Cyprus has introduced three new laws to bolster sanctions enforcement. The legislative package results in the establishment of a new authority for the implementation of sanctions, with powers of centralised oversight and coordination as well as the ability to impose administrative fines for non-compliance with its requests or reporting obligations.Criminal liability for sanctions violations has also been revisited, with prison sentences of up to 5 years (for natural persons) and monetary penalties of up to 5% of the aggregate worldwide turnover (for legal persons), amongst others. Whistleblower protection has also been expanded to encourage reporting of sanctions violations and safeguard individuals from retaliation.
Cyprus sanctions laws overhauled
The Cypriot Parliament voted three new bills into law, with a view to enhancing the Cyprus framework for the implementation and enforcement of restrictive measures. The package comprises:
- Law on the Implementation of Sanctions and Establishment of a National Sanctions Unit of 2025
- Law on Defining Criminal Offences and Penalties for Violating Restrictive Measures of 2025
- Legislation amending the whistleblowers framework.
New Sanctions Authority
The new framework establishes a National Unit for the Implementation of Sanctions (Εθνική Μονάδα Εφαρμογής Κυρώσεων, ΕΜΕΚ) (the Cyprus Sanctions Authority).
The Cyprus Sanctions Authority is a central authority, created as a Directorate within the Ministry of Finance, with significant institutional weight. It consolidates the mandates and powers of the previous bodies (the Sanctions Advisory Committee (ΣΕΟΚ) and the Sanctions Implementation Unit (ΜΕΚ)).
The Cyprus Sanctions Authority will operate as the central coordinating body for all competent supervisory authorities and government agencies—including those in the banking, legal, and corporate services sectors—to ensure a unified and consistent approach to sanctions enforcement across the economy. It will also have the power to issue licenses and approvals where permitted under EU restrictive measures.
The Cyprus Sanctions Authority is also granted powers of accessing information (such as the beneficial owners registry), collecting information, exchanging intelligence with other authorities and imposing significant administrative fines for the infringement or non-compliance with its requests or reporting obligations. These administrative fines are distinct from, and can be applied in addition to, criminal proceedings for the infringement of sanctions.
Criminalising sanctions violations
The Law on Defining Criminal Offences and Penalties for Violating Restrictive Measures of 2025 transposes Directive 2024/1226, which mandates the criminalisation of sanctions violations across the European Union.
The new statute defines a range of activities as criminal offences, including:
- making funds or economic resources available, directly or indirectly, to a sanctioned person or entity
- failing to freeze the assets of a sanctioned person or entity upon their designation
- facilitating the travel of sanctioned individuals through Cyprus
- engaging in prohibited trade (import/export), transactions, or services with sanctioned regimes or entities
- circumventing sanctions through deceptive means, such as using complex networks of shell companies to conceal asset ownership or providing false information to authorities and financial institutions.
Companies found guilty of such criminal offences may be fined up to 5% of their total worldwide turnover or a fixed amount reaching into the millions of euros. Crucially, they also face additional crippling penalties such as exclusion from public benefits and procurement contracts, permanent disqualification from business activities, and court-ordered liquidation. Individuals found guilty of these criminal offences may face severe penalties of up to five years imprisonment and/or fines.
The law establishes procedures for the freezing (temporary seizure) and ultimate confiscation (permanent removal) of assets and any proceeds derived from the criminal violation of sanctions, ensuring that crime does not pay.