Cyprus

On 29 May 2025, the House of Representatives passed the Investment Funds Administrators Law, L.101(I)/2025, marking a pivotal advancement in Cyprus’s financial regulatory regime. Published in the Official Gazette on 18 June 2025, the Law introduces a standalone legal framework for the regulation and supervision of fund administrators—a sector previously operating under the broader umbrella of fund manager legislation. This legislative development establishes a distinct regime tailored to the operations of fund administration companies, bringing Cyprus into closer alignment with leading EU and global jurisdictions. For the first time, investment fund administrators are subject to direct licensing and supervision by the Cyprus Securities and Exchange Commission (CySEC), ensuring a higher level of regulatory consistency and oversight. Under the Law, fund administrators are required to maintain minimum capital reserves—€50,000, or €125,000 where additional services are provided—carry professional indemnity insurance, and operate from a registered and central office located in Cyprus. Governance standards are enhanced through obligations relating to board structure, internal controls, and risk management. In addition, the Law imposes robust compliance, reporting, and anti-money laundering obligations, reflecting a clear commitment to operational integrity and investor protection. The scope of permitted activities includes core administrative services such as maintaining investor registers, calculating net asset values, and processing investor transactions for both UCITS and Alternative Investment Funds. While these functions were previously referenced under existing legislation and EU directives, they are now unified within a coherent and purpose-built legal structure. Investor confidence is further safeguarded through provisions addressing conflicts of interest, mandatory disclosure requirements, and reinforced governance mechanisms. CySEC is granted broad enforcement powers to ensure adherence, including the imposition of sanctions where necessary. The enactment of this Law significantly enhances the regulatory clarity and professionalism of Cyprus’s fund services sector. By setting a defined operational and supervisory framework, the Law strengthens the jurisdiction’s credibility and appeal to international asset managers seeking a stable and transparent European base. It represents a strategic step forward in Cyprus’s ongoing effort to modernise its financial services landscape and support sustainable growth in the investment funds industry. For more information, please contact Demosthenes Mavrellis ([email protected]) or your usual contact at Chrysses Demetriades & Co LLC. Author:  Demosthenes Mavrellis, Partner

The gaming industry in Cyprus, like in other jurisdictions, has evolved significantly, transitioning from traditional gaming to advanced digital platforms. With this growth it comes the necessity for strict regulatory frameworks, for ensuring security, fairness, and consumer protection. The legislation of the gambling sector in Cyprus is primarily governed by the Betting Law 37(I)/2019 and is regulating gambling activities in Cyprus. It establishes licensing requirements for betting operators and outlines obligations related to financial operations, transparency, and anti-money laundering (AML). The Importance of Industry Standards Industry standards in Cyprus gaming sector are designed to ensure consistency, quality, and security across gaming platforms. These standards serve several critical purposes: Consumer Protection The Cyprus National Betting Authority (NBA) enforces consumer protection measures to prevent fraudulent gaming practices. Regulations mandate that all licensed gaming operators provide fair and transparent gaming environments, particularly in online gambling, where risks of fraud and unfair gameplay are higher. NBA is also responsible to issue the following licenses for land-based and online betting: the provision of carrying out betting services within licensed premises excluding online betting services and horse racing betting (land-based betting); Τhe provision of electronic betting services excluding slot machines, on-line casino games of chance provided with a direct link and electronic horse racing (online betting). Quality Assurance Gaming operators in Cyprus must adhere to strict quality benchmarks. This includes compliance with technical standards to ensure the stability and performance of gaming systems, which is essential for consumer trust and industry credibility. Accessibility Under European Union (EU) regulations, which Cyprus follows, gaming platforms are encouraged to incorporate accessibility features for players with disabilities. This ensures inclusivity in the gaming experience. On the 2nd of May 2024 Cyprus announced the introduction of the Accessibility of Products and Services Law of 2024, upon the ratification of the EU Accessibility Act and the EU 2019/882 directive on the accessibility requirements for products and services. Key Industry Standards in Gaming Several key standards have been established to address various aspects of the gaming industry: Game Rating Systems The Pan-European Game Information age rating system (PEGI) is a voluntary, self-regulatory system. It was introduced following consultations with the industry and civil society in order to replace national age rating systems with a single European system. Most European Union (EU) Member States use PEGI, and some also have specific legislation.  While Cyprus does not have its own game rating authority, it follows the Pan European Game Information (PEGI) system. PEGI is an age rating system for video games which is used throughout the European Union, for age rating. This provides age and content ratings, ensuring that games are appropriately classified based on their content. Data Protection (GDPR Compliance) Gaming operators in Cyprus must comply with the General Data Protection Regulation (GDPR), which governs the collection, storage, and processing of personal data. The Data Protection Law of 2018 (Law 125(I)/2018) enforces GDPR requirements in Cyprus, ensuring that players personal and financial information is safeguarded. The Role of Regulation The Cyprus gaming industry is subject to a robust regulatory framework aimed at maintaining market integrity and protecting players. Regulatory authorities oversee several key areas: Player Protection Regulations impose strict measures to protect vulnerable groups, particularly minors. These measures include: No, entrance to a licensed premise is not allowed to minors that are either unaccompanied or accompanied by an adult. Mandatory Age Verification; Players must verify their age before accessing gambling platforms. Administrative fines The NBA may impose an administrative fine In case it is found that a person has performed an act, or has omitted to do so, either in breach of a condition in a Class A or B bookmaker’s or authorised agent’s licence, or in breach of the present L.37(I)/2019 69 Law, or in breach of the regulations, or in breach of the Directives issued. Data Security With the rise of online gaming, the security of players and financial information is very significant. The primary legislation governing Cybersecurity in Cyprus is the Security of Networks and Information Systems Law of 2020 (Law 89(I)/2020) (referred to as the “NIS Law”), which enforces the NIS Directive, Directive (EU) 2016/1148. The Digital Security Authority (DSA) oversees the enforcement of this law. The DSA is tasked with developing a national strategy for the security of networks, information systems, and cyber security. This strategy will outline strategic goals and relevant policy and regulatory measures to ensure a high level of security for networks and information systems. Companies designated as operators of essential services or as Competent Authorities fall under the regulation of this law. Gaming operators must implement strict security measures, such as encryption and secure payment processing, to protect player’s data. Conclusion A well-regulated gaming industry is essential for ensuring fairness, consumer protection, and market integrity in Cyprus. Implementing industry standards and regulatory supervision fosters sustainable growth while safeguarding the interest of players. As the gaming sector evolves, Cyprus adapts it’s regulatory framework in order to address adapt into new technologies and emerging risks, ensuring a safe and fair gaming environment for all participants. Author: Xenia Kasapi, LL.B., LL.M., MCIArb Senior Advocate Head of Intellectual Property & Data Protection [email protected] https://www.legal500.com/firms/17733-e-g-economides-llc/c-cyprus/lawyers/2159518-xenia-kasapi

