Summary of CySEC's Circular C475

Memo #48-2021
CySEC Circular No: C475
Date: 12/11/2021
Subject: Sanctions Imposed by the Office of Foreign Assets Control ("OFAC") of the U.S. Treasury Department
Purpose: To inform Obliged Entities and particular CASPs for the latest U.S. sanctions list.

In Summary:

CySEC has issued the Circular C475 on 11/11/2021 to draw the attention of Crypto Asset Services Providers (CASPs), CIFs, ASPs, UCITS Management Companies, Internally managed UCITS, AIFMs, Internally managed AIFs, Internally managed AIFLNPs, Companies with sole purpose the management of AIFLNPs and the Small AIFMs, to the continuously updated list of the latest U.S. sanctions, which inter alia, contains Cyber related Designations and Designations Updates.

Cyber related designations are in particular relevant to Crypto Asset Services Providers (CASPs). They are also relevant to all Obliged Entities. 

CySEC is responsible for the compliance of the Obliged Entities with the Sanctions/Restrictive Measures that are decided and imposed by the United Nations’ Security Council and the European Union.

Sanctions imposed individually by third countries are not enforceable in the EU, but CySEC expects the Obliged Entities falling under CySEC's supervision to take such measures into account including refraining from engaging with affected persons.

This Circular serves as a reminder of the content of CySEC's Policy Statement "PS-01-2021" on the registration and operations of Crypto-Asset Service Providers. CySEC reminds that the Crypto-Asset Service Providers are expected to have in place policies, procedures, systems and controls to ensure compliance with a risk based approach as further elaborated under paragraph 2.2.2.4 of "PS-01-2021".

The updated list of the latest U.S. sanctions can be found on the following link: https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions 

CySEC's Policy Statement "PS-01-2021" can be found on the following link: https://www.cysec.gov.cy/CMSPages/GetFile.aspx?guid=13075523-a19e-43d9-8cce-e2c0e0f5bca9 

Read the CySEC Circular C475

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