The authorities involved have submitted in writing their comments and observations on the revised bills for the creation of the National Sanctions Enforcement Unit (EMEK), as well as for harmonization with the relevant EU Directive, to the Parliamentary Committee on Finance.
Among other things, the Institute of Certified Public Accountants of Cyprus (ICPAC) notes that ambiguities and gaps regarding sectoral sanctions persist in the bills. It also expresses objections concerning the administrative fines provided for, as well as issues related to the protection of personal data in connection with the obligation to transmit unaltered information to EMEK.
The Cyprus Securities and Exchange Commission (CySEC), on its part, believes that its participation in the Advisory Committee is not necessary, as the cases to be examined and the guidance to be provided to EMEK mostly fall outside its jurisdiction.
On the other hand, the Cyprus Bar Association (CBA) states that the proposals regarding the preservation of lawyer-client confidentiality have been adopted.
It is recalled that the revised texts of the three bills were sent to the Parliamentary Committee on Finance on May 23, with assurances that the positions of the affected authorities and stakeholders had been incorporated.
Risk of EU Sanctions and Fines
It is worth noting that Member States were required to implement the necessary legislative, regulatory, and administrative provisions to comply with the Directive by May 20, 2025.
What the Bills Provide
It is reminded that the purpose of the first bill is the establishment of the National Sanctions Enforcement Unit (EMEK) within the Ministry of Finance. This unit is designated as the competent authority for implementing the EU’s restrictive measures, UN Security Council sanctions, and national sanctions imposed by the Republic of Cyprus.
The bill also defines EMEK’s responsibilities, including collecting information, cooperating with other national and international authorities and organizations, exchanging data and information, and imposing administrative fines.
The second bill aims to align Cypriot law with Directive (EU) 2024/1226, which defines criminal offenses and penalties for violating EU restrictive measures and amends Directive (EU) 2018/1673.
This bill defines criminal offenses and penalties for violations of EU sanctions, introduces deterrent fines, facilitates investigations and prosecutions, and sets provisions for cooperation, information exchange, and asset freezing, in line with the Directive.
The third bill amends the 2022 whistleblower protection law, with the goal of aligning it with Article 14 of Directive (EU) 2024/1226, concerning protection for individuals reporting violations of Union and national law.
