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ML/TF risks in Cyprus in light of COVID-19 and related policy responses



ML/TF risks in Cyprus in light of COVID-19 and related policy responses 1

By Andrea Moundi Savvides, Head of Compliance, MLRO (Cyprus), at Harneys.


COVID-19 has changed the world in a lot more ways than one could imagine. An increase in the level of crime and changes in the type of criminal activity is just one of the many consequences of COVID-19 on global businesses. According to “COVID-19 related Money Laundering and Terrorist Financing, Risk and Policy Responses” (FATF COVID-19 paper), new Money Laundering (ML) and Terrorist Financing (TF) threats and vulnerabilities from the outbreak of COVID-19 related crimes have been created.


Before the outbreak, the first National Risk Assessment (NRA) with regards to Cyprus was completed. Following that, it was evident that Cyprus is a strong international financial centre with a significant and advanced professional services sector.[1] The NRA acknowledges that the ML threat in Cyprus has increased due to international engagement. According to the NRA, the banking sector is the most fragile to an ML threat followed by TCSPs[2] or lawyers or accountants offering company and trust services.[3] The Cypriot NRA[4] identified that TSCPs have a “medium-high” risk for ML/TF. The relative ease by which companies are set up may cause, the otherwise lawful activities they provide,[5] to be used for criminal purposes. For instance, in Cyprus companies can be formed in less than two weeks and the actual cost does not exceed €700-800. If pre-approved names have been obtained, the service provider might be able to set up a company in just a few days. Cypriot companies have, in the past, been involved in recent laundromat instances,[6] a fact which both justifies (i) the level of risk allocated to this sector and (ii) the risk that COVID-19 may pose if proper due diligence procedures cannot be followed.

In 2020, Moneyval, the Council of Europe’s expert committee on the evaluation of Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) measures, published a report summarising their findings on the Cyprus AML/CFT measures in place following the on-site visit which took place between 13-14 May 2019 for the period 2013-2018.

COVID-19 related crimes

Increased fraud is one of the consequences of the pandemic. In April, the FATF president stated that: “criminals are taking advantage of the COVID-19 pandemic to carry out financial fraud and exploitation scams, including advertising and trafficking in counterfeit medicines, offering fraudulent investment opportunities and engaging in phishing schemes that prey on virus-related fears. Malicious or fraudulent cybercrimes, fundraising for fake charities, and various medical scams targeting innocent victims are likely to increase”.[7]

The European Commission has issued statements attempting to enlighten the public and prevent them from becoming victims of fraudsters.[8] Interpol[9] has also encouraged the public to exercise caution in general, including when buying medical supplies (including the immediate need to obtain face masks and antiseptic sprays) from “online providers” as there have been reports that the promised goods may never be delivered despite the payment having been made. Similar warnings have been issued by Europol[10] as well as the local police in Cyprus.[11] COVID-19 related crimes include fraud, cybercrime, misdirection or exploitation of government funds or international financial assistance.

With many places physically shutting down, working from home has become the new norm. This increases the use of online platforms for socialising, as well as purchasing goods and services which means that increased efforts need to be made both on a national level (for instance by regulators) and on a business level to ensure that adequate safeguards are appropriately used to guard against the further exploitation of the opportunities presented to criminals. Increased misuse of online financial services and virtual assets to move and conceal illicit funds is also on the rise.

The FATF COVID-19 paper highlights the increase in fundraising scams. As a jurisdiction, Cyprus should ensure that proper oversight is in order to ensure that criminals are not posing as charities by circulating emails and requesting donations for COVID-19 related fundraising campaigns. During the Moneyval inspection, Cyprus was rated as “partially compliant” in relation to Recommendation 8 of the FATF Recommendations[12] pertaining to the standards required of non-profit organisations.

According to the Moneyval inspection, Cyprus is hugely exposed to receiving proceeds from criminal activities abroad due to its activity as a financial centre. Hence, one of the challenges that trust and company service providers based in Cyprus need to overcome as a result of COVID-19 is the collection and verification of client due diligence and the execution of documents. Arguably, the various financial crime compliance programmes are commensurate to the various risks that countries and businesses face on a daily basis, as a result of inter alia, the globalisation of crime.

Becoming commercial and pragmatic is perhaps the best way for businesses to manage the risks that have arisen because of COVID-19. For instance, when dealing with the need to comply with client due diligence and onboarding requirements, it is important for compliance officers to apply the Risk-Based Approach (RBA) to its full extent whilst acting with caution. For instance, the requirement to obtain identification documents in hard copy certified form is undoubtedly difficult, if not impossible, depending on the level of lockdown in each country. On the other hand, obtaining documents in certified format is not only a regulatory requirement in certain jurisdictions it is also a way of ensuring that the risk of impersonation is significantly minimised.

