letter, and the application template and clarify the process relating to the assessment of completeness of the application by the competent authority. As credit institutions are only required to receive approval to publish a white paper, the draft RTS and ITS do not apply to credit institutions.
- Consistent with the general regime applicable in the financial sector, MiCAR envisages a prudential assessment by competent authorities for the acquisition of qualifying holdings in issuers of ARTs that are not credit institutions. The draft RTS on the detailed content of the information to be included in the notification for the proposed acquisition clarifies the information requirements that are necessary for such an assessment.
- This information covers five criteria relating to (a) the reputation of the proposed acquirer, (b) the suitability of any person who will direct the target undertaking, (c) the financial soundness of the proposed acquirer, (d) the sound and prudent management of the target undertaking following the acquisition and (e) suspicion that money laundering or terrorist financing is committed or attempted or that it may increase following the acquisition.

Next Steps: Comments to the consultation paper can be sent by clicking on the “send your comments” button on the EBA’s consultation page. The deadline for the submission of comments is 12 October 2023.

3. Statement on timely preparatory steps towards the application of MICA to ART and e-money tokens (the “EMT”):

Scope: To encourage timely preparatory actions to MiCA application, with the objectives to reduce the risks of potentially disruptive and sharp business model adjustments at a later stage, to foster supervisory convergence, and to facilitate the protection of consumers.
Content:
- The Statement includes ‘guiding principles’ to which financial institutions (and other undertakings) carrying out ART/EMT activities are encouraged to have regard until the application date (disclosures to, and fair treatment of, potential acquirers and holders of ARTs and EMTs, the business model, sound governance, including effective risk management, reserve, recovery and redemption arrangements, and communications with the relevant competent authority).
- The Statement is accompanied by a template that financial institutions (and other undertakings) intending to carry out, or carrying out, ART/EMT activities, are encouraged to communicate, on a timely basis, to the relevant competent authority.

B. ESMA’s Consultation Papers:

Same-day press release publication by ESMA, in relation to the lunch of the first of three consultation packages (the “ESMA’s Consultation Paper”), on the technical standards specifying certain requirements.

Scope: Through the aforesaid consultation paper, ESMA is seeking input on proposed rules for CASPs related with their authorization, identification and management of conflicts of interest as well as the procedures on how CASPs should address complaints. The ESMA’s Consultation Paper‘s aim is to collect views, comments and opinions from stakeholders and market participants in regard to the appropriate implementation of MiCA.

Main Provisions:

- Provision of crypto-asset services by certain financial entities – Article 60

Specifies the notification requirements, that certain financial entities intended to provide crypto-asset service and for which they shall take into account when submitting the notification to the NCA of their home Member State (e.g. program of operations, description of the internal control mechanisms relating to AML/CFT obligations, description of the procedure for the segregation of clients’ crypto-assets and funds, etc.)

- Content of templates for the application for authorisation – Article 62

Sets out the requirements related to the application for the authorisation as a CASP as well as the information to be provided with the application that shall be submitted to the NCA of their home Member State. (i.e. program of operations, description of CASP’s governance arrangements, description of the procedure for the segregation of clients’ crypto-assets and funds, etc.).

- Complaints-handling procedures of CASPs – Article 71

Provides the requirements that CASPs shall follow when establishing and maintaining effective and transparent procedures for the prompt, fair, and consistent handling of complaints received from clients (i.e. filing a free-of-charge complaint by the client).

- Identification, prevention, management, and disclosure of conflicts of interest by CASPs – Article 72

Clarifies the policies and procedures that CASPs shall implement and maintain so as to be able to identify, prevent, manage and disclose any conflict of interest and disclose to their clients the general nature and sources of conflicts of interest as well as the steps that shall be taken to mitigate them.

- Assessment of intended acquisition of a qualifying holding in a CASP under Article 83(4)

Natural/Legal person who intends to acquire or increase a qualifying holding in a CASP shall notify the respective NCA through an assessment with the specific information in order for the relevant NCA to assess the proposed acquisition or increase the existing qualifying holding.

Next Steps: Comments to the ESMA’s Consultation Paper can be sent by clicking the heading ‘Your input – Consultations’. The deadline of the submission of the responses/comments is on the 20^th of September 2023.

Should you have any further questions, please do not hesitate to contact us at info@apapageorgiou.com.

Announcement, COMPLIANCE, News, REGULATORYJuly 19, 20230 comments

by Andria Papageorgiou

Strengthening Compliance: Safeguarding against Money Laundering Risks

A. Introduction:

In an increasingly interconnected and digital world, the fight against financial crimes, including money laundering, has taken center stage. As illicit activities continue to evolve and become more sophisticated, it is crucial for businesses to prioritize Anti-Money Laundering (AML) compliance. This article sheds light on the importance of AML measures, the risks associated with non-compliance, and how our law firm is dedicated to upholding AML standards while offering consulting services to organizations seeking to strengthen their AML frameworks.

