CySEC AML Certification - Comprehensive Study Notes
Chapter 1: Introductory Provisions
1.1 References used in the manual
AML/CFT Law ( Prevention and Suppression of Money Laundering and Terrorist Financing Law) of 2007-, as amended
CySEC Directive: Prevention and Suppression of Money Laundering and Terrorist Financing
EBA Guidelines (EBA/GL/2021/02) on ML/TF risk factors for customer due diligence
FATF Risk-Based Approach Guidance for the Securities Sector
Cyprus NRA (National Assessment of Money Laundering and Terrorist Financing Risks)
Directive (EU) 2015/849 (4th EU Directive) and 2018/843 (5th EU Directive) amendments
ASP Law (Law regulating companies providing administrative services)
Terrorism Law (Law 75(I)/2019) as amended
UNSC resolutions and EU Restrictive Measures (Sanctions Law) 2016 (58(I)/2016)
Directive for the register of Crypto Asset Service Providers (CASPs)
1.2 The Cyprus Securities & Exchange Commission (CySEC)
Independent public supervisory authority for the Cyprus securities market
Supervises investment services, collective investment and asset management, admin services, and CASPs
CySEC publishes AML/CFT-related directives and maintains AML/CFT registers
Mission: investor protection, integrity, fairness, transparency; support safe securities market growth
1.3 Becoming an AML certified Compliance Officer (AMLCO)
AMLCO appointment required under AML/CFT Law Art. 69; AMLCO must be certified and registered in CySEC’s AMLCO register
AMLCO role defined in CySEC’s Directive for the Prevention and Suppression of Money Laundering and Terrorist Financing
The certification process ensures candidates have the knowledge and competence for AMLCO duties
Global AML challenges drive demand for qualified AML professionals
1.4 The objectives of the CySEC AML Certification
Provide AML professionals with knowledge, expertise and competence to detect, prevent and control ML/TF activities as AMLCO
Sets standard for AMLCOs in CySEC-regulated entities
All AMLCOs must be registered before appointment; ongoing annual professional trainings required to keep knowledge updated
1.5 Workbook for the AML Certification Examination
Purpose: learning and revision tool; first point of study; aids revision chapter-by-chapter
Structure: Preface, core study areas, sample questions, definitions and abbreviations
Chapter 2: Understanding Money Laundering, Terrorist Financing and Sanctions
2. Understanding ML, TF and Sanctions
2.1 What is Money Laundering (ML)?
ML: process of concealing or disguising illicit origin, movement or use of illicit funds to appear legitimate
Core ML model typically three stages: Placement, Layering, Integration
2.2 The 3 stages of ML
Stage 1 – Placement Phase
Introduce dirty money into the financial system (cash, cash-intensive businesses, etc.)
Structuring: deposit cash below reporting thresholds to avoid detection; deposits split across days and banks
Examples: €50,000 deposited in parts (e.g., €8k, €9.5k, etc.)
Smurfing: multiple agents (smurfs) deposit across many accounts/banks to seed ML
Other placement methods: mixing illicit funds with legitimate funds, loan repayments with laundered cash, cross-border currency smuggling, purchases of FX with illegal funds, shell companies, reverse flips in real estate, etc.
Stage 2 – Layering Phase
Distancing funds from their illicit source via complex structures to conceal audit trail
Techniques: wire transfers across banks/countries, converting cash to monetary instruments, rapid trading of securities, creating shell companies
Electronic transfers as a fast layering method (ATM, mobile, etc.)
Offshore structures and PICs to conceal UBOs
Stage 3 – Integration Phase
Re-enter funds into economy as apparently legitimate; difficult to distinguish between legal and dirty money
Examples: real estate, luxury purchases, cash-intensive businesses, joint ventures
2.3 ML threats and vulnerabilities (NRA-based, risk factors by sector)
Domestic ML threat level in Cyprus: medium
Vulnerable sectors:
Banking sector
Securities sector
Insurance sector
Other obliged entities (DNFBP)
Designated non-financial businesses and professions (DNFBP)
2.3.1 The banking sector
High exposure due to international activities; risk factors include unclear activity, lack of physical presence, tax transparency concerns, few employees, etc.