The COVID-19 pandemic has yet again highlighted the importance of shifting from traditional methods of identifying and verifying the identity of clients and using reliable digital ID verification methods. The further use of electronic platforms should also be encouraged to the extent that appropriate safeguards are in place. In scenarios where regulated institutions identify instances of lower risk, then the FATF Standards provide for simplified measures to be applied. More generally, supervisors are encouraging the full use of electronic and digital channels to continue payment services whilst maintaining social distancing.

Encouraging responses

According to the FAFT, the swift and effective implementation of measures will act as a shield against the rising risks. Such responses could include better domestic coordination and the strengthening of communication between governments and the private sector.

In Cyprus, the various regulators have issued guidance or policy papers as a response to COVID-19. For instance, the Cyprus Securities and Exchange Commission (CySEC) has issued several circulars and guidance notes informing regulated entities of the impact that COVID-19 might have on their operations. CySEC encourages regulated entities to consider their business continuity procedures and systems, proportionate to the size and complexity of a regulated entity’s activities.[13] WFH requires a company’s systems to be just as robust and operational as on-premises. From a compliance with applicable AML/CFT procedure perspective, means providing the compliance team with unhindered access to the client files whilst at the same time ensuring that the use of those files remotely is not susceptible to external threats. It is also important to ensure communication channels between employees remain intact so criminals do not take advantage of a “broken phone” to facilitate their illegal aspirations.

Another example of the intervention by regulators in Cyprus includes the response that the Institute of Certified Public Accountants of Cyprus (ICPAC) has issued. This includes guidance as to what should be perceived as a red flag by its supervised entities during the pandemic. ICPAC urged its members to remain alert to any changes in the known business activities of their clients, or change in the behaviour of their clients, as well as new clients. With regards to the completion of client due diligence procedures, ICPAC has provided its members with general guidance notes to complete the CDD requirements such as using reliable online sources.[14] Supervisors have also responded by extending submission deadlines to the various annual reports, which are due during the first quarter of each year.

In general, less supervision and less direct contact between supervised entities and regulatory authorities is also a risk which has arisen due to the COVID-19 pandemic. Onsite inspections have been postponed or substituted and most national and international policy departments have activated business continuity plans with most staff working from home. This development signifies yet again the importance of ensuring that robust IT infrastructure is in place to support workers, working from home and to ensure that all parties involved fulfil their obligations to the best extent possible.

It is also important to ensure that regulated entities have a central point of contact to reach out to in difficult times. Due to limited resources, it is also vital for regulators to focus their resources in the area where the risk is greater – this means that regulators may need to revisit their risk assessment on the various regulated entities in due time to ascertain whether the risk of each entity has changed.

Encouraging and enabling the use of technology to the fullest extent is also highlighted in the FATF COVID-19; it is advisable that regulators should issue guidance which would further assist companies to meet regulatory requirements in a digitalised and socially distant era. Areas where the regulator may intervene, is in instances where certified true copies and the maintenance of hard copy files are a legal requirement and CDD completion, as mentioned above. Further, within the EU it is a legal requirement to train employees to be able to identify and manage ML/TF risks in discharging their day-to-day duties. With face-to-face meetings becoming a privilege and any “mass” gatherings prohibited, businesses need to turn to e-learning, webinars and virtual workshops and other forms of distance learning. Digital payment solutions are also vital in helping social distancing rules be adhered to.

It is important to balance out the commercial needs of all types of regulated businesses with possible risks. To remain alive, companies need to be agile and take a proactive approach to address the various issues in order to come out of the crisis best.

Economic relief measures and monetary assistance to individuals and businesses is yet another area where regulated entities may need guidance on in order to detect suspicious financial transactions, particularly in the context of cross border flows from countries that are receiving emergency COVID-19 related funding from international organisations and other donors. The FATF COVID-19 paper includes a reference to the fact that measures may be implemented to prevent the misuse of economic relief packages for ML/TF purposes and manage risks including the risk of corruption.[15] Regulated institutions should remain vigilant and ensure that AML/CFT procedures are applied correctly in such instances to avoid misuse of such economic relief, irrespective of whether it has been obtained locally or abroad.

