Cyprus

The establishment of the National Sanctions Implementation Unit (NSIU) with the Greek acronym: EMEK, through The Law on the Establishment of the NSIU (L.150 (I) 2025 with effect as of 25th July 2025, constitutes a major development in Cyprus’ sanctions legal framework. The House of Representatives plenary approved the "National Sanctions Implementation Unit Law" (NSIU). Statements emphasized Cyprus’ commitment to high international and EU standards, enhanced protection of the financial system, and strengthened mechanisms to prevent and penalize sanctions evasion. The formation of the NSIU was supported by three legal instruments: • The Law on the Establishment of the NSIU • The Law criminalizing violations of EU restrictive measures • An amendment to the Law on the Protection of Persons Reporting Violations of EU and National Law The broad powers of the NSIU include among others: • Investigating suspected violations of national, EU and UN sanctions and imposing administrative fines (up to €100,000 plus €100 per each day for non-compliance) • Reviewing applications and issuing sanctions-related licences and exemptions • Issuing binding directives, circulars and guidance • Coordinating enforcement efforts across local regulatory and law enforcement authorities • Collecting and exchanging information with local and foreign authorities • Freezing assets Individuals and legal entities have the obligation to report to the NSIU of funds or assets belonging or controlled by sanctioned persons and designated persons listed in EU sanctions have the obligation to disclose to the NSIU all funds and assets owned or controlled. Non-compliance with the above, gives the right to NSIU to impose administrative sanctions which may have potential criminal liability. The NSIU is expected to be fully operational by the end of 2025. How MPC can assist MPC Legal closely monitors the developments relating to EU sanctions and may assist with the evaluation of the application of the new framework, provide tailored advice and prepare, submit and monitor relevant applications to the NSIU.

The European Union (EU) continues to adopt further packages of economic sanctions against Russia due to the continuance of its military aggression against Ukraine, the latest of which is summarised below. The relevant legal framework is EU Regulation 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (“Regulation 269”) and EU Regulation 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine (“Regulation 833”) (hereinafter collectively referred to as the “EU Sanctions”). Note: The position is constantly evolving. Additional sanctions may be introduced in the coming days and these will be the subject of future articles. This information is: of a general nature only and is not intended to address the specific circumstances of any particular individual or entity; not necessarily comprehensive, complete, or up to date; not professional or legal advice (if you need specific advice, you may consult us). 17th SANCTIONS PACKAGE The European Union adopted on 20th of May 2025 its 17th sanctions package in response to Russia’s ongoing war against Ukraine through the Council Regulation (EU) 2025/932 of 20 May 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine and through the Council Regulation (EU) 2025/933 of 20 May 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The 17th package is EU’s largest ever package targeting Putin’s shadow fleet, doubling the number of vessels included in the list of those subject to a port access ban, ban on provision of a broad range of service. This package is also aiming to further restrict Russia's access to battlefield technologies, cut revenues from Russian energy imports and also introduces new hybrid, human rights, and chemical weapons-related sanctions. Key elements of the 17th package: Russian’s Shadow Fleet New 189 vessels originating from third countries were targeted (primarily oil tankers), bringing the total of designated vessels to 342. This “shadow fleet” – a loosely affiliated network of ships is responsible for transporting Russian oil while practicing irregular and high-risk shipping practices and/or supporting Russia’s energy sector.  Energy Sector EU has sanctioned major Russian energy actors including Surgutneftegaz, a major Russian oil company which provides substantial revenues to the Russian government, directly fuelling its war effort and Eiger Shipping DMCC, a Dubai based entity that controls vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices. Military-Industrial Complex EU is imposed sanctions on more than 45 Russian companies and individuals providing the Russian army with weapons, drones, military equipment, ammunition, critical components and logistical support. New 31 companies were added to the list since they are providing direct or indirect support to Russia's military industrial complex, or engaged in sanctions circumvention, subject to tighter export restrictions concerning dual use goods and technologies. This includes companies established in Russia and in third countries (Turkey, Vietnam, UAE, Serbia and Uzbekistan). Additional Listings This package introduces 75 additional listings, including 17 individuals and 58 entities, responsible for actions undermining the territorial integrity, sovereignty, and independence of Ukraine. The sanctions imposed include asset freeze and prohibition to make economic resources available and – in the case of individuals – also includes travel bans. Trade Measures The package further expands the list of dual use and advanced technology items subject to export restrictions with the aim of cutting Russia off from key technologies, in particular for military use, such as chemical precursors to energetic material and spare parts and components of high‑precision Computer Numerical Control (CNC) machine tools. Russian Hybrid Threat and Human Rights Violation Additional restrictive measures were imposed by EU against 21 individuals and 6 entities responsible for Russia’s destabilising actions abroad. EU in addition imposed restrictive measures on 28 individuals responsible for serious violations of human rights and the repression of democratic opposition. The new listings target members of the Russian judiciary: judges, prosecutors, representative of the Supreme Court of the Russian Federation and regional courts, as well as members of the Investigative Committee. _______ Authors Marilou Pavlou Christodoulides | Partner Stella Kagia | Senior Associate