Regulatory and supervisory framework of CBC provides defence; internal controls bolster defenses
2.3.2 The securities sector
CIFs and Fund Managers dominate; most transactions abroad or OTC; risks mainly in layering/integration rather than placement due to non-cash dominance
ML threat: medium-low overall due to licensing and compliance focus; higher risk from international criminals
Risk profiles by player: CIFs (online brokers) medium-high due to non-face-to-face customers; traditional CIFs high net worth exposure; fund managers medium ML vulnerability
2.3.3 The insurance sector
Life/Investment components increase ML risk; products with long maturities and tax benefits attract ML/TF concerns
2.3.4 Other Obliged Entities
Money remittance, card issuing/acquiring, EMIs, digital currencies, DNFBPs; overall ML risk medium-low due to sector size
Specific risks by sub-sector: MTBs, EMIs, digital currencies, etc.
2.3.4.1 Money Remittance Business (MTBs)
Agent networks; international cash transfers; biggest TF threat globally; examples include Western Union, MoneyGram
2.3.4.2 Card issuing/acquiring
Card fraud, identity misuse; potential use of cards in layering/integration; cross-border implications
2.3.4.3 Electronic money services (EMIs)
Non-face-to-face risks; low regulatory limits; AML/CFT requirements under Electronic Money Law; AML concerns with anonymity and large transfers
2.3.4.4 Digital currencies, E-money, Virtual currencies
Virtual currencies are digital representations of value; high anonymity and cross-border misuse risks; not same as electronic money; transactions are often untraceable
2.3.5 DNFBPs
Trust/Company Service Providers (TCSPs), Non-profit organizations (NPOs) as high-risk; supervision by CySEC, CBA, ICPAC; NPOs used in TF financing historically
2.4 Terrorist Financing (TF) and TF Criminalization
TF history and FATF special recommendations post-9/11; Cyprus actions; authorities involved in TF control (Ministries, Police, MOKAS, DCE, etc.)
TF defined under Terrorism Law; criminal acts include providing support or financing to terrorist groups
2.4.1 Differences and similarities between TF and ML
Differences: origins of funds, motivation (profit vs ideology), nature of funds (large, structured vs small, unstructured), group structures vs non-group patterns
Similarities: same or similar methods (structuring, monetary instrument purchases, wire transfers, debit/credit cards); terrorists exploit AML/CFT weaknesses; global AML/CFT regimes influence TF activities
2.5 Sanctions
Sanctions concept: EU or UN policy to intervene in crises; targets include governments, entities, groups, individuals
Reasons for sanctions: peace, security, human rights, democracy, rule of law
Cyprus sanctions landscape: EU and UN sanctions; design and enforcement obligations for obliged entities; risk management to detect sanctions breaches
Financial sanctions related to TF
EU sanctions lists are list-based: prohibition on funds/financial resources to sanctioned individuals/entities; applies within the EU, to EU nationals, and entities established or operating in the union
Obliged Entity responsibilities under sanctions law
Identify acts in breach, document measures, seek approvals from UIS/SEOK for fund releases
SEOK (Advisory Committee on Economic Sanctions) for fund release recommendations to the Minister of Finance
UIS (Unit for the Implementation of Sanctions in the Financial Sector) responsibilities
Public access to sanctions information; requirement to consult UN/EU lists for customer due diligence and suspicious transaction reporting
End-of-Chapter Knowledge Check (high-level: ML stages, bank/non-bank methods; TF vs ML; sanctions)
Chapter 3: Legal and Regulatory Requirements
3. The Prevention and Suppression of Money Laundering Activities Laws of 2007 to 2023
3.1 Unit for Combating Money Laundering and Financial Intelligence Unit of Cyprus (MOKAS)
3.1.1 The Unit (MOKAS)
Established under AML/CFT Law Art. 54; independent operation; composition includes the Attorney General, Chief of Police, and Director of DCE
Functions: FIU for gathering, evaluating suspicious transactions; investigations; cooperation with other authorities and FIUs; issue directives; suspend transactions; provide guidance to Obliged Entities; request information; publish annual report
3.1.2 Functions of the Unit
Autonomy; powers include gathering, evaluating, and analyzing information; may request supplementary information; notify and cooperate with other FIUs; issue administrative orders for suspension; protect privacy; annual report
