MOKAS Annual Sectorial Quantity & Quality Assessment of STRs/SARs for 2025

TO : Regulated Entities
i. CIFs
ii. ASPs
iii. UCITS Management Companies
iv. Internally managed UCITS
v. AIFMs
vi. Internally managed AIFs
vii. Internally managed AIFLNPs
viii. Companies with sole purpose the management of AIFLNPs
ix. Crypto Asset Service Providers
x. Small AIFMs under Law 81(I)/2020
xi. Crowdfunding Service Providers
FROM : Cyprus Securities and Exchange Commission DATE : 9 October 2026 CIRCULAR NO. : C805 SUBJECT : MOKAS’ Annual Sectorial Quantity & Quality Assessment of STRs/SARs submitted to the FIU by Obliged Entities for the year 2025 The Cyprus Securities and Exchange Commission (the ‘CySEC’) wishes with this Circular to inform the Regulated Entities that the Unit for Combating Money Laundering (the ‘MOKAS’ or the ‘Unit’) has published its Annual Sectorial Quantity & Quality Assessment of STRs/SARs submitted to the FIU by Obliged Entities for the year 2025 (the ‘Report’, attached). The Report constitutes a valuable tool to the Obliged Entities, assisting them to focus on high￾risk areas on a sectorial basis, providing financial intelligence valuable for actual analysis, criminal investigations and asset tracing. According to the Report, the most used risk indicators for the year 2025 that raised suspicions and triggered the submission of an STR/SAR were the following:

• Transactions related with Virtual Assets
• Use of Money Mules
• Transactions between unrelated counterparties
• Internet Fraud/Cyber Crime
• Money Laundering

2
Despite a commendable improvement in the overall quality and effectiveness of reporting, MOKAS notes that it has identified a number of deficiencies in some reports, that affect the quality, completeness, and analytical value of the information provided. These deficiencies were identified through the evaluation of Reports against the requirements and expectations outlined in MOKAS Reporting Guidelines. Addressing these shortcomings is essential to improving the effectiveness of financial intelligence analysis and ensuring timely and accurate reporting. CySEC encourages the Regulated Entities to study the Report and continue their efforts of improving STRs/SARs submissions to the Unit. Sincerely, Mr. George Karatzias Chairman, Cyprus Securities and Exchange Commission

Annual Sectorial Quantity and Quality
Assessment
Of STRs/SARs submitted to the FIU of Cyprus by Obliged Entities For the year 2025

Contents
1 Purpose of this Document.........................................................................................3
2 Quantitative Assessment.......................................................................................... 3
2.1 Number of Reports Submitted to the FIU from all Obliged Entities .....................................3
2.1.1Number of STRs/SARs submitted by "traditional" Obliged Entities during 2025 and
2024. ..........................................................................................................................................4
2.1.2Number of STRs/SARs submitted by Obliged Entities operating under the free
provision of services during 2025 and 2024 .............................................................................6
2.2 Number of Reports that failed submission during 2025 .......................................................7
3 Quality Assessment ..................................................................................................9
3.1 Reports Categorization..........................................................................................................9
3.2 Common deficiencies identified for all sectors...................................................................10
3.3 Reports Outcome / Use of Financial Intelligence................................................................10
3.3.1 Disseminations by Sector.................................................................................................12
3.4 Use of Reporting Indicators.................................................................................................13
3.4.1 Use of Reporting Indicators by Sector During 2025 for ML/TF ........................................13
4 Delivery Methods During 2025................................................................................ 19
5 Developments and Initiatives During 2026 .............................................................. 21
6 Executive Summary ................................................................................................ 22
7 Appendices............................................................................................................. 23
7.1 Report Indicators during the period 2024-2025..................................................................23
7.2 Seminars Provided by the FIU During 2025.........................................................................25
7.3 General Yearly Feedback for 2025.......................................................................................26
7.4 Measures of Quality Report Assessment ............................................................................27

