Cyprus has deferred the deadline for the new Register of Beneficial Owners after which those who don't file will face €200 fine plus further daily fines of €100 up to a maximum of €20,000 and even  criminal prosecution. 

In a briefing note by Cyprus law firm Kinanis, Chrysanthi Shiantani, associate lawyer said the Department of the Registrar of Companies and Intellectual Property of the Ministry of Energy, Commerce and Industry of Cyprus (Registrar of Companies), the updating of the Register of Beneficial Owners on the upgraded digital platform, has been extended to the 31st of March 2024.

Following the expiration of the deadline, penalties will apply for non-compliant companies and other legal entities according to the provisions of the Prevention and Suppression of Money Laundering and Terrorist Financing Law 188(I)2007, enacted by the House of Representatives on 23rd of February 2021.

As from 1 April 2024, a fine of € 200 and a further fine of  € 100 for each day of non-compliance with a maximum charge of €20,000 will be applied. Criminal liability or prosecution of any person might also arise in the case of non-compliance with the abovementioned obligation, she said.

"The officers of a corporate and/or other legal entity will not be subject to any penalty if they had acted with due diligence in complying with the provisions of the Prevention and Suppression of Money Laundering Activities Law 188(I)/2007 (as amended) and of the Anti-Money Laundering Directive 2018/843 and provided that failure to comply with the aforementioned obligation was not due to inaction, omission or negligence on their part.

"Additionally, with respect to the initial deadline for the submission of the Register of Beneficial Owners, namely the 31st of December 2023, the Registrar of Companies announced on the 08th of February 2024, that any penalties imposed and paid for the period from 01/01/2024 until 16/01/2024 for late submission, have been fully refunded."