3.2 The Supervisory Authority (CySEC)
3.2.1 CySEC’s remit: ML/TF prevention within CySEC-supervised entities (CIFs, fund managers, ASPs, etc.)
3.2.2 Powers of CySEC: binding directives, on-site and off-site supervision; risk-based supervision; sanctions (administrative fines up to EUR 1,000,000; up to 10% of turnover; other sanctions); public reporting of sanctions; liability of legal persons; other enforcement features
3.3 Main provisions of AML/CFT Law: criminal liability, offences and penalties
3.3.1 Prescribed offences: ML offences and predicate offences
3.3.2 Who may be prosecuted and penalties for ML offences (e.g., for those who know: up to 14 years imprisonment or up to €500,000 penalties; for those who ought to have known: up to 5 years imprisonment or up to €50,000 penalties)
3.3.3 Other offences associated with ML/TF: disclosure delays; tipping-off; penalties
3.3.4 Privileged information (e.g., privileged communications between lawyers and clients)
3.3.5 Orders of disclosure by court; duty to notify changes post-disclosure
3.3.6 Tipping-off offences; penalties; prohibition on tipping-off during investigations
3.3.7 Exemptions from information disclosure under specified circumstances
3.3.8 False/misleading evidence or forged documents; penalties
3.4 European Directives
Six EU Directives implemented by Cyprus as of 2022; ML/TF risk factors; cross-border cooperation
3.5 FATF
FATF: international standard-setter; 40+9 Recommendations; ongoing typology reports; FATF Plenary meetings; EU Commission involvement
3.6 High-Risk Third Countries
EU risk-based approach to identify high-risk third countries; delegated acts after assessment; example Cayman Islands and Jordan in 2024 derogation list updates
3.7 MONEYVAL
Council of Europe body; mutual/self-evaluations; improvements and recommendations in respect of FATF standards
3.8 Law 75(I)/2019 (Fight against Terrorism) as amended
Terrorism prevention, investigation and prosecution; life imprisonment for TF offences; list of TF-related offences (threats, recruitment, financing, etc.)
