The Cyprus Securities and Exchange Commission
(CySEC) has issued a circular requiring that
entities under its supervision investigate any connections they may
have with the so-called Panama Papers leak.
The circular is addressed to Cyprus Investment Firms, self-managed
Alternative Investment Funds (AIFs), AIFs
with limited number of persons, Alternative Investment Fund
Managers, UCITS management companies, and administrative service
providers (Regulated Entities).
Noting that the documents leaked may relate to tax evasion,
corruption and/or money laundering, the circular instructs the
Regulated Entities to immediately investigate their files to
determine:
(a) Whether they maintain or maintained any relationship with
Mossack Fonseca, whether directly or indirectly through a third
party which represented or acted for Mossack Fonseca;
(b) Whether they maintain or maintained any business relationship
with customers who were introduced or managed by Mossack Fonseca,
or by a third party representing acting on the behalf of Mossack
Fonseca;
(c) Whether they maintain or maintained any business relations with
anyone other person that seems to be included in the said
documents.
The Regulated Entities are required to inform CySEC by 20 April
2016 of their findings in relation to the above, as well as of the
measures they are taking to ensure compliance with Cypriot
anti-money laundering legislation in relation to the claims made in
the Panama Papers.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.