B. The Significance of AML Compliance:

Anti-Money Laundering compliance refers to the comprehensive set of regulations, policies, and procedures designed to prevent the facilitation of money laundering and terrorist financing activities. Money laundering not only undermines the integrity of the global financial system but also aids criminal enterprises in disguising their illicit gains as legitimate funds. By complying with AML regulations, businesses not only protect their reputation but also contribute to maintaining the integrity of the financial system.

C. Risks of Non-Compliance:

The consequences of non-compliance with AML regulations are severe, ranging from reputational damage to financial penalties and legal consequences. Financial institutions and businesses failing to implement adequate AML controls can face substantial fines, regulatory sanctions, and potential loss of licenses (if applicable). Additionally, non-compliance may lead to damaged customer trust and adverse publicity, which can have long-lasting impacts on an organization’s bottom line.

D. Our Commitment to AML Compliance:

At Andria Papageorgiou Law Firm, we recognize the critical importance of AML compliance and the challenges businesses face in meeting regulatory obligations. With a team of experienced legal professionals specializing in AML, we are dedicated to assisting organizations in navigating the complex AML landscape, tailoring our services to their unique needs.

Our law firm offers comprehensive AML consulting services, helping clients establish robust AML frameworks and compliance programs. We collaborate closely with businesses across various sectors, providing guidance on risk assessment, policies and procedures development, staff training, and ongoing monitoring. By leveraging our expertise, organizations can ensure compliance with AML regulations, minimize risks, and safeguard their operations and reputation.

Recognizing that each business has unique AML requirements, our consulting services are tailored to meet specific needs. We work closely with clients to understand their operations, risk profile, and regulatory environment. We then develop customized solutions that address their specific challenges, ensuring an effective and efficient AML compliance program.

We understand that AML regulations are constantly evolving to keep pace with emerging risks. We remain up-to-date with the latest regulatory developments and industry best practices, ensuring our clients stay ahead of the curve. We proactively monitor changes in AML laws, guidelines, and enforcement actions, incorporating relevant updates into our consulting services to help clients maintain their AML compliance posture.

Further to all the above, we are also proud to announce that our esteemed Founder and Lawyer, Mrs. Andria Papageorgiou, has achieved an exceptional milestone in her professional career. Mrs. Papageorgiou has recently completed the prestigious International Compliance Association (ICA) Certification in Anti-Money Laundering (AML) for Institute of Certified Public Accountants of Cyprus and Cyprus Bar Association (CBA) Members, successfully passing the exam with Distinction. This accomplishment highlights her expertise and dedication to upholding the highest standards in AML compliance. The ICA Certification in AML is an internationally recognized qualification offered by the International Compliance Association (ICA). This certification equips professionals with the in-depth knowledge and skills necessary to combat the ever-evolving challenges posed by money laundering and terrorist financing activities.

E. Conclusion:

The fight against money laundering requires a proactive and comprehensive approach to ensure the integrity of the global financial system. By prioritizing AML compliance, businesses can mitigate risks, Andria Papageorgiou Law Firm, we are committed to helping organizations navigate the complex world of AML regulations through our tailored consulting services.

Should you have any further questions, please do not hesitate to contact us at info@apapageorgiou.com.

AML, COMPLIANCE, Finance, News, REGULATORYJuly 3, 20230 comments

by Andria Papageorgiou

ESAs public consultation on DORA

We would like to draw your attention that the European Supervisory Authorities (EBA, EIOPA, and ESMA – the ESAs) launched yesterday, 19^th of June 2023, a public consultation on the first batch of policy products under the DORA.

This includes four draft regulatory technical standards (RTS) and one set of draft implementing technical standards (ITS). These technical standards aim to ensure a consistent and harmonized legal framework in the areas of ICT risk management, major ICT-related incident reporting, and ICT third-party risk management.

DORA entered into force on the 16^th of January 2023 and will apply from the 17^th of January 2025 aiming to enhance the digital operational resilience of entities across the EU sector and to further harmonize key digital operational resilience requirements for all EU financial entities.

This regulatory framework covers key areas such as:

ICT risk management,
ICT-related incident management and reporting,
digital operational resilience testing and
management of ICT third-party risk.

DORA has mandated the ESAs to jointly develop altogether 13 policy instruments in two batches. The first batch of technical standards, are the following:

RTS on ICT risk management framework and RTS on simplified ICT risk management framework;
RTS on criteria for the classification of ICT-related incidents;
ITS to establish the templates for the register of information;
RTS to specify the policy on ICT services performed by ICT third-party providers.

