CySEC AML · Chapter 6 · Topic 7 of 14

Who can see beneficial ownership registers in Cyprus?

Who counts as a beneficial owner, which central registers record them, who may look, and why an extract never replaces a firm's own checks.

By the ExamPass CY editorial teamLast reviewed 7 min read

Tested inAML · Ch 6

Short answer

A beneficial owner is the individual who ultimately owns or controls a customer; for a company, 25% plus one share, or an ownership interest above 25%, is the indicator. Cyprus keeps central registers for companies, for societies and foundations, and for trusts. Supervisors, MOKAS, the Tax Department, Customs and the Police have full access. Obliged firms may consult the registers for CDD but must never rely on them alone. Anyone else sees limited details, and only after showing a legitimate interest.

Beneficial ownership at a glance

Beneficial owner of a companyThe individual who owns or controls it, directly or through companies they control; 25% plus one share, or an ownership interest above 25%, indicates ownership
No owner identified, or doubt about the one identifiedAfter all possible means are exhausted, and with no grounds for suspicion, the senior managing official is treated as the beneficial owner and the steps taken are recorded
Companies and other legal entitiesHold current beneficial ownership information and file it with the central register kept by the Registrar of Companies
Express trusts and similar arrangementsTrustees hold details of the settlor, trustees, protector, beneficiaries or class of beneficiaries, and anyone else in effective control; CySEC keeps the trust register
AuthoritiesCySEC and the other supervisors, MOKAS, the Tax Department, the Customs and Excise Department and the Police have full, timely access; for companies and other entities, without the entity being alerted
Obliged entitiesAccess for CDD purposes, but never as the only source; discrepancies they find are reported to the authority that keeps the register
Persons with a legitimate interestName, month and year of birth, nationality, country of residence, and the nature and extent of the interest held
Trust information not filed€100 plus €50 for each day the failure continues, up to €5,000 in total, since December 2024

Source: Law 188(I)/2007, Article 2 (definition of beneficial owner) and Articles 61A–61C, as amended in 2024 and 2026.

Who counts as a beneficial owner?

The beneficial owner is always a natural person: the individual who ultimately owns or controls the customer, or on whose behalf a transaction is carried out. Holding companies and nominees are only steps along the way.

For a company, a holding of 25% plus one share, or an ownership interest of more than 25%, is treated as an indication of ownership. It counts whether the stake belongs to the individual directly or sits in one or more companies that the same person controls. Control exercised by other means counts too. Companies listed on a regulated market with disclosure rules that meet EU standards fall outside this test, because their ownership is already transparent.

The senior managing official is treated as the beneficial owner only as a fallback: when, after every possible step and with no grounds for suspicion, no owner can be identified, or when it is doubtful whether the person identified really is the owner. The firm then verifies that person and records what it did. For a trust, the beneficial owners are the settlor, the trustees, any protector, the beneficiaries or, if they have not yet been determined, the class of persons the trust mainly serves, and anyone else who ultimately controls it. Foundations and similar arrangements follow the same pattern.

Terms used in this note

Beneficial owner
The natural person who ultimately owns or controls a customer, or on whose behalf a transaction or activity is carried out.
Legitimate interest
An interest in preventing and combating money laundering and terrorist financing, which anyone other than the authorities and obliged entities must demonstrate before seeing register data.
Express trust
A trust created deliberately by a settlor, usually in writing, to hold assets for beneficiaries, as opposed to one that arises by operation of law.

Which beneficial ownership registers does Cyprus keep?

There are three central registers. The Registrar of Companies keeps the one for companies and other legal entities on its register. The General Registrar keeps the one for societies, foundations, federations, associations and charities. CySEC keeps the register of express trusts and similar legal arrangements.

In each case the entity itself, or the trustee, must hold adequate, accurate and current information about its beneficial owners; for companies and foundations, the owners must supply what the entity needs. When a firm takes on a customer that has to register, it asks for proof of registration or an extract from the register; see When must CDD be completed?

Who can access the registers?

Access works in three tiers. The authorities, meaning CySEC and the other supervisors, MOKAS, the Tax Department, the Customs and Excise Department and the Police, see everything, promptly, and for companies and other entities without the entity being told. Obliged entities can use the registers while carrying out CDD.

Anyone else, whether a person or an organisation, needs a legitimate interest, meaning an interest in preventing and combating money laundering and terrorist financing. Such a person sees only the owner's name, month and year of birth, nationality and country of residence, plus the nature and extent of the interest held. Open public access ended after the EU Court of Justice ruled in November 2022 that giving the general public this data breached the rights to privacy and data protection. A March 2026 amendment wrote the legitimate-interest test into the law for the company register and the register of societies, foundations and charities, matching the rule already used for the trust register.

Access for obliged entities and for people with a legitimate interest can be withheld, only in exceptional cases and case by case, for all or part of the data: where it would expose the owner to a disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the owner is a minor or legally incapable. That exemption never applies to banks and other financial institutions.

Why can't a firm rely on the register alone?

A register entry is a starting point, not proof. The law says firms may not rely only on the register to meet their CDD duties and must take a risk-based approach, so they still identify the beneficial owners themselves and take reasonable steps to verify them.

If what the firm finds differs from what the register shows, it reports the discrepancy to the authority that keeps the register, which then acts to resolve it.

What happens if a trust is not registered?

CySEC can fine a trustee who fails to submit registration information €100, plus €50 for each day the failure continues, up to €5,000 in total. These amounts apply since December 2024; before then they were €200, €100 a day and €20,000, and older study material may still show them.

For other breaches of the trust register rules, CySEC can impose penalties of up to €500,000, or €1,000,000 for repeated breaches, depending on how serious they are, and can suspend or remove the trust's registration.

How to think about it

Keep three questions apart. Who is the beneficial owner? Follow ownership and control through every layer to a natural person, with 25% plus one share as the marker. Where is it recorded? In the register that matches the customer's legal form. Who can look? Authorities see everything, firms see it for CDD, and anyone else sees a few fields only after proving a legitimate interest. Whatever the register says, the firm still does its own checks.

Common mistakes

  1. Treating a register extract as complete CDD. Firms must take a risk-based approach and may never rely on the register alone.

  2. Assuming anyone can browse the registers. Outside the authorities and obliged firms, access requires a legitimate interest and covers a few fields only.

  3. Counting exactly 25% as beneficial ownership. The indicator is 25% plus one share, or an ownership interest above 25%.

  4. Stopping at the first corporate shareholder. Indirect holdings through companies controlled by the same person count toward the threshold.

  5. Naming the senior managing official too early. That fallback applies only when no owner can be found after exhausting all means, with no grounds for suspicion, or when there is doubt about the person identified.

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Last reviewed on by the ExamPass CY editorial team against the law in force on that date. Study notes help you prepare for the CySEC exams; they are not legal advice. ExamPass CY is not affiliated with CySEC.

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