Lastly, in the FATF COVID-19 Paper it is stated that agencies are considering pooling available resources, including repurposing assets confiscated or forfeited from criminals to assist in COVID-19 responses (eg using confiscated properties as temporary/emergency hospital facilities). The Moneyval inspection on Cyprus notes that the local competent authorities have not been proactive at freezing and confiscating foreign criminal proceeds, although they have been instrumental in assisting other countries. Unless the outbreak lasts for years, it is not likely that Cyprus will be in a position to utilize such confiscated assets for covering existing needs. According to Europol, only 1 per cent of criminal proceeds are confiscated in the EU.[16] Nevertheless, this could be an area of development both locally as well as on an EU level.

[1] Cyprus National Assessment of Money Laundering and Terrorist Financing Risks, (2018), p.9.

[2] Trust and Company Service Providers.

[3] Cyprus National Assessment of Money Laundering and Terrorist Financing Risks, (2018), p.10,11.

[4] Cyprus National Assessment of Money Laundering and Terrorist Financing Risks, (2018).

[5] Transparency International UK, ‘Hiding in plain sight – how UK companies are used to launder corporate wealth’ UK, (November 2017).

[6] Council of Europe, ‘Committee on Legal Affairs and Human Rights Laundromats: responding to new challenges in the international fight against organised crime, corruption and money-laundering Report’, Rapporteur: Mr Mart van de VEN, Netherlands, Alliance of Liberals and Democrats for Europe (March 2019). Accessed October 20, 2019.

[7] FATF, ‘COVID-19-related Money Laundering and Terrorist Financing Risks and Policy Responses’, May 2020




[11] ,

[12] FATF, ‘International Standards on Combatting Money Laundering and the Financing of terrorist & proliferation’ The FATF Recommendations, Updated June 2019



[15] According to the Moneyval inspection, the GRECO evaluation report on Cyprus, Fourth evaluation round – Corruption prevention in respect of members of parliament, judges and prosecutors) adopted in June 2016, it is stated that that “…It would appear that general awareness about corruption in Cyprus has increased over the years but although Transparency International’s Corruption Perception Index has ranked Cyprus among countries less affected by corruption (32 out of 168), other surveys indicate that corruption is perceived to be widespread in the country;…”.



Former Bank of England Governor Carney joins board of digital payments company Stripe



Former Bank of England Governor Carney joins board of digital payments company Stripe 2

By Kanishka Singh

(Reuters) – Mark Carney, former head of the UK and Canadian central banks, has joined the board of U.S. digital payments company Stripe Inc, days after the company was reported to be planning a primary funding round valuing it at over $100 billion.

“Regulated in multiple jurisdictions and partnering with several dozen financial institutions around the world, Stripe will benefit from Mark Carney’s extensive experience of global financial systems and governance”, the company said on Sunday, confirming a report by the Sunday Times newspaper.

Forbes magazine had reported on Wednesday that investors were valuing Stripe at a $115 billion valuation in secondary-market transactions.

A senior Stripe executive told Reuters in December that the company plans to expand across Asia, including in Southeast Asia, Japan, China and India.

The company offers products that allow merchants to accept digital payments from customers and a range of business banking services.

Stripe raised $600 million in April in an extension of a Series G round and was valued back then at $36 billion.

Consumer-facing fintechs have seen a boost to their businesses during the COVID-19 pandemic, as people have been staying at home to avoid catching the virus and have increasingly been managing their finances online.

Carney, who headed the Bank of England and the Bank of Canada, had a 13-year career at Wall Street bank Goldman Sachs Group Inc in its London, Tokyo, New York and Toronto offices.

He is the United Nations special envoy on climate action and finance.

(Reporting by Kanishka Singh in Bengaluru; Editing by William Mallard)

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The potential of Open Finance and the digitisation of tax records



The potential of Open Finance and the digitisation of tax records 3

By Sudesh Sud, Founder of APARI 

The world is undergoing huge changes at the moment. Between coronavirus pushing the economy to the limit and a group of Redditors challenging the financial market hegemony, people are questioning the role of established institutions. If finance doesn’t work to enable the economy, businesses or individuals, then who is it for?

Before the digital revolution, financial experts were seen as a necessity. They knew how things worked, what everything meant, could provide good advice and were employed to sit at the heart of the action. Now, trading can be done by anyone online through established platforms, with a wealth of information available to hand.

Yet, as the 2008 financial crisis proved, established financial institutions have made themselves too big to fail. Simply tearing down the existing financial system would leave many ordinary people, along with businesses and government treasuries, in ruin.

However, as legendary futurologist, Buckminster Fuller, once said: “You never change things by fighting the existing reality. To change something, build a new model that makes the existing model obsolete.”