3.9 UNSC Resolutions and EU Sanctions Law 2016 (58(I)/2016)
CySEC role in enforcing UN/EU sanctions; penalties for breaches; appointment and functioning of UIS/SEOK
End-of-Chapter Knowledge Check: topics to know (ML stages; bank, non-bank and non-financial ML methods; TF differences; sanctions)
Chapter 4: The AML Compliance Culture
4 The AML compliance culture
4.1 Basic elements of a strong compliance culture
Leadership commitment; compliance as a core value; avoid prioritizing profit over AML obligations
Components: internal policies, risk-based controls; appointment of AMLCO; ongoing training; independent internal audit
4.2 Internal Policies, Controls and Procedures
Policies aligned to AML/CFT framework; risk appetite; board/SM approval; rolled out across lines of business; regular reviews and updates
4.3 The Role of the Board (BoD)
BoD responsibilities: approve policies; appoint AMLCO and alternates; ensure access to necessary data; establish reporting lines; ensure resources and board awareness; oversee risk management manual
4.4 The role and duties of the AML Compliance Officer (AMLCO), Alternate AMLCO and Assistants
AMLCO duties: design and implement internal controls; customer acceptance policy; risk management manual; monitor compliance; evaluate suspicious reports; liaise with MOKAS; annual reporting; maintain customer risk registers
Alternate AMLCO: stand-in; can be outsourced; appointment documented; assistants may be appointed for large or dispersed operations
Immediate reporting to CySEC and maintaining staff lists for AML roles
4.5 The establishment and role of an Internal Audit Department
Independent audit function to annually assess AML policies, controls and procedures; findings reported to BoD; CySEC notified
4.6 Employees obligations, education and training
Obligation to report suspicious activity; training program mandatory; tailored training by role; evaluation of training effectiveness; BOD-specific training required; training materials aligned with AML/CFT laws and EU directives
End-of-Chapter Knowledge Check: summarize key elements (4.1-4.6) and their interrelations
Chapter 5: Assessing and Managing Risks
5. Assessing and Managing Risks
5.1 Risk-Based Approach (RBA)
Identify ML/TF risks considering customers, countries/geography, products/services, transactions and delivery channels
Proportionate measures; resources focused where risk is higher; EU-wide coordination via EBA risk-factor guidelines
RBA helps prioritise controls and monitoring; implement proportionate controls
5.2 Identifying ML/TF risks
Process comprises two steps: risk identification and risk assessment for particular customers, products, services and geographies
Initial CDD measures include: verify identity; verify beneficial owner; establish purpose and nature of business relationship
Obtain holistic view; ongoing monitoring
5.2.1 Sources of information for risk identification
Use internal knowledge and external sources (FATF, MONEYVAL, UN sanctions lists, IMF, EU CFSP, etc.)
Other sources: national risk assessments, regulators, FIUs, credible open sources, media, academia
5.3 Factors to determine risks
Primary indicators: customer risk, country/geography risk, product/service/transaction risk, delivery channel risk