The ESAs expect to submit these draft technical standards to the European Commission by 17 January 2024.

Comments to this consultation can be sent to the ESAS by the 11^th of September 2023.

Should you have any further questions, please do not hesitate to contact us at info@apapageorgiou.com.

COMPLIANCE, CYSEC, News, REGULATORYJune 20, 20230 comments

by Andria Papageorgiou

CySEC Circular C576 – Adoption of the European Banking Authority Guidelines

We would like to draw your attention to Circular C576 (the “Circular”) issued by the Cyprus Securities and Exchange Commission (the “CySEC”) on the 2^nd of June 2023, for the purposes of informing the Cyprus Investment Firms (the “CIFs”) about its decision to adopt the following European Banking Authority’s (the “EBA”) guidelines, that have been previously published within 2022, by incorporating them into its supervisory practices and regulatory approach:

(a) Guidelines on the benchmarking exercises on remuneration practices and the gender pay gap under the Directive (EU) 2019/2034 (the “Guidelines on benchmarking”). Our previous notification email is attached herein; and
(b) Guidelines on data collection exercises regarding high earners under Directive 2013/36/EU and under Directive (EU) 2019/2024 (the “Guidelines on high earners”). Our previous notification email is attached herein.

In brief, kindly note the below:

1. Guidelines on benchmarking:

The relevant guidelines specify how competent authorities shall collect from investment firms the remuneration and the gender pay gap data and how they will then submit them to EBA. It is noted that the said data shall be collected and submitted at the individual level whereas where Article 7 of IFR applies, this data shall be collected and submitted only at the level of consolidation set out therein. Please note that the Guidelines on benchmarking should be read in conjunction with the EBA Guidelines on sound remuneration policies under IFD.

In view of the above and pursuant to Section 28(1) of the Prudential Supervision of Investment Services Law of 2021 (the “Prudential Supervision Law”), CySEC shall collect the information disclosed in accordance with Article 51(1)(c) and (d) of IFR as well as the information provided by CIFs on the gender pay gap and use that information to benchmark remuneration trends and practices. Pursuant to Section 28(4) of the Prudential Supervision Law, CySEC shall provide the collected information to EBA in order to benchmark remuneration trends and practices at the Union level.

Therefore, the following actions should be taken by CIFs in regard to the topics presented below:

Related Topic	Information to be submitted	Deadline
Remuneration Data	o Information on the remuneration of all staff, as set out in Annex I of Guidelines on benchmarking	15^th of June of each calendar year*
	o Additional information on remuneration for identified staff, as set out in Annex II and Annex III of Guidelines on benchmarking
	o Information on derogation as specified in Annex IV of Guidelines on benchmarking
Gender Pay Gap	o Information set out in Annex V of Guidelines on benchmarking regarding the financial year 2023	*15^th of June every three years, starting from 2024*

*It is clarified that the remuneration data outlined above should be submitted by the 31^st of August 2023 the latest, regarding the financial year 2022.

2. Guidelines on high earners:

The objective of the data collected on high earners is to analyse and publish year-to-year developments in the number of individuals in institutions and investment firms earning at least EUR 1 million within the European Union (the “EU”) and the European Economic Area (the “EEA”), and within the different Member States, and to assess the major components of remuneration awarded to high earners in different business areas. The said information can be used together with other remuneration benchmarking data to analyse the application of remuneration policies within the EU and EEA and the trends in remuneration practices so as to improve the relevant legal framework.

In view of the above, CIFs should submit to CySEC data regarding high earners (i.e. staff member(s) earning a remuneration of at least EUR 1 million in the reported financial year) so as for the latter to submit such information to EBA.

Please note that high earners data should be reported, as applicable, at the level of consolidation set out in Article 7 of IFR and should concern all the high earners’ data for all entities and branches within the highest level of prudential consolidation. In the case of standalone investment firms, high earner’s data should be reported on an individual basis. The data submitted should also include data relevant to EU/EEA branches.

In this respect, please note the following:

Where CIFs do not have high earners to report, it is not necessary to submit this information, unless explicitly requested by the CySEC.
High earners data should be submitted to CySEC each year for any given financial year by the 15^th of June of the next calendar year.
It is clarified that high earners’ data should be submitted by the 31^st of August 2023 the latest, regarding the financial year 2022.

3. Method of submission:

The information outlined in points 1 and 2 above should be submitted through CySEC’s XBRL Portal only, which is expected to be updated by the 30^th of June 2023.

CIFs are urged to consider the Guidelines on benchmarking & Guidelines on high earners and where necessary, take actions to ensure compliance with their provisions.

