What this chapter covers
Rules on paper only work if a firm is organised to apply them. Every regulated firm in Cyprus needs a culture in which compliance comes before profit, and a clear division of work between the Board, senior management, the AML compliance officer, internal audit and every employee.
The rules come from Law 188(I)/2007 and, for firms supervised by CySEC, CySEC's AML Directive, which sets out the Board's duties, the compliance officer's tasks and reports, the annual internal audit and the training programme.
Read the notes in order the first time: culture and the Board first, then the compliance officer and internal audit, and finally what each employee must do and how staff are trained.
The 5 topics
Each note starts with a short answer and a table of the facts to remember.
Culture and governance
- What makes a strong AML compliance culture?Compliance before profit, the four building blocks, and proportionate, approved and reviewed policies.4 building blocks5 min
- What are the Board's responsibilities for AML compliance?What the Board sets, appoints and approves, what senior management signs off, and the designated Board member.6 min
The compliance function
- What does the AML compliance officer do?Appointment, the alternate and assistants, the officer's duties and the monthly and annual reports to CySEC.15 daysEnd of March7 min
- What does internal audit do for AML compliance?An independent, at least annual review of the AML controls, reported to the Board and then to CySEC.At least annually5 min
The numbers to know
Every figure in this chapter, with the note that explains it.
| Figure | What it is | Note |
|---|---|---|
| 4 building blocks | Risk-based policies and controls, a compliance officer, ongoing training and independent audit | Topic 1: What makes a strong AML compliance culture? |
| 15 days | Deadline after each month-end for the Monthly Prevention Statement to CySEC | Topic 3: What does the AML compliance officer do? |
| End of March | Latest date for the compliance officer's approved Annual Report and Board minutes to reach CySEC (submitted to the Board for approval by the end of February) | Topic 3: What does the AML compliance officer do? |
| At least annually | How often internal audit reviews the AML controls; its report and the Board minutes reach CySEC by the end of April | Topic 4: What does internal audit do for AML compliance? |