Sector-specific risk factors by Wealth Management, Investment Firms, Investment Funds, Securities Sector (see detailed subsections 5.3.1–5.3.4)
5.4 Assessing ML/TF Risks
Categorize relationships and transactions into risk levels: High, Medium (Normal), Low
High risk requires Enhanced Due Diligence (EDD); EDD cannot substitute for regular CDD
Even with a low risk assessment, some high-risk scenarios require EDD (e.g., PEPs, high-risk third countries)
Weighting risk factors should be done carefully; avoid over-reliance on a single factor and avoid misaligned incentives
5.5 On-going monitoring of the risk assessment and record keeping
Keep risk assessments updated; monitor effectiveness of controls; review risk factors for individual relationships; adjust CDD accordingly
Maintain records (risk assessments, updates, etc.) for regulatory inspection; use automated MIS to track customer and transaction data; implement monitoring thresholds and alerts; ensure timely information sharing with BoD and AMLCO
End-of-Chapter Knowledge Check: review risk-based approach concepts and risk levels; 5.5 summary on ongoing monitoring and record-keeping
Chapter 6: Know Your Customer (KYC) and Customer Due Diligence (CDD)
6 Know Your Customer (KYC) and Customer Due Diligence (CDD)
6.1 Procedures for the prevention of ML/TF
Article 58 AML/CFT Law: Policies to mitigate ML/TF risks including CDD, record-keeping, internal reporting, and external reporting
6.2 Customer Identification and Due Diligence Requirements
6.2.1 When to apply CDD: establishing business relationships, occasional transactions above thresholds, suspicion of ML/TF, doubts about veracity of data, gaming services thresholds (€2,000), cash transactions in goods (€10,000), crypto asset services (€1,000)
6.2.2 Identification procedures and CDD measures: verify identity from reliable sources; verify beneficial owner; assess purpose; ongoing monitoring; third-party verification when applicable; ensure proportionality to risk
6.2.3 Identification procedures for individuals: Cypriot residents; required data; acceptable documents (ID, passport); address verification via visit or utility bill; keep copies certified true copies
6.2.3.2 Non-residents: obtain PEP information, foreign documents; ensure sanction-list integration with identity data; include passport data
6.2.4 Identification for unions, societies, clubs, provident funds and charities: verify legitimacy and board/management details
6.2.5 Identification for legal entities: understand ownership/control structure; obtain documents (certificate of incorporation, good standing, directors, etc.); require copies of financial statements if available; verify outside-Cyprus entities similarly
6.2.6 Constructing a customer economic profile: gather data to understand ownership, business activities, expected transactions; maintain separate forms/files
6.2.7 Timing of CDD: verify identity before establishing relationship or completing a transaction; derogations allowed in limited cases to avoid interrupting business; beneficiaries’ identity must be verified at payout or assignment in life insurance contexts
6.3 Simplified Customer Due Diligence (SDD)
May apply when business risk is low; SDD is not exemption from CDD; monitoring must be sufficient to detect anomalies; conditional factors for lower risk (Annex II) include public entities, pension schemes, banks, etc.