1 Purpose of this Document
This Document concluded by the CyFIU presents the Annual Sectorial Quantity & Quality Assessment of STRs/SARs submitted to the FIU by Obliged Entities for the year 2025, a valuable tool to assess and enhance the quality of Reports submitted by the Regulated Sector. The purpose of this Document is:
A. To provide to the FIU an intelligence and resource allocation tool, assisting in:
o Identifying sectors with low reporting rates and/or with insufficient quality reports o Improve FIUs’ intelligence, moving from simply receiving STRs to enhancing the intelligence value of the STRs o Provide supervisory feedback o Support effective and quality reporting by the regulated sector B. To support Obliged Entities to focus on high-risk areas on a sectorial basis, providing financial intelligence valuable for actual analysis, criminal investigations and asset tracing. Specifically, it aims to:
o Improve the quality and usefulness of STRs/SARs o Reinforce legal and regulatory expectations o Highlight emerging risks and typologies o Encourage a risk-based approach o Build a cooperative relationship
C. To provide Supervisory Authorities useful feedback insights and meaningful
information on the quantity, quality and relevance of the Reports submitted by each Regulated Sector and to strengthen cooperation and mutual understanding between the FIU and the Supervisory Authorities. 2 Quantitative Assessment
2.1 Number of Reports Submitted to the FIU from all Obliged Entities
During the year 2025, the FIU Cyprus received 24.092 Reports from Obliged Entities of which, 21.857 were Reports from Obliged Entities operating under the free provision of services. From those 21.857 Reports, only 246 had a nexus with Cyprus and remained for further analysis in the CyFIU, while the rest of the Reports concerned and were disseminated to other EU/EEA FIUs.

Technological innovation and the resulting transformation of financial services and CASPs licenses in Cyprus, along with the Freedom to Provide Financial Services, have contributed to an increase in the volume of Reports received. As a result, the total number of Reports submitted as explained above, increased from 3.870 in 2024 to 24.092 in 2025.
2.1.1 Number of STRs/SARs submitted by "traditional" Obliged Entities during
2025 and 2024
The total number of Reports from "traditional" Obliged Entities has been steadily rising during the period under review. This category includes Reports submitted by Banking Institutions, Payment Institutions, Gambling Service Providers/Casino, Lawyers, Company Services Providers, Accountants/Auditors and other Obliged Entities established in the Republic. In 2025, a total of 1.183 Reports were submitted from Traditional Obliged Entities, recording an increase of 16% compared to 2024. 3.870 24.092 0 5.000 10.000 15.000 20.000 25.000 30.000 2024 2025 Number of Reports 2024 - 2025 597 340 136 33 32 28 17 0 100 200 300 400 500 600 700 Banking Institutions Payment Institutions (PIs) Gambling Service Providers Lawyers Company Service Providers Accountans/Auditors Others Number of STRs/SARs by sector 2025

o Banking Institutions
Even though the total number of Reports submitted by banking institutions decreased by 12% compared to 2024, banking institutions remained the largest submitter in this category, with a total of 597 Reports. The Reports submitted by Banking Institutions were highly concentrated across two Obliged Entities, with the first accounting for 47% of the 597 Reports submitted and the second for a further 27%. The remaining 26% were submitted among other Banking Institutions. o Payment Institutions Reports submitted by payment institutions show an increase over the period 2024– 2025, with the total number of Reports submitted in 2025 reaching 340. This 676 152 84 26 36 19 31 0 100 200 300 400 500 600 700 800 Banking Institutions Payment Institutions (PIs) Gambling Service Providers Lawyers Company Service Providers Accountans/Auditors Others Number of STRs/SARs by sector 2024 597 340 136 33 32 28 17 676 152 84 26 36 19 31 0 100 200 300 400 500 600 700 800 Banking Institutions Payment Institutions (PIs) Gambling Service Providers Lawyers Company Service Providers Accountans/Auditors Others Number of STRs/SARs by sector - Comparison of 2024 & 2025 2024 2025

represents a significant increase of 123%, ranking payment institutions as the second￾largest reporter within this category. o Gambling Service Providers /Casino Gambling services providers ranked third in terms of report submissions. In comparison with the Reports submitted in 2024, they recorded an increase of 62% in 2025, submitting a total of 136 Reports. Out of the 136 Reports mentioned above, 109 came from Obliged Entities supervised by the National Authority for Gambling and Casino Supervision, whereas the remaining 27 Reports submitted by Obliged Entities supervised by the National Betting Authority. o Lawyers The number of Reports received from lawyers slightly increased compared to 2024, amounted to 33 Reports in 2025. o Company Service Providers In 2025, the number of Reports submitted by Company Service Providers declined, with submissions in total, amounting to 32 Reports. o Accountants/Auditors In 2025, 28 Reports were submitted by accountants and auditors. There was nevertheless an increase compared to 2024, which may be viewed as corrective in nature, following the decrease observed in 2024.
2.1.2 Number of STRs/SARs submitted by Obliged Entities operating under
the free provision of services during 2025 and 2024 As previously noted, Obliged Entities that are licensed in the Republic, by exercising the right to the freedom to provide services, can offer their products and services across the Union, through the passporting mechanism.