Should you have any further questions, please do not hesitate to contact us at info@apapageorgiou.com.

COMPLIANCE, CYSEC, News, REGULATORYJune 7, 20230 comments

by Andria Papageorgiou

Regulation on Markets in Crypto-assets: Navigating the Evolving Landscape

A. Introduction:

In recent years, the rapid growth of cryptocurrencies and the emergence of blockchain technology have led to a significant expansion of the crypto-assets market. This growth, while exciting, has also raised concerns regarding investor protection, market integrity, and financial stability. As a result, regulatory authorities around the world have been striving to develop comprehensive frameworks to regulate markets in crypto-assets. This article aims to explore the evolving regulatory landscape and its implications for market participants.

B. The Global Context:

Crypto assets, including cryptocurrencies and tokenized assets, operate in a borderless digital environment, posing challenges for traditional regulatory frameworks. Recognizing the need for regulatory clarity, several jurisdictions have taken proactive steps to establish frameworks that balance innovation with investor protection.

One notable initiative is the European Union’s proposed Regulation on Markets in Crypto-assets (MiCA). MiCA aims to create a harmonized regulatory framework for crypto-assets and related service providers within the EU. The regulation seeks to enhance transparency, protect consumers, and foster market integrity while promoting innovation.

C. Key Provisions of MiCA:

Classification and Authorization: MiCA introduces a comprehensive classification system for crypto-assets, distinguishing between e-money tokens, asset-referenced tokens, and significant or non-significant tokens. It also establishes a licensing regime for crypto-asset service providers, ensuring they meet strict operational and governance standards.
Market Conduct and Investor Protection: MiCA sets out rules on the marketing, sale, and provision of crypto-assets and related services. It aims to enhance investor protection by requiring clear and accurate disclosure of risks, imposing conduct of business obligations on service providers, and establishing safeguards against market abuse and fraud.
Operational Requirements: The regulation imposes operational requirements on crypto-asset service providers, including capital requirements, custody rules, and risk management obligations. These provisions aim to ensure the security and resilience of market infrastructure and protect customer assets.
Cross-Border Passporting: MiCA introduces a mechanism for cross-border passporting, allowing authorized service providers to operate across EU member states without the need for additional authorizations. This harmonization is expected to foster competition, facilitate market access, and streamline regulatory compliance.

D. Challenges and Opportunities:

Implementing regulations on markets in crypto-assets is a complex task, requiring a balance between regulatory oversight and fostering innovation. Challenges include addressing the inherent volatility of crypto-assets, the risk of money laundering and terrorism financing, and the need for international cooperation.

However, clear and consistent regulatory frameworks can also bring opportunities. Regulatory certainty can attract institutional investors, encourage responsible innovation, and provide a level playing field for market participants. It may also help mitigate systemic risks associated with the growing interconnections between traditional financial systems and crypto-assets.

E. Conclusion:

The regulation of markets in crypto-assets is an ongoing and dynamic process, driven by the need to protect investors, maintain market integrity, and foster innovation. Initiatives like MiCA demonstrate a commitment to providing legal clarity and regulatory oversight within the European Union. As the global regulatory landscape continues to evolve, it is essential for market participants to stay informed, adapt to changing requirements, and engage in constructive dialogue with regulators to shape the future of this exciting and transformative market.

Should you have any further questions, please do not hesitate to contact us at info@apapageorgiou.com.

Disclaimer: The information contained in this article is provided for informational purposes only, and should not be construed as financial or investment or legal advice on any matter. It is important to conduct thorough research and consult with financial professionals before making any investment decisions related to cryptocurrencies or digital banking. Andria Papageorgiou Law Firm is not responsible for any actions (or lack thereof) taken as a result of relying on or in any way using information contained in this article and in no event shall be liable for any damages resulting from reliance on or use of this information.

COMPLIANCE, News, REGULATORYMay 30, 20230 comments

by Andria Papageorgiou

Cryptocurrencies: Evaluating Risks and Assessing Their Future in Digital Banking

A. Introduction:

The emergence of cryptocurrencies has disrupted traditional financial systems, offering decentralized and secure alternatives to conventional banking. However, as with any financial innovation, cryptocurrencies come with inherent risks. In this article, we will delve into the risks associated with cryptocurrencies and explore their potential future in the realm of digital banking.

