Nov 14 / Evdokia Pitsillidou

Know All 2025 Anti-Money Laundering Regulatory Updates

about the author

Evdokia Pitsillidou

Director of Risk & Compliance at SALVUS Funds

Evdokia, a partner at SALVUS Funds, is actively advising and working on all matters related to licensing, regulatory compliance, and internal audit for investment firms, funds, Electronic Money Institutions (EMI) & Crypto-Asset Services Providers (CASP).

  • Member of the Global Institute of Internal Auditors (IIA)
  • Member of the Cyprus Investment Funds Association (CIFA)
  • Certified Actuarial Analyst (CAA)
  • CySEC Advanced Certified Person
  • CySEC certified Anti-Money Laundering Compliance Officer (AMLCO)
The fight against Money Laundering (ML) and Terrorist-Financing (TF) remains a global priority, with regulatory frameworks continuously evolving to address the emerging risks. In 2025, CySEC together with other European and national authorities, introduced several updates and assessments to further enhance the effectiveness of AML/CFT systems across supervised entities.

With this blog post, Evdokia Pitsillidou, an instructor at the institute,  explores key areas regarding the latest developments in the AML/CFT frameworks, including recent CySEC Circulars, MONEYVAL assessments, and National Risk Assessments, all of which shape the regulatory landscape of 2025.

Towards the end of this blog post, we conclude with an overview of the knowledge and skills gained upon successful completion of the course "Know All 2025 Anti-Money Laundering Regulatory Updates." 

Insights from Cyprus’ National Risk Assessment Reports


The Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) of the Council of Europe continues to assess the AML/CFT frameworks of EU Member States that are not FATF members. In its most recent reports (December 2023 and May 2025), Cyprus was assessed as largely compliant or compliant with 38 of the FATF Recommendations, with only two remaining partially compliant, reflecting the country’s ongoing progress in strengthening its AML/CFT regime. The Cyprus National Risk Assessments (NRAs) of 2018 and 2021 have been instrumental in identifying the country’s key ML/TF threats and vulnerabilities. The 2018 NRA, coordinated by the Central Bank of Cyprus and MOKAS, concluded that Cyprus faces a medium level of ML/TF threat, primarily driven by cross-border rather than domestic crime. The 2021 NRA, conducted in line with FATF Recommendation 15, examined ML/TF risks linked to crypto-asset activities and led to key recommendations such as adopting the Travel Rule and introducing enhanced due diligence measures for entities engaging in VA-related services.

The findings showed that CySEC-supervised entities in the securities sector demonstrated a strong understanding of VA-related risks and applied relevant mitigating measures, while the banking sector remained cautious due to limited experience and operational readiness. Meanwhile, Administrative Service Providers (ASPs) supervised by CySEC, ICPAC, and the CBA experienced inconsistencies stemming from differing supervisory guidance. Since then, these authorities have revisited and aligned their AML/CFT directives to ensure a more consistent approach. However, supervisory bodies have since revisited and updated their AML/CFT directives to provide greater clarity and alignment.


To further enhance supervision, the NRAs emphasized the need for financial supervisory authorities other than CySEC to establish formal registration, licensing, and supervision frameworks for VA activities. They also encouraged information sharing on best practices, assigned CySEC the responsibility for detecting unregistered CASPs, and recommended that the Customs Department receive specialized training for handling crypto-asset storage devices.

CySEC Circulars and Regulatory Updates

CySEC continues to play a central role in strengthening the national AML/CFT framework. Through the adoption of new European legislation and the issuance of targeted circulars, CySEC seeks to enhance supervisory consistency, transparency against ML/TF risks.


At the European level, several significant developments have shaped the AML landscape. The Regulation (EU) 2024/1624 introduces directly applicable AML/CFT rules across all Member States, ensuring a harmonized approach to compliance. It expands list of obliged entities to include Crypto-Asset Service Providers (CASP) and sets clearer obligations concerning Customer Due Diligence, beneficial ownership verification, and risk-based internal policies.


Complementing this, the Directive (EU) 2024/2654 strengthens the investigate powers of competent authorities by providing direct access to the Bank Account Register Information System (BARIS). This measure is designed to facilitate more efficient detection and investigation of serious financial cries, including ML and TF, by enabling authorities to trace assets and transactions in a timely manner.

Additionally, the 6th Anti-Money Laundering (AMLD6) repeals previous directives (AMLD4 and AMLD5) and modernizes the EU’s AML/CFT legal framework. AMLD6 focuses on enhancing cooperation between national authorities, increasing transparency and addressing emerging risks such as those related to crypto-assets and complex corporate structures.

Further, CySEC Circular C655 summarises common findings from CySEC’s review of AML Compliance Officers’ Annual Reports and Internal Audit Reports for the years 2022 ad 2023. The assessment revealed recurring deficiencies, including insufficient methodological explanations in AML inspections, limited detail in findings, data gaps, and the absence of detailed training and organisational information. These elements are essential for a comprehensive and credible AMLCO Annual Report.