o Crypto Asset Service Providers
In 2025, Crypto-Asset Service Providers (CASPs) ranked first in terms of the number of Reports submitted, both within the category under review and across the overall total, submitting 20.570 Reports during the year. CASPs first began submitting STRs and SARs to MOKAS in 2024. In 2025, they began providing their services on a more extensive scale, which explains the significant increase observed. This development is indicative of the growing trend in the use of crypto-assets as a means of transfer, payment, and store of value. Out of the 20.570 reports submitted, only 172 had a nexus with Cyprus. Consequently, the vast majority were disseminated to the FIUs of the relevant Member States. o Investment Firms The number of Reports submitted by investment services firms shows an increasing trend over 2024 and 2025, with the total number of Reports in 2025 rising sharply to
980. Nevertheless, out of these 980 Reports, 26 had a link with Cyprus and remained
with CyFIU for further analysis. o Electronic Money Institutions Among the Obliged Entities licensed in the Republic and operating under the freedom to provide services, the only category to record a decrease in the number of reports in 2025 was Electronic Money Institutions, which submitted 283 Reports during the year, compared to 370 reports in 2024. Out of the 283 Reports submitted, 28 had a nexus with Cyprus. Note: No reporting has been observed from a number of categories of Obliged Entities, namely:

1. Real Estate Agents, including when they are acting as Intermediaries in the letting of
   immovable property, when transactions of monthly rent exceed €10.000.
2. Persons trading or acting as Intermediaries in the trade of works of art, including when
   those are carried out in art galleries and auction houses.
3. Persons storing, trading or acting as intermediaries in the trade of works of art when this
   is carried out by free ports, amounting €10.000 or more.
   2.2 Number of Reports that failed submission during 2025
   During 2025, 185 Reports failed submission due to the below most common reasons:
   Year Number of Reports that Failed Submission
   2025 185

o Reason for Suspicion
The narrative of the Report should contain more than 400 and less than 4000 characters. The purpose of this requirement is to encourage Obliged Entities to provide sufficiently detailed, meaningful, and well-substantiated information when submitting Reports. By establishing a minimum narrative threshold, reporting entities are prompted to include adequate background information, the rationale for suspicion, relevant transactional details, and any supporting context necessary for effective analysis. This measure aims to improve the overall quality, completeness, and usefulness of Reports submitted to the FIU, thereby enhancing the efficiency and effectiveness of financial intelligence analysis. If this requirement is not fulfilled by the Obliged Entities, then the Report fails submission. o Attachments All Reports submitted to the FIU must be accompanied by all relevant supporting documents. The purpose of this requirement is to ensure that Reports are supported by adequate justifying documentation and relevant information, enabling a more comprehensive and efficient assessment by the FIU. Reports submitted without attachments will automatically fail the submission process. o Identification Details Reports containing missing or incomplete identification information for the subject(s) involved will automatically fail the submission process. The purpose of this requirement is to ensure that the FIU receives sufficient information to accurately identify and assess the individuals, legal entities, or beneficial owners referenced in the report. o Entity’s details Reports containing missing or incomplete information relating to legal entities will automatically fail the submission process. This requirement aims to ensure that the FIU receives sufficient information to accurately identify and assess the entities involved, including their legal name, registration number, jurisdiction of incorporation, business activities, registered address, and beneficial ownership information. The table and pie chart that follow, represent the percentages of Reports that failed submission during the year 2025. It should be noted that a Report may have failed submission for more than one reason(s).

