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).
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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.
Legal Opinions For Financial Institutions
Legal opinion is a piece of professional legal advice on a specific subject. Lawyers have an exclusive right to prepare such a document at the request of the person concerned. A correctly drafted opinion letter will ensure the benefit of your side to all parties to the dispute and confirm the transparency of the contract or the legality of certain legal actions.
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Regulators, payment service providers, and other methods of payment such as Visa and Mastercard are now requiring investment firms and other financial institutions to show that the provision of services in European or non-European countries, is permitted and in line with local country rules and regulations.
It is important to remember that in drawing up a Legal Opinion on any issue, Lawyers are responsible for their opinions, as they conduct legal and factual research, analysis, and verification and it is for this reason that providing Legal Opinions can be a rather expensive process at times.
Our global network of associates has been vetted to ensure that quality Opinions are prepared with investment issues distinguished by strict language, clarity of circumstances provided, and presence of transparent and understandable conclusions.
We have assisted investment firms and other financial institutions globally, including Cyprus, South Africa, Belize, New Zealand, Australia, Thailand, Malaysia, Taiwan, Singapore, and more, to attain Legal Opinions in over 100 countries.
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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.