Lastly, CySEC Circular C656 presents the results of a thematic review on regulated entities’ compliance with AML/CFT Law. The review identifies both areas of improvement and good practices observed during on-site inspections. Among the strengths noted were the use of enhanced monitoring systems, escalation procedures and robust customer due diligence documentation. However, weaknesses were also observed, including outdated AML manuals, incomplete application of enhanced due diligence measures, and gaps in transaction monitoring.


Therefore, these updates illustrate CySEC’s ongoing commitment in improving AML/CFT supervision, encouraging a culture of accountability, and ensuring that all obliged entities operate under a consistent and risk-based regulatory framework.


What is the Know All 2025 Anti-Money Laundering Regulatory Updates course and what does it include?

The Know All 2025 Anti-Money Laundering Regulatory Updates course is developed by SALVUS Funds and led by their Global Chief Risk & Compliance Director, Evdokia Pitsillidou. In this course, Evdokia focuses on presenting the key AML/CFT regulatory developments for 2025, including the latest MONEYVAL findings, Cyprus National Risk Assessments (NRAs), and CySEC Circulars, such as C614, C655, C656. Participants are guided through the recent EU AML legislative package, including Regulation (EU) 2024/1624, Directive (EU) 2024/1654, and the 6th AML Directive (AMLD6), ensuring a comprehensive understanding of how these updates affect regulated entities.

The course is designed to assist Compliance Officers, AMLCOs, Internal Auditors, and Senior Management of regulated entities in staying informed and compliant with the evolving AML/CFT landscape. It provides practical insights into applying these regulatory updates, adapting internal frameworks, and enhancing supervisory readiness.

The syllabus of the 2025 Anti-Money Laundering Regulatory Updates Course includes: 

  • Money Laundering (ML), Stages and Methods of ML

- What is Money Laundering (ML)?
- The phases/stages of Money Laundering (ML), and examples
- Methods of Money Laundering (ML)
- What is Terrorist Financing?
- Differences between Money Laundering (ML) and Terrorist Financing (TF)
- Similarities between Money Laundering (ML) and Terrorist Financing (TF) - ML & TF risks emanating from crypto-assets

  • MONEYVAL Assessment and follow-up reports

- Who is MONEYVAL?
- MONEYVAL Assessment Dec 2019
- Areas for Improvement
- Follow-up Report Dec 2021 - Follow-up Report Nov 2022
- Follow-up Report Dec 2023 - Partially Compliant Recommendations
- Largely Compliant Upgrade                                                                                                              
- Timeline - CY Ratings
- 4th Enhanced Follow-UP Report
- Why MONEYVAL ratings matter     

  
  • Cyprus National Risk Assessments of 2018 & 2021
- Cyprus National Risk Assessment 2018
   a. MOKAS and its powers
  b. NRA and ML threats
  c. The Vulnerable Sectors as per the NRA d. Banking Sector e. Securities Sector
d. Banking Sector
e. Securities Sector


- Cyprus National Risk Assessment 2021
   a. Supervisory Authorities
  b. Expected Legal Updates
  c. The Travel Rule
d. Key Findings - Supervisory Authorities, Banking, Securities, and ASP Sector
e. What to expect following the NRA findings
f. Important Recommendations

  • The AML Regulatory Framework
 
- Supervisory Authorities
- Powers of the supervisory authority
- AML Regulatory Framework
   a. EU Directives
  b. National Law
- Regulation (EU) 2024/1624 
- EU AML Authority (AMLA)
- Markets in Crypto-Assets Regulation (MiCAR)
 a. Aim and objectives
  b. Coming into force

  • Upcoming AML Regulatory Updates

- Regulation (EU) 2024/1624
- Directive (EU) 2024/1654
- 6th AML Directive - AMLD 6
- EU AML Authority (AMLA)

  • CySEC  Circular C614 - EBA Guidelines on National Restrictive Measures- CySEC Circular C614a. 1st set of Guidelines
    b. 2nd set of Guidelines


  • CySEC  Circular C655 -
 Findings of the AMLCO Annual Reports' Assessment
- CySEC Circular C655
a. Deficiencies
b. CySEC's Expectations
  • CySEC Onsite Inspections - Circular C656 - Thematic Review on supervised entities' compliance with the AML/CFT Law
- CySEC Circular C656 - Key takeaways
- Consolidated Good Practices
- Common Weaknesses/Deficiencies
- CySEC's Expectation
The material of the course is delivered in PDF slides and online video recordings. Learners registered for this course are provided with the flexibility to learn wherever and whenever. 

Upon completion of the course, learners have the opportunity to assess the knowledge acquired by answering a series of questions based on the examined material. 
The completion of this course counts towards the Continuous Professional Development (CPD) annual requirements for professionals, and holders of the CySEC Advanced, Basic and AML certifications. 
Get in touch
If you have any questions about Evdokia's course or any other questions related to your training requirements, please contact us
we would love to help.
From all of us at IforPE, the Institute for Professional Excellence,
Ancora Imparo