B. Cryptocurrency Risks:

Price Volatility: One of the primary risks associated with cryptocurrencies is their extreme price volatility. The value of cryptocurrencies can experience significant fluctuations within short periods. Investors must be prepared for the possibility of substantial gains or losses in their cryptocurrency holdings.
Regulatory Uncertainty: Cryptocurrencies operate in a regulatory landscape that is still evolving. The lack of standardized regulations across jurisdictions introduces uncertainties regarding their legal status, taxation, and consumer protection. Regulatory changes can impact the viability, adoption, and usage of cryptocurrencies, leading to potential risks for investors and digital banking institutions.
Cybersecurity Vulnerabilities: Cryptocurrencies face cybersecurity threats due to their digital nature. Hacking attempts, phishing attacks, and theft pose significant risks to individuals and digital banking platforms that deal with cryptocurrencies. Robust security measures, such as secure wallets and strong authentication protocols, are essential to safeguard against these risks.
Market Liquidity: Cryptocurrency markets may experience liquidity challenges, particularly for less-established or low-volume cryptocurrencies. Limited liquidity can impact the ability to buy or sell cryptocurrencies at desired prices, leading to potential trading difficulties and increased transaction costs.
Technological Risks: Cryptocurrencies rely on underlying technologies, such as blockchain, which are still evolving. Technical vulnerabilities, software bugs, and network disruptions can pose risks to the stability and reliability of cryptocurrencies. Ongoing technological advancements and upgrades are necessary to mitigate such risks.

C. The Future of Cryptocurrencies in Digital Banking:

Despite the risks, cryptocurrencies have the potential to shape the future of digital banking in several ways:

Increased Financial Inclusion: Cryptocurrencies can provide access to financial services for the unbanked and underbanked populations, enabling secure and efficient cross-border transactions without the need for traditional banking intermediaries.
Streamlined Cross-Border Payments: Cryptocurrencies can facilitate faster and cheaper cross-border transactions, eliminating intermediaries and reducing transaction fees. Digital banking institutions can leverage cryptocurrencies to offer efficient global payment solutions to their customers.
Decentralized Finance (DeFi): Cryptocurrencies underpin the growth of decentralized finance, enabling various financial services, including lending, borrowing, and yield farming, without traditional intermediaries. DeFi platforms can integrate cryptocurrencies to provide innovative financial products to users.
Central Bank Digital Currencies (CBDCs): Several central banks worldwide are exploring the development of CBDCs, which are digital currencies issued and regulated by central authorities. CBDCs can potentially enhance the efficiency and transparency of digital banking systems, bridging the gap between traditional currencies and cryptocurrencies.

D. Conclusion:

Cryptocurrencies have emerged as a disruptive force in the financial industry, offering unique advantages and challenges. Understanding the risks associated with cryptocurrencies is crucial for individuals and digital banking institutions venturing into this domain. While risks such as price volatility and regulatory uncertainties persist, cryptocurrencies hold the potential to transform digital banking by enabling financial inclusion, streamlining cross-border payments, fostering decentralized finance, and paving the way for central bank digital currencies.

As the digital banking landscape continues to evolve, carefully navigating the risks and leveraging the opportunities presented by cryptocurrencies will be pivotal for the future of the industry.

Should you have any further questions, please do not hesitate to contact us at info@apapageorgiou.com.

Disclaimer: The information contained in this article is provided for informational purposes only, and should not be construed as financial or investment or legal advice on any matter. It is important to conduct thorough research and consult with financial professionals before making any investment decisions related to cryptocurrencies or digital banking. Andria Papageorgiou Law Firm is not responsible for any actions (or lack thereof) taken as a result of relying on or in any way using information contained in this article and in no event shall be liable for any damages resulting from reliance on or use of this information.

COMPLIANCE, News, REGULATORYMay 19, 20230 comments

by Andria Papageorgiou

CySEC Circular C533 on the guidelines on certain aspects of the compliance function requirements

Cyprus Securities and Exchange Commission (the “CySEC”) issued the Circular C553 (the “Circular”) on the 14^th of March 2023, for the provision of guidance on the application of certain aspects of the compliance function requirements provided in Article 17(2) of the Investment Services and Activities and Regulated Markets Law (the “Law”) and Article 22 of the MiFID II Delegated Regulation 2017/565 (the “Delegated Regulation 565”).

It shall be noted, that Circulars C030 and C050 are repealed and replaced by this Circular, and that this Circular should be read with Circular C447 on the ESMA’s Guidelines (ESMA35-36-1952) on certain aspects of the MiFID II compliance function requirements (the “Compliance Function Guidelines”).

The Circular issued by CySEC provides a summary of the Compliance Function Guidelines, alongside with further guidance from the Commission (please refer to statements in italics) so as to ensure the common, uniform and consistent application of the relevant legal requirements, as these are outlined above. In brief, we would like to note the following:

A. Guidelines on the responsibilities of the Compliance Function:

Guideline 1 – Compliance risk assessment:

A risk assessment must be conducted by adopting a risk-based monitoring program to determine its priorities and the focus on monitoring, advisory, and assistance activities. In addition, based on the new provisions of the Guidelines, the following are expected:

The findings of the compliance risk assessment should be used to set the work programme of the Compliance Function and to allocate the function’s resources efficiently.
The compliance risk assessment should be reviewed on a regular basis, and, when necessary, updated to ensure that the objectives, focus and the scope of compliance monitoring and advisory activities remain valid.

