What this chapter covers
Every regulated firm in Cyprus must be able to recognise transactions that do not fit what it knows about a customer and report its suspicions to MOKAS, the financial intelligence unit. The rules come from Law 188(I)/2007 and, for firms supervised by CySEC, CySEC's AML Directive.
Reporting runs through the firm's AML compliance officer, who evaluates each internal report, files with MOKAS through goAML when there is knowledge or reasonable suspicion, and keeps a record of every decision. The law protects people who report in good faith and tells firms to hold back suspicious transactions until MOKAS has been told.
Read the notes in order the first time. Monitoring accounts against the customer's profile is covered in the KYC & Customer Due Diligence notes.
The 4 topics
Each note starts with a short answer and a table of the facts to remember.
Recognising suspicion
Reporting
- How are suspicious transactions reported internally and to MOKAS?The Internal Suspicion Report, the Internal Evaluation Report and filing through goAML.Any amount5 min
- How are reporters protected, and should a suspicious transaction be carried out?Good-faith protection, no retaliation, and holding back suspicious transactions until MOKAS is told.6 min
The numbers to know
Every figure in this chapter, with the note that explains it.
| Figure | What it is | Note |
|---|---|---|
| Any amount | Suspicious transactions are reported whatever their size, including attempts | Topic 2: How are suspicious transactions reported internally and to MOKAS? |
| 2 internal reports | Internal Suspicion Report by the employee; Internal Evaluation Report by the AML compliance officer | Topic 2: How are suspicious transactions reported internally and to MOKAS? |
| Immediately | When MOKAS must be told once there is knowledge or reasonable suspicion, or right after a transaction that could not be held back | Topic 3: How are reporters protected, and should a suspicious transaction be carried out? |