Traditional banking models are already being upended by technology. Through Open Banking, challenger banks are able to connect services digitally, cutting inefficiencies and costs while speeding up transactions. Now, Open Finance is seeking to build on this model to connect financial services via technology, potentially making the existing financial model obsolete.

Just as Open Banking led to greater democratisation of money, Open Finance has the potential to transfer power back to individuals. Not only would this benefit society as a whole, but it would help minimise the boom-bust cycles that cripple entire economies. No individual would be too big to fail, and bailing people out would cost far less, having minimal impact on the economy overall.

With more information available to them, Open Finance businesses will be able to use technology to make better decisions instantly. Many people struggle to get onto the housing ladder due to a poor credit score, for example, yet they have been paying rent every month of their adult lives. Why, then, can they not access mortgages? A company called Credit Ladder is addressing this through Open Banking, reporting rent payments via challenger banks like Starling to credit agencies, helping good renters to access mortgages.

While it is still very early days for Open Finance, there seems to be an endless raft of possibilities to benefit individuals, businesses and national economies. Faster, more secure, and less risky access to credit can help grow the economy, transforming finance from something that benefits a few wealthy capitalists to something that enables growth in the real economy.

So how else could Open Finance benefit society?

Using Tax Information

Every working adult pays income tax. Some of us via self-assessment while others are enrolled in PAYE. Regardless, we all have tax records with a wealth of financial information that has been verified, at least in part, by HMRC.

This centralised repository of financial information could be put to better use, such as allowing credit reference agencies to better understand an individual’s risk profile or helping to prove income as part of a mortgage application. Unfortunately, HMRC is a black hole of information ‒ its sheer size and power sucks information in, but nothing comes back out again.

However, by Making Tax Digital (MTD), HMRC are effectively allowing individuals to keep validated tax records on the software of their choice. Software providers may then be able to use this information to enable certain aspects of Open Finance. The information doesn’t need to be protected by HMRC, it is the individual’s choice and responsibility over how to use their own information.

As MTD software develops, we will see it connected to Open Banking, allowing self-assessed taxpayers to connect their business account directly to the software, effectively getting their tax return completed for them by an AI program. They would simply check the details, add any adjustments, and click submit. HMRC would then validate the records, providing assurance for any financial institutions using that financial information.

More Growth, Lower Risk

With access to complete and validated financial information, lenders would be able to more quickly and accurately assess individual risk when considering a loan or mortgage application. This would greatly speed up the process of applying for a loan, whether for a business venture or property purchase, for example.

Take residential landlords, for example. They may own a few properties already, with equity coming out of their ears. If that landlord wants to obtain another property, they would need to get their accountant to assemble their financial information, complete a SA302, and send everything off to their mortgage advisors who would then validate the information before submitting the mortgage application.

The application can then take months to approve, slowing down the process and potentially leading to missed opportunities. Since property sales usually occur in a chain (the owner of the property you are purchasing is usually purchasing another property, and so on), these inefficiencies slow the process down for everyone and can have major impacts.

If, however, mortgage applicants could simply share validated financial/tax records, mortgage providers could use that information to make quick decisions with reduced risk. What’s more, applicants could share only relevant, high-level information, rather than expose their entire financial history.

Individual Risk Management

Currently, individuals can manage their credit score/risk profile via third party providers like Experian, Equifax and TransUnion. These credit reporting agencies use limited information, such as credit cards, store cards and loans to assess risk. Individuals need to understand what factors each agency uses in order to ‘game’ the system.

For example, someone who has always been careful with their money, kept to a strict budget and never taken out a loan or credit card will have a far worse credit rating than someone who regularly uses debt to finance their lifestyle. So, even though they may have amassed a good deal of savings, they cannot get a good deal on a loan or mortgage.

With Open Finance, these individuals would be able to quickly prove their earnings, spending, and savings, decreasing their risk profile in line with reality. Rather than crude measures of creditworthiness, financial institutions would be able to use accurate and validated information to make quick decisions based on realistic risk. This both transfers more power to individuals and contributes to faster growth while reducing overall risk.

As a centralised repository for validated financial information, MTD providers will be in a unique position to develop a two-sided marketplace for finance, allowing credit providers to match products to individuals’ risk profiles. When a customer needs a loan, credit card or mortgage, they can simply browse products for which they have already been approved, applying and receiving finance instantly.

Empowering PAYE Taxpayers

Currently, PAYE taxpayers have little, if any, visibility or control over their tax contributions. They will see the amount paid in tax and national insurance, but to claim any allowances requires them to submit a self-assessment tax return. For most PAYE taxpayers, this simply doesn’t seem worthwhile.

