Monday legal briefing — 28 September 2026
AML client checks: relying on another professional does not transfer responsibility.
Official guidance: the Cyprus Bar Association published its September 2026 guidance on third-party reliance on 22 September 2026. It explains existing duties under section 67 of Law 188(I)/2007; no separate commencement date is specified.
The guidance clarifies the safeguards for accepting another professional’s client checks: written arrangements, assessment of the third party and compliance-officer approval. The receiving provider remains responsible. This reliance does not cover ongoing monitoring.
For clients using company or fiduciary services, previous checks by a bank or adviser do not automatically complete the new provider’s checks. Practical next step: agree the secure transfer of identification and ownership evidence early, and allow time for the provider’s verification before completion.
Official sources
- Cyprus Bar Association — announcement, 22 September 2026
- CBA third-party reliance guidance, September 2026 edition, sections 1–4
- AML Law 188(I)/2007, as amended — sections 61 and 67
General information only; not legal advice. Please contact us about your circumstances.