Soteris Pittas & Co LLC is pleased to share the successful outcome in a high-stake legal matter handled before the District Court of Limassol. Our litigation team has successfully secured, inter alia, the ex parte issuance of an Anton Piller Order and extensive Freezing Orders in civil proceedings for the infringement of rights pertaining to intellectual property. Our clients, copyrights’ owners of a sophisticated AI software’s source code, had their source code repositories accessed, stolen, copied and used in, as it later appeared, other AI startup companies in the same field. Since copyright protections in the source codes underlying Artificial Intelligence (AI) systems require extensive evidence to be adduced by a plaintiff, the preservation of any evidence that establish the nature and extent of conduct constituting infringement, is critical. The Anton Piller Order, constituting a powerful and draconian legal remedy, was granted ex parte by the District Court of Limassol to protect our clients’ rights by permitting the Applicants to conduct a search of the Respondents’ premises for the purposes of seizing any incriminating evidence in the Respondents’ procession. In order to ensure that any evidence of vital importance to our clients’ case would not have otherwise been destroyed, nor tampered with, prior to being brought before the Court to be examined, a designated team of independent IT Forensic Experts, accompanied by independent supervising lawyers, authorised by the Court, managed to effectively identify, collect and secure any evidence of digital/ electronic nature. Once the evidence was preserved, the IT Forensic Experts carried out an in-depth analysis of the gathered documents, data and materials, which, involved the review and examination of, inter alia, a large volume of electronic files, system logs, emails and messages to extract valuable information that would assist in determining the extent of the infringement and in identifying any additional parties that may be also involved in the wrongdoings. This outcome highlights the meticulous preparation of our litigation team and underscores our commitment in delivering top-tier legal services to our clients while navigating the complexities that modern litigation entails.

SOTERIS PITTAS & CO LLC is pleased to announce that as of the 1st of January 2024, Mr. Christodoulos Neophytou, Mr. Alexandros Mavrommatis and Mr. Kyriakos Pittas have been promoted as partners in our Firm! Mr. Christodoulos Neophytou joined our firm for his legal training in September 2017 and he mainly specializes in Corporate and Commercial Litigation, Tort Law and Administrative Law, while he is also dealing with cases of the banking and financial sector. He has many years of court experience in related cases, representing clients on corporate and commercial disputes before the Cypriot courts, as well as companies and individuals in cases involving, inter alia, shareholders’ disputes, conspiracy matters, fraud and breach of fiduciaries duties, as well as cases concerning petitions for the appointment of Interim Receivers, Winding Up Petitions and applications for the issuance of discovery and gagging orders. Mr. Christodoulos Neophytou has obtained an LLB from Frederick University of Cyprus. Mr. Alexandros Mavrommatis has been a member of our Law Firm since 2015, joining the litigation team in 2019. He mainly deals with dispute resolution proceedings, the handling of court cases on corporate and commercial disputes and international proceedings for the recovery of debts and the enforcement of foreign judgments and arbitral awards, as well as the handling of court cases for the issuance of discovery orders and other interim measures. He has many years of court experience in cases pertaining to the aforementioned issues, representing domestic and international clients with a range of disputes before the Cypriot Courts. Mr. Alexandros Mavrommatis has obtained a Bachelor’s Degree in Classical Philology from University of Ioannina, Greece and an LLB Degree from Neapolis University of Cyprus. Mr. Kyriakos Pittas joined our litigation team in 2019 and specializes in cross-border commercial disputes and corporate law matters. He has court experience in representing clients in complex commercial disputes with an international element, as well as in representing clients in proceedings for the issuance of interim orders in aid of inter alia foreign proceedings. Mr. Kyriakos Pittas also frequently advises clients in matters pertaining to shareholders’ disputes and insolvency matters. He is a graduate of the University of Newcastle and holds a Master’s Degree in Corporate and Commercial Law from Queen Mary University of London, with First Honours. We would like to congratulate our three colleagues on their admission, and wish them continuous success.