Spurred by recent international events involving Ukraine, Russia, China, Iran, Venezuela, and North Korea, among others, complex export controls, economic sanctions and trade embargoes continue to evolve. In particular, the EU has adopted a wide range of restrictive measures against Russian individuals and entities in order to cripple Russia’s ability to finance the war. Navigating the complex landscape of EU sanctions can be challenging, particularly for companies operating in multiple jurisdictions or with international supply chains. MPC Legal’s sanctions compliance team offers specialized key services, as listed below, to help businesses remain compliant with the EU Sanctions while minimizing risk and ensuring smooth operations. Sanctions Risk Assessment MPC Legal performs comprehensive risk assessments to identify potential sanctions-related risks in your business operations. This involves analysing your supply chains, customer base, and partner relationships to detect any links to sanctioned entities or regions. A thorough risk assessment lays the foundation for a robust compliance strategy. Legal Consultation and Compliance Strategy Once risks are identified, our Firm can help you develop a tailored compliance strategy. This includes advising on EU sanctions regulations, offering legal opinions on the matter and providing guidance on how to align your business practices with the latest laws based on our people’s deep expertise in EU regulations who offer insights into best practices for compliance. Sanctions Screening and Due Diligence To ensure compliance with EU sanctions, it's essential to conduct thorough due diligence on customers, suppliers, and other business partners. MPC Legal can assist in implementing sanctions screening procedures, including conducting background checks and utilizing specialized software to identify sanctioned individuals and entities. This proactive approach helps you avoid costly compliance violations. Contract Review and Clause Development Sanctions compliance often requires specific clauses in contracts to protect your business. Our firm’s people can review existing contracts and develop new ones with appropriate sanctions-related clauses. These clauses help ensure that all parties understand their obligations in relation to EU sanctions and mitigate risks associated with non-compliance. Training and Education Compliance is a team effort, and a knowledgeable workforce is crucial for avoiding sanctions violations. MPC Legal can provide customized training sessions for your employees, covering EU sanctions regulations and compliance best practices. This training helps ensure that everyone in your organization understands the importance of compliance and knows how to recognize potential risks. Assistance with Regulatory Inquiries and Investigations If your business is subject to regulatory inquiries or investigations related to EU sanctions compliance, our experienced personnel can provide invaluable support. We can represent you during investigations, respond to information requests, and help you navigate the legal complexities involved. Our expertise can be instrumental in achieving favourable outcomes and minimizing disruptions to your business. Ongoing Monitoring and Compliance Audits EU sanctions regulations change frequently, requiring ongoing monitoring and adjustments to your compliance strategy. Our Firm offers services for continuous monitoring of sanctions lists and regulatory updates. Additionally, it can conduct regular compliance audits to ensure your business remains in line with EU sanctions requirements. Conclusion Compliance with EU sanctions is crucial for businesses operating within the EU and internationally. MPC Legal offers a comprehensive range of services to help you navigate this complex landscape. From risk assessment and compliance strategy to contract review and ongoing monitoring, our people’s expertise can guide you through the regulatory challenges and ensure your business remains compliant while minimizing the relevant risks. Investing in these services can ultimately safeguard your reputation and keep your operations running smoothly in an ever-changing regulatory environment.

Spurred by recent international events involving Ukraine, Russia, China, Iran, Venezuela, and North Korea, among others, complex export controls, economic sanctions and trade embargoes continue to evolve. In particular, the EU has adopted a wide range of restrictive measures against Russian individuals and entities in order to cripple Russia’s ability to finance the war. Navigating the complex landscape of EU sanctions can be challenging, particularly for companies operating in multiple jurisdictions or with international supply chains. MPC Legal’s sanctions compliance team offers specialized key services, as listed below, to help businesses remain compliant with the EU Sanctions while minimizing risk and ensuring smooth operations. Sanctions Risk Assessment MPC Legal performs comprehensive risk assessments to identify potential sanctions-related risks in your business operations. This involves analysing your supply chains, customer base, and partner relationships to detect any links to sanctioned entities or regions. A thorough risk assessment lays the foundation for a robust compliance strategy. Legal Consultation and Compliance Strategy Once risks are identified, our Firm can help you develop a tailored compliance strategy. This includes advising on EU sanctions regulations, offering legal opinions on the matter and providing guidance on how to align your business practices with the latest laws based on our people’s deep expertise in EU regulations who offer insights into best practices for compliance. Sanctions Screening and Due Diligence To ensure compliance with EU sanctions, it's essential to conduct thorough due diligence on customers, suppliers, and other business partners. MPC Legal can assist in implementing sanctions screening procedures, including conducting background checks and utilizing specialized software to identify sanctioned individuals and entities. This proactive approach helps you avoid costly compliance violations. Contract Review and Clause Development Sanctions compliance often requires specific clauses in contracts to protect your business. Our firm’s people can review existing contracts and develop new ones with appropriate sanctions-related clauses. These clauses help ensure that all parties understand their obligations in relation to EU sanctions and mitigate risks associated with non-compliance. Training and Education Compliance is a team effort, and a knowledgeable workforce is crucial for avoiding sanctions violations. MPC Legal can provide customized training sessions for your employees, covering EU sanctions regulations and compliance best practices. This training helps ensure that everyone in your organization understands the importance of compliance and knows how to recognize potential risks. Assistance with Regulatory Inquiries and Investigations If your business is subject to regulatory inquiries or investigations related to EU sanctions compliance, our experienced personnel can provide invaluable support. We can represent you during investigations, respond to information requests, and help you navigate the legal complexities involved. Our expertise can be instrumental in achieving favourable outcomes and minimizing disruptions to your business. Ongoing Monitoring and Compliance Audits EU sanctions regulations change frequently, requiring ongoing monitoring and adjustments to your compliance strategy. Our Firm offers services for continuous monitoring of sanctions lists and regulatory updates. Additionally, it can conduct regular compliance audits to ensure your business remains in line with EU sanctions requirements. Conclusion Compliance with EU sanctions is crucial for businesses operating within the EU and internationally. MPC Legal offers a comprehensive range of services to help you navigate this complex landscape. From risk assessment and compliance strategy to contract review and ongoing monitoring, our people’s expertise can guide you through the regulatory challenges and ensure your business remains compliant while minimizing the relevant risks. Investing in these services can ultimately safeguard your reputation and keep your operations running smoothly in an ever-changing regulatory environment.