Guideline 2 – Monitoring obligations of the Compliance Function:

The aim of the risk-based monitoring program should be to evaluate whether the firm’s business is conducted in compliance with its obligations under the Law and that the internal policies and procedures, organization, and control measures remain effective and appropriate to ensure that compliance risk is comprehensively monitored. The risk-based approach to compliance shall form the basis for determining the appropriate tools and methodologies used by the Compliance Function, as well as the extent of the monitoring program and the frequency of monitoring activities performed by the Compliance Function. Also, the monitoring program should reflect changes to the firm’s risk profile as well as, extend to the implementation and effectiveness of any remedial measures taken by the firm in response to breaches of the Law.

Guideline 3 – Reporting obligations of the Compliance Function:

The mandatory compliance reports should cover all business units involved in the provision of investment services, activities and ancillary services provided by a firm. The mandatory compliance reports is expected to include general information, manner of monitoring and reviewing, findings, actions taken and other information. The relevant report should also cover the firm’s product governance arrangement (e.g. role of Compliance Function, monitoring of the firm’s product governance by the Compliance Function, information about the financial instruments manufactured / distributed, including information on the distribution strategy). Additionally, the Compliance Function and the Complaints Management Function should be properly segregated, subject to the principle of proportionality.

Investment Firms should submit to CySEC the annual reports mentioned in Article 25 of the Delegated Regulation 565 within twenty (20) days from the date the reports are discussed by the Board of Directors and not later than four (4) months from the end of the calendar year. The Board of Directors should also provide CySEC with explanations of the Compliance Function’s findings (e.g. corrective measures in response to the identified deficiencies and timetable for their implementation). It is provided that the annual report is a standalone document and cannot be part of another report that the Investment Firm is obliged to prepare (e.g. anti-money laundering compliance function report).

Guidelines 4 – Advisory and assistance obligations of the Compliance Function:

In general, pursuant to the Guideline 4, it is expected that the Compliance Function to fulfil its advisory and assistance responsibility, including providing support for staff and management training, providing day-to-day assistance for staff and management and participating in the establishment of policies and procedures within the firm (e.g. the firm’s remuneration policy or the firm’s product governance policies and procedures).

B. Guidelines on the responsibilities of the Compliance Function:

Guideline 5 – Effectiveness of the Compliance Function:

The firm should ensure that the Compliance Function is allocated with the appropriate human and other resources by taking into account the scale and types of investment services, activities and ancillary services undertaken by the firm, as well as any changes to the firm’s compliance risk in case its business unit activities are significantly extended (e.g. establishment of branches, use of affiliates, cross border activities). The said guideline was further enhanced so as to be clearly indicated that it is of vital importance for the firms to have in place the necessary arrangements to ensure an effective exchange of information between the Compliance Function and other control functions (such as the internal audit and risk management) as well as with any internal and external auditors.

Guideline 6 – Skills, knowledge, expertise and authority of the Compliance Function:

Guideline 6 outlines the requirements related with the skills, knowledge, expertise and authority of the Compliance Function (e.g. sufficiently broad knowledge and experience, sufficiently high level of expertise etc.). The senior management should assess the prospective Compliance Officer’s qualifications prior appointment, ensures that he/she has integrity, morals and credibility, as well as that he/she is a holder of the CySEC’s Advanced Certificate and registered in the Public Register. CySEC also performs an assessment of the qualification of the nominated Compliance Officer during the authorisation process and/or in the context of ongoing supervision, which includes the analysis of his/hers curriculum vitae, as well as an interview.

Guideline 7 – Permanence of the Compliance Function:

The firm should establish adequate arrangements for ensuring that the Compliance Function performs its tasks and responsibilities on a permanent basis and are fulfilled when the Compliance Officer is absent. The responsibilities, competences and the authority of the Compliance Function should be set out in a “compliance policy” or other general policies or internal rules that consider the scope and nature of the firm’s services and activities, which should include information on the monitoring programme, the reporting duties of the Compliance Function and its risk-based approach to monitoring activities.

Guideline 8 – Independence of the Compliance Function:

Guideline 8 highlights that the Compliance Function holds a position in the firm’s organisational structure that ensures that the Compliance Officer and other compliance staff act independently when performing their tasks. The tasks performed by the Compliance Function should be carried out independently from the senior management and other units of the firm. Where the senior management deviates from important recommendations or assessments issued by the Compliance Function, the Compliance Officer should document this accordingly and present it in the compliance reports, and if deemed necessary, inform CySEC the soonest possible.

