Cyprus Strengthens Sanctions Enforcement with New Legislative Package

On 25 July 2025, three new legislations were published in the Official Gazette of the Republic of Cyprus, introducing a comprehensive framework for the implementation and enforcement of Restrictive Measures and Sanctions in Cyprus. The new legislative package, includes the following laws:

1. The Protection of Persons Reporting Breaches of Union and National Law (Amending) Law of 2025 – (Law 148(I)/2025, available in Greek)
2. The Criminalisation of the Violation of the Union’s Restrictive Measures Law of 2025 – (Law 149(I)/2025, available in Greek)
3. The Establishment of the National Sanctions Implementation Unit and the Implementation of Restrictive Measures and National Sanctions in the Republic Law of 2025 – (Law 150(I)/2025, available in Greek)

The new laws entered into force on the date of their publication in the Official Gazette.

In particular, the laws introduce the following:

1. The Protection of Persons Reporting Breaches of Union and National Law (Amending) Law of 2025 (L. 148(Ι)/2025)

This law harmonises Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024, on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673.

The amending law, extends the scope of the original law by adding the violations of Union restrictive measures listed in Article 5 of the Law on the Criminalization of the Violation of Union Restrictive Measures, including cases of incitement, aiding and abetting and attempting to commit them, to the application of the relevant law.

2. The Criminalization of the Violation of the Restrictive Measures of the European Union Law of 2025 (L. 149(Ι)/2025)

This law harmonises Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024, on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673.

It also repeals the Implementation of the Provisions of the Resolutions or Decisions of the United Nations Security Council (Sanctions) and the Decisions and Regulations of the Council of the European Union (Restrictive Measures) Law of 2016 (Law 58(I)/2016).

3. The Establishment of the National Sanctions Implementation Unit Law of 2025 (L. 150(Ι)/2025)

This law establishes, within the Ministry of Finance, a new directorate called the National Sanctions Implementation Unit (NSIU).

The NSIU acts as the competent authority for the implementation and supervision of restrictive measures and sanctions in Cyprus. Among its key responsibilities are:

• The implementation and supervision of the Restrictive Measures of the Council of the European Union and the Sanctions of the United Nations Security Council in relation to economic sanctions,
• The coordination of all authorities and state services for the implementation of the Restrictive Measures/Sanctions in the Republic,
• The collection of information, the cooperation with other state authorities and bodies in the Republic, with competent authorities abroad and with other organizations,
• The examination of requests for the granting of licenses or derogations in accordance with the legislative acts establishing Restrictive Measures and/or Sanctions,
• The evaluation of cases of potential violation of the Restrictive Measures/Sanctions,
• The issuance of directives, circulars, guidelines, clarifications and guidance on issues related to the implementation of Restrictive Measures/Sanctions in the Republic,
• The organisation of educational or training seminars or conferences and the publication and distribution of training material on issues related to the implementation of Restrictive Measures/Sanctions in the Republic.

Furthermore, the Law sets out a framework for the submission of authorisation applications or derogation concerning economic sanctions and any other sanctions, the obligations of Obliged Entities*, and the imposition of administrative sanctions by the NSIU, while preserving the existing powers and responsibilities of other competent supervisory authorities.

* “Obliged entity” is defined in Article 2 of the Prevention and Suppression of Money Laundering and Terrorist Financing Law.

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