SDD indicators include adjusting timing, amount of information, sources of funds, frequency of reviews, etc.; SDD must still support risk assessment
6.4 Enhanced Customer Due Diligence (EDD)
Applied to higher-risk customers (natural or legal with high-risk jurisdictions, cross-border correspondents, PEPs, etc.)
EDD requirements include more information on identity, source of funds/wealth, purpose, senior management approval, enhanced monitoring, etc.
For cross-border correspondent relations: evaluate respondent’s AML/CFT controls; obtain senior management approval; document responsibilities; ensure payee-through data if applicable
PEP-related measures: SM approval; source of funds/wealth verification; ongoing enhanced monitoring; continue risk management for 12 months after public function ends
For payout/assignment of life policies where beneficiary is a PEP: perform enhanced checks at payout/assignment time
For beneficiaries in life/insurance: verify beneficiary identity and provide information at payout if named; if class-based, provide information about beneficiaries; monitor life-insurance policy payouts
6.4.2 High-risk indicators for EDD (Annex III): list of higher risk factors across customer, product/service/transaction and geographical domains
6.4.3 Type of EDD measures: examples include more intense identification, additional information about customer/beneficiary, source of funds verification, enhanced monitoring, senior management approvals, etc.; SDD where risk is low and intermediary-level checks acceptable
6.5 Sectoral guidelines for application of CDD measures
6.5.1 Wealth Management: high-value, private banking risk; aims for enhanced due diligence; verify source of wealth; increased monitoring; ensure funds origin is legitimate; ongoing enhanced monitoring of high-risk clients; maintain a robust internal review and management approvals
6.5.2 Investment Firms: risk driven by client base; adherence to EDD guidelines; potential use of third-party intermediaries; verify underlying investors if unregulated intermediaries; open to SDD where permitted
6.5.3 Investment Funds: fund structure and distribution channels create detection needs; risk-sensitive CDD; for funds with intermediaries, ensure robust CDD for intermediaries and underlying investors; for complex fund arrangements EDD
6.5.4 Securities Sector: complex, fast-paced, high liquidity; risk factors include bearer shares, disclosure gaps, anonymous entities; apply enhanced due diligence
6.6 Ongoing Monitoring
CySEC directives require ongoing monitoring of KYC/CDD and transactions
6.6.1 Review of KYC/CDD requirements; 6.6.1.1 Ensure records updated; 6.6.1.2 Regular checks; 6.6.1.3 Update timing; 6.6.1.4 Documentation of review outcomes
6.7 Beneficial Ownership information
6.7.1 Central Registry for Corporate or Other Legal Entities (Corporate Central Registry): Cypriot corporates must hold current beneficial ownership information; accessible to competent authorities, MOKAS, Tax Authorities, Police; CBC operates automated access
6.7.2 Central Registry for Trusts and similar arrangements: trusts must hold beneficial ownership information for settlor, trustee, protector, beneficiaries; access by competent authorities; penalties for non-compliance
6.8 Reliance on third parties
You may rely on third parties to meet CDD requirements; ultimate responsibility remains with the relying entity; request copies of verification data; third-country reliance not allowed if from high-risk jurisdictions unless certain conditions apply
6.9 CDD in case of networking (group) structures
Group-wide policies and data-sharing procedures; ensure compliance in branches/subsidiaries across jurisdictions; ensure cross-border compliance with local law; data protection considerations
6.10 Prohibition of shell banks cooperation
Do not engage with shell banks; ensure risk controls for anonymity-facilitating products and technologies
6.11 Processing of personal data
Personal data processing must comply with Personal Data Processing Act; data processing only for AML/CFT purposes; provide required privacy notices to customers; respect data subject rights; restrictions on data use
End-of-Chapter Knowledge Check: links to Know-Your-Customer, CDD, SDD, EDD, sector-specific guidelines, ongoing monitoring, and shell-bank prohibition
Chapter 7: Transaction Monitoring & Suspicious Reporting
7 Transaction Monitoring & Suspicious Reporting
7.1 Internal reporting procedures and external reporting to MOKAS
Pre-reporting information collection: ML/TF definitions broad; red flags and indicators; maintain comprehensive customer information to identify suspicious activity
Internal reporting process: appoint an AML Compliance Officer; internal suspicion reports; evaluate information; access to data; if suspicion exists, report to MOKAS via GoAML; monitor affected accounts; investigate transactions; explain if no report is filed
7.1.2 Internal reporting steps: internal suspicion report; internal evaluation report; if decide to report, file via GoAML; monitor accounts; if not reporting, document rationale; AMLCO acts as first point of contact during investigations
7.1.3 Disclosure in good faith (protection)
7.1.4 Protection of a person submitting internal/GoAML reports from threats/hostility; statutory protections
7.1.5 Avoidance of tipping-off before filing a report; restrictions on disclosure during investigations; exceptions for professional activities (e.g., auditors) depending on context
7.1.6 Non-execution or late execution of transactions: if data is insufficient or funds may be ML/TF, delayed execution may be allowed; not a breach if due to data gaps
7.2 Examples of suspicious transactions and activities (ML/TF indicators)
Suspicious customer behavior: evasive, non-responsive, threats, bribes to avoid reporting
Suspicious transactions/activities: unusual/complex transactions; large volumes; cash-intensive patterns; cross-border or high-risk activity; rapid movement of funds; unusual settlement patterns; bearer instruments; cross-border transfers
Suspicious customer identification circumstances: intermediaries with inadequate documentation; unusual IDs; reluctance to provide information; offshore or bearer features; aggressive secrecy
Suspicious investment activity: unusual investment patterns; rapid redemption; unusual holdings; cross-border or offshore features; complex structures
Suspicious activity in securities sector: undisclosed principals; multiple accounts; unusual cross-account transfers; large/wide wire activity; bearer instruments; offshore connections
Additional subcategories for cash, non-cash deposits, wire transfers, employee activity, etc.