Guideline 9 – Proportionality with regard to the effectiveness of the Compliance Function:

The firm should decide which measures, including organisational measures and the level of resources, are best suited for ensuring the effectiveness of the Compliance Function in the firm’s particular circumstances. The firm may fall under the proportionality exemption if the performance of the necessary compliance task does not require a full-time position due to the nature, scale and complexity of the firm’s business, and the nature and rage of the investment/ancillary services and activities, but should ensure that any conflicts of interests are minimised. Where a firm makes use of the proportionality exemption, it should record how this is justified, so that the CySEC is able to assess this.

The Compliance Function should also ensure that all employees that fall under the Directive regarding the Certification of Persons and the Certification Registers of 2019 to 2021 hold the relevant certificate and are registered in the public register, as well as that the content of the CIF Electronic Record is complete and accurate and where amendments are required, that these are done immediately.

Guideline 10 – Combining the Compliance Function with other internal control functions:

Generally, firms should ensure that the control functions are properly segregated (e.g. the compliance staff shall not be involved in the activities they monitor). Nevertheless, a combination of the Compliance Function with other control units at the same level (such as money laundering prevention) may be acceptable if this does not generate conflicts of interests or compromise its effectiveness. Any such combination should be documented, including the rationale behind it, so that CySEC is able to assess whether such a combination is appropriate. Based on the provisions of the Guideline 10, the following should be noted:

Where an internal audit function has been established and is maintained, such function may not be combined with other control functions such as the Compliance Function;
Where the Compliance Officer is not appointed as the Single Officer (referred to in Article 9 of the Directive DI87-01), both the Single Officer and the Compliance Officer should act independently and the Compliance Officer should not supervise and/or issue any instruction to the Single Officer; and
Where the Compliance Function is combined with other control functions or where it is also responsible for other tasks (for example anti-money laundering), the firm should ensure that it allocates enough resources for MiFID II compliance at all times.

Guideline 11 – Outsourcing of the Compliance Function:

In accordance with Guideline 11, which outlines the requirements related with the outsourcing of tasks undertaken by the Compliance Officer and not the outsourcing of the relevant responsibilities, the following shall be noted:

In all cases, outsourcing the Compliance Function should not undermine its quality and independence, create undue additional operational risks, impair the activities of internal controls or impair the ability of the firm and the relevant competent authority to supervise compliance with the applicable requirements;
The outsourcing to non-EU entities may potentially make oversight and supervision of the Compliance Function more difficult and should therefore be subject to a closer monitoring; and
Upon the termination of the outsourcing arrangement related with the Compliance Function, firms should ensure the continuity by transferring the Compliance Function back to the firm or outsourcing it to another provider.

C. Guidelines on the competent authority review of the Compliance Function:

Guideline 12 – Review of the Compliance Function by the competent authority:

Generally, the competent authorities should assess whether a firm’s Compliance Function is adequately resourced and organised and whether adequate reporting lines have been established. With respect to the CySEC’s expectations and clarifications provided:

It is required, as a condition for authorisation, that any necessary amendments to the Compliance Function are notified to CySEC.
Also, as part of the ongoing supervisory process, CySEC assesses whether the measures implemented by the firm for the Compliance Function are adequate, and whether it fulfils its responsibilities appropriately.
The Compliance Function must immediately disclose to CySEC every important development that may substantially affect its ability to effectively perform the Compliance Function and to fulfil its responsibilities appropriately.

Finally, without prejudice to the provisions of Guideline 6, a person may be nominated as Compliance Officer, even if not registered in the Public Register provided that, following an assessment of his/her qualifications, CySEC is satisfied that the person has the relevant knowledge and expertise and will succeed in the Advanced Examination and be registered in the Public Register within a determined time period decided by CySEC. The firm should notify CySEC of both the appointment and replacement of the Compliance Officer and the later may require a detailed statement on the grounds for the replacement.

In case you have any questions, please do not hesitate to contact us for further professional assistance.

Disclaimer: The information contained in this article is provided for informational purposes only, and should not be construed as legal advice on any matter. Andria Papageorgiou Law Firm is not responsible for any actions (or lack thereof) taken as a result of relying on or in any way using information contained in this article and in no event shall be liable for any damages resulting from reliance on or use of this information.

