by Andria Papageorgiou

Announcement, NewsNovember 15, 20210 comments

Circular C475: Sanctions Imposed by the Office of Foreign Assets Control (“OFAC”) of the U.S. Treasury Department

With Circular C475 and on continuation to the Circulars C266 and C337, CySEC draws your attention to the continuously updated list of the latest U.S. sanctions (available here), which inter alia, contains Cyber related Designations and Designations Updates.

Sanctions imposed individually by third countries are not enforceable in the EU, but CySEC expects the Obliged Entities falling under their supervision to take such measures into account, in the context of their relevant risk assessment and take proportionate action, including refraining from engaging with affected persons.

This Circular serves as a reminder to Obliged Entities of their obligations and particularly to CASPs, of the content of CySEC’s Policy Statement on the Registration and Operations of CASPs (“PS-01-2021”, available here), according to which CASPs, are inter alia expected to have in place policies, procedures, systems and controls to ensure compliance with a risk based approach (Paragraph 2.2.2.4 of PS-01-2021 elaborates further on the subject matter).

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.