Yet, self-employed taxpayers can claim for things like travel to their place of work, a proportion of living expenses when working from home, even their lunch. These things are necessary for productive work yet, for PAYE taxpayers, come out of their already taxed income. Meanwhile, businesses tend to make use of every tax allowance available to them.

This imbalance could be rectified with Open Finance connected to tax software. As MTD becomes a validated system for self-assessed taxpayers, a new version could be developed for PAYE taxpayers, putting them in control of their tax and finances. Not only would they be able to benefit from Open Finance in the same way as self-assessed taxpayers, but they will also be able to claim for reasonable allowances. What’s more, HMRC/the Treasury/the government would be able to hold employers accountable for pay disparities and unreasonable tax avoidance.

Open Finance, then, has the power to speed up and reduce the cost of obtaining and providing finance. It would make the finance system fairer and most transparent while distributing financial power, and help to avoid the creation of too big to fail financial institutions and the boom-bust cycle that has become unfortunate features of modern capitalism.

Ultimately, Open Finance has the potential to help the UK and other nations recover from the seemingly unending series of crises that have plagued the early 21st century by allowing people to access finance quicker in order to grow their business and personal finances while reducing risk, inefficiencies, and costs.

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Three ways payment orchestration improves financial reconciliation



Knowing the best alternative payment methods

By Brian Coburn, CEO or Bridge,

When Luca Pacioli, the 15th century Venetian monk, invented double-entry account keeping, managing financial reconciliations had its own unique challenges. The father of modern accounting didn’t have to deal with glitches in his book-keeping app but he did have to write with feather-based quills by candlelight. Five hundred years later the challenges are different but no less onerous.

As in the 15th century, solid financial reporting is at the heart of every successful high-transaction business. As Pacioli no doubt knew, up-to-date, well-documented accounting ensures good operational health and makes it easier to grow. And that’s never been more important.

While it might not be feather quills by moonlight, today’s environment of multiple customer channels can be time-consuming and labour intensive, with various payment methods and financial reconciliations from multiple data sources.

Understanding cash inflow through online transactions is a critical element of financial reporting. However, when these involve multiple payment processors and payment methods and a complex system of disjointed silos of payment data, this can become a cumbersome and arduous manual task.

Common issues in this fragmented payments landscape include working across different formats, managing different data owners and access as well as inconsistent process timings. The result is often increased inaccuracy and inefficiency. Procuring multiple tools and software can end up being uncost-effective and unwieldy. Though the current digital transformation is an exciting time for retailers, staying on top of the ever-changing payment options can be an overwhelming burden for many business owners.

Introducing payment orchestration presents a single, accessible, creative and accurate source of transactional data, crucial for today’s complex challenges around financial reconciliations.


Today, commerce is 24/7, so being able to access and analyse real-time information is vital to managing business controls. Many organisations have looked to automate these processes with account reconciliation software.

However, one key challenge is the sheer volume of transactions and the need to capture data from a variety of different sources. Payment orchestration enables transactions to be carried out by multiple payment processors and payment methods with simple and flexible plugins, centrally monitored and routed in the most optimum way.

It allows users to add or remove providers easily, knowing the complexity (detecting outages and automatically rerouting payments) is being handled by a trusted specialist partner via an intelligent platform.

Bringing disparate sources of online transaction data into one place simplifies how enterprises access and operate with multiple payment processors and payment methods. This makes it easier for businesses to remain agile.


For organisations that still depend on manual, spreadsheet driven processes, the mechanics of reconciliation can be extremely time consuming.

A payment orchestration layer creates the opportunity to automate processes and reduce manual intervention. By bringing multiple payment processors and payment methods into an integrated service layer with intelligent routing capabilities, the impact of individual outages or failed payments can be mitigated to ensure optimum payment success rates, saving crucial revenue.


Naturally, significant manual work brings with it the added risk of human error. The speed with which business moves today demands accurate accounting processes. Checking for error takes up valuable time that could be spent focusing on business growth.

Payment orchestration can improve accuracy and reduce the opportunity for error. Providing a holistic and central source of real-time transactional data, payment orchestration can offer improved transparency and greater visibility of financial data.

With all transactional data captured in one source, payment orchestration can present a data source to feed other applications – such as automated reconciliation tools and fraud management – automating business processes in a seamless way across the enterprise. Good practice like this will, of course, enable a consistent approach to fraud management across all channels and payment services.

Multiple payment choices can be onerous but, today, not adopting them at all is unwise. The key to success, and good financial reconciliation, is being able to streamline and manage them.

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