COMPLIANCE, CYSEC, REGULATORYMarch 16, 20230 comments

by Andria Papageorgiou

Financial Action Task Force Statement Publications – February 2023

Paris, 24 February 2023 – The second Plenary of the FATF under the Presidency of T. Raja Kumar of Singapore concluded on 24/2/2023. Delegates from over 200 jurisdictions of the Global Network participated in these discussions at the FATF headquarters in Paris.

Following the statements issued since March 2022, the FATF reiterates that all jurisdictions should be vigilant to current and emerging risks from the circumvention of measures taken against the Russian Federation in order to protect the international financial system. The outcomes of the FATF Plenary, 22-23 February 2023 relate among others to the following matters:

FATF Statement on High-Risk Jurisdictions subject to a Call for Action:

Following FAFT’s statement of October 2022 on the list of “High-Risk Jurisdictions subject to a Call for Action- October 2022”, the latter proceeded with the issuance of a Publication on the 24^th of February 2023, through which it urges all jurisdictions to apply enhanced due diligence, and, in the most serious cases, countries are called upon to apply counter-measures to protect the international financial systems from the money laundering, terrorist financing, and proliferation financing (the “ML/TF/PF”) risks emanating from the country. In particular, the FATF’s call for action on the following high-risk jurisdictions remains in effect:

A. Jurisdictions subject to a FATF call on its members and other jurisdictions to apply countermeasures.

- Democratic People’s Republic of Korea (DPRK)
- Iran

B. Jurisdiction subject to a FATF call on its members and other jurisdictions to apply enhanced due diligence measures proportionate to the risks arising from the jurisdiction.

- Myanmar

FATF Statement on Jurisdictions under Increased Monitoring:

On the 24^th of February 2023, the FAFT issued a Publication in relation to the results of the progress review to identify new countries with strategic AML/CFT deficiencies, despite the challenged posed by Covid-19, based on which:

A. Jurisdictions no longer subject to increased monitoring:

- Cambodia
- Morocco

B. Jurisdictions with strategic deficiencies:

- Albania
- Barbados
- Burkina Faso
- The Cayman Islands
- (*) Democratic Republic of the Congo
- Gibraltar
- Haiti
- Jamaica
- Jordan
- Mali
- (*) Mozambique
- Nigeria (new)
- Panama
- Philippines
- Senegal
- South Africa (new)
- South Sudan
- Syria
- (*) Tanzania
- Turkey
- Uganda
- United Arab Emirates
- Yemen

* Chose to defer reporting; thus, the relevant Statements available, issued in October 2022 may not necessarily reflect the most recent status of the jurisdictions’ AML/CFT regimes.

FATF Statement on the Russian Federation:

On the 24^th of February 2023, the FAFT issued a Statement in relation to its decision to suspend the membership of the Russian Federation, as the latter’s continuing and intensifying war of aggression against Ukraine runs counter to FATF’s core principles aiming to promote security, safety and the integrity of the global financial system. In particular, Russian Federation can no longer hold any leadership or advisory roles or take part in decision-making on standard-setting, FATF peer review processes, governance, and membership matters.

Other matters:

Mutual Evaluation Reports: FATF has adopted a mutual evaluation report of Indonesia and Qatar that will be published by May 2023 following the completion of its quality and consistency review.
Beneficial Ownership of Legal Persons: FATF Plenary has finalised a guidance document which will help countries implement the revised requirements of Recommendation 24 which requires countries to ensure that beneficial ownership information is held by a public authority or body functioning as a beneficial ownership registry or an alternative mechanism they will use to enable efficient access. The guidance will be published in March 2023.
Beneficial Ownership of Legal Arrangements: FATF Plenary also agreed on enhancements to Recommendation 25 on legal arrangements to bring its requirements broadly in line with those for Recommendation 24 on legal persons to ensure a balanced and coherent set of FATF standards on beneficial ownership.
Disrupting the financial flows from ransomware: FATF completed research that analyses the methods that criminals use to carry out their ransomware attacks and how they launder ransom payments. Relevant research will be published in March 2023 and will include a list of risk indicators that can help public and private sector entities identify suspicious activities related to ransomware.
Improving implementation of FATF requirements for virtual assets and virtual asset service providers: Plenary agreed on a roadmap to strengthen the implementation of FATF Standards on virtual assets and virtual asset service providers, which will include a stocktake of current levels of implementation across the global network. In the first half of 2024, the FATF will report on steps FATF members and FSRB countries with materially important virtual asset activity have taken to regulate and supervise virtual asset service providers.
Money Laundering and Terrorist Financing in the Art and Antiquities Markets: FATF has also finalised a report that explores the link between money laundering and art and antiquities which was published on the 27^th of February 2023.

In case you have any questions, please do not hesitate to contact us for further professional assistance.

AML, COMPLIANCE, CYSEC, News, REGULATORYMarch 7, 20230 comments

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