End-of-Chapter Knowledge Check: internal reporting procedures; when to report; examples of suspicious activity; sanctions and protection rules
Chapter 8: Crypto Asset Service Providers (CASPs)
8 Crypto Asset Service Providers
8.1 Registration Procedure
Obligation to register CASPs under Art. 61E; CASPs must be registered if operating in Cyprus or planning to provide services from Cyprus
8.1.1 Obligations to register
CASPs established in Cyprus or intending to provide crypto-asset services from Cyprus must be registered
8.1.2 CASP Register: publicly accessible; information on CASP name, address, services, website
8.1.3 Application for registration: include CASP data, crypto-asset addresses, services offered, client types, geographic jurisdiction, whether registered/supervised elsewhere
8.1.4-8.1.7 Material changes, deregistration, suspension and notifications: timelines and conditions for updates and changes; regulatory actions and requirements
8.2 Organizational and Operating Requirements for CASPs
CASPs must adopt organizational/operational requirements per the CASP Directive; registration conditions include governance, capital, controls, data protection, and information security
8.2.1 Conditions for registration: honest and competent management; board composition; independence; strong governance; risk management; data protection; cybersecurity; internal controls; anti-money laundering measures; adequate funds; staff integrity
8.2.2 CASP information for clients/ potential clients; marketing clear and non-misleading; cost and risk disclosures; information presentation; standardised formats
8.2.3 Penalties for breach of CASP registration: up to EUR 350,000 prison; or fines; or both
8.3 AML/CFT Obligations of CASPs
CASPs are Obliged Entities under AML/CFT Law; must perform KYC and CDD measures; constructive economic profiling; source of funds/wealth verification; ongoing monitoring; report suspicious transactions; risk assessment and proportionate controls; CASPs are subject to the full AML/CFT framework
End-of-Chapter Knowledge Check: CASP registration, governance, and AML/CFT obligations
Chapter 9: Abbreviations & Definitions
Abbreviations (selected):
AML, AML/CFT, AI: various regulatory bodies (CySEC, MOKAS, CBC, ICPAC, CBA), FIU, NRA, DNFBP, PEP, KYC, CDD, SDD, EDD, CASP, UIS, SEOK, DO, etc.
Definitions (selected):
Beneficial Owner: natural person who ultimately owns or controls the customer; detailed criteria for corporate and trust structures
ML: Money Laundering; TF: Terrorist Financing; Proceeds; Designated non-financial businesses and professions (DNFBPs); shell bank; PEP; etc.
Central Registry concepts: Corporate Central Registry; Trust Central Registry
Other key terms: “Obliged Entities,” “Third Parties,” “Respondent Bank,” etc.
Chapter 10: Examination Practice Questions
10.1 Sample questions and answers (selected) to illustrate exam style
Q1: Three stages of ML? Answer: Placement, Layering, Integration
Q2: Three customer factors increasing risk in Wealth Management? See 6.5; factors include high-risk sectors, high confidentiality expectations, high-profile/PEP status
Q3: Example of a placement activity? Answer: Mixing of illegitimate funds with legitimate cash-intensive funds; structuring; smurfing
Q4: True statement about ML/TF? (ML vs TF basics)
Q5: Basic difference ML vs TF? About origin of funds and motivations
Q6: Stage where laundered funds used to buy high-value assets? Integration
Q7: Threshold for CDD for goods traders in occasional cash transactions? €10,000
Q8–40: Additional practice questions on training, governance, sanctions, PEPs, CASPs, etc.
End-of-Examination: Answers sheet provided to validate responses
General notes and cross-cutting themes
The CySEC AML Certification aims to standardize knowledge across AML professionals and ensure consistent, high-standard AML governance in CySEC-regulated firms.
The AML/CFT framework emphasizes an integrated approach: regulatory requirements, risk-based supervision, ongoing monitoring, and robust governance.
Thresholds and sanctions are central to practical compliance (e.g., CDD/EDD triggers, reporting thresholds, suspension periods for transactions, penalties, and reporting obligations).
The framework strongly emphasizes non-financial sectors (DNFBPs), cross-border risks, and emerging risk areas such as CASPs and digital/virtual assets.
The material emphasizes the interdependence of institutions: BoD governance, AMLCO, internal audit, MOKAS, CySEC, and the UIS/SEOK bodies all play complementary roles in AML/CFT enforcement.
*Notes: Where figures are given in the material, they are reproduced here with LaTeX formatting where applicable, e.g. thresholds and penalties: ; fines; penalties; setup/suspension durations: 7 business days; 30 business days; retention: years; TF life-imprisonment: up to life (depending on law); PEP monitoring: 12 months post-public function; etc.