3 Quality Assessment
3.1 Reports Categorization
The submitted Reports are categorized and prioritized based on predefined risk criteria within a risk-based assessment framework to determine their priority for assignment to analysts for further analysis, ensuring a more efficient allocation of the Unit’s human resources on priority cases and subsequent increase in effectiveness. Based on this prioritization, the Reports are categorized as “Low”, “Medium”, “Medium Serious” and “High”. Number Percentage Reason for Suspicion 66 26% Attachments 66 26% Identification Details 35 14% Entity's Details 26 10% Date of Birth 22 9% Nationality 12 5% Transactions' Details 11 4% Report Type 9 4% Other 7 3% Person's Details (Other than Nationality, Date of Birth, Identification Details) 2 1% Total 256 100% 2025 Reason of Failure

The below table demonstrates the categorization of Reports submitted by “traditional” Obliged Entities during 2025.
3.2 Common deficiencies identified for all sectors
Common Deficiencies Identified on Reports Submitted by Obliged Entities by evaluating Compliance with the Guidelines issued by the FIU to the Obliged Entities:
The FIU's assessment of Reports submitted by Obliged Entities has identified a number of deficiencies in some reports, that affect the quality, completeness, and analytical value of the information provided. These deficiencies were identified through the evaluation of Reports against the requirements and expectations outlined in the FIU Reporting Guidelines. Addressing these shortcomings is essential to improving the effectiveness of financial intelligence analysis and ensuring timely and accurate reporting. The most common deficiencies identified in some of the reports, include:
o Weak reason for suspicion, with insufficient narrative, lack of supporting documentation, or unclear grounds for suspicion. o Use of certain report indicators without clear explanation in the reason for suspicion. o Submission of SARs instead of STRs. o In rare cases, late submission of Reports has been identified, resulting in delays in the timely dissemination and analysis of financial intelligence. The above deficiencies and other findings related to reporting obligations identified during the review process were communicated by the FIU to the Obliged Entities on a case-by-case basis together with detailed explanations and guidance on the corrective measures required.
3.3 Reports Outcome / Use of Financial Intelligence
During 2025, a commendable increase was observed in the number of FIU disseminations. A total of 572 disseminations were carried out by the FIU, of financial intelligence, emerged from Reports received and from other sources. The majority were transmitted to the Police (469 disseminations), followed by the Tax Department (58 disseminations), while a smaller Sector Low Medium Medium Serious High Total Banking Institutions 136 261 141 59 597 Payment Institutions 28 294 17 1 340 Gambling Service Providers 57 66 8 5 136 Lawyers 12 14 5 2 33 Company Service Provider 11 10 8 3 32 Accountants/Auditors 4 16 5 3 28 Total 248 661 184 73 1166 PRIORITY CASES

number of disseminations were made to Customs, the Ministry of Interior, Supervisory Authorities, and other Departments of the Republic. For comparison purposes, in 2024, there were 205 disseminations, resulting from the analysis of suspicious transaction and activity Reports as well as from information from other sources. The majority of the disseminations were made to the Cyprus Police (131), while 74 Reports were disseminated to Supervisory Authorities and Other Governmental Departments. During 2024 and 2025, the FIU took increased action to suspend transactions reported by Obliged Entities, in accordance with its statutory powers and based on the information provided in the submitted Reports. During 2025, the upward trend in freezing orders secured in domestic criminal cases continued, with the value of the assets exceeding €10.000.000. This increase is attributed to the concerted effort, launched since 2023, of MOKAS, the Police, and the Prosecution, aiming to enhance the effectiveness of criminal asset recovery measures.

In 2025, the value of the frozen assets, from the Registration of Foreign Freezing Orders, issued on the basis of mutual legal assistance requests from foreign authorities, amounted to approximately € 17.115.298. In 2025, the value of confiscated assets exceeded €6.5 million.
3.3.1 Disseminations by Sector
The table below provides a breakdown of disseminated intelligence emerged from reports submitted, according to the type of obliged entity from which they originated:
Sector 2025
Banking Institutions 192
Payment Institutions 39
Gambling Service Providers 54
Lawyers 5
Company Service Provider 4
Accountants/Auditors 10
Investment Firms 5
Electronic Money Institutions 4

Απάτη (περιλαμβανομένης και διαδικτυακής απάτης) /Fraud (including Cyber Fraud) Ανεπαρκής τεκμηρίωση / No sufficient documentation provided Αρνητικές πληροφορίες/ Adverse Media Συναλλαγές που δεν συνάδουν με το οικονομικό προφίλ του πελάτη /Transactions don’t meet client economic profile Καταθέσεις Μετρητών / Cash Deposits Main Money Laundering / TF Suspicion Indicators 2025 - Banking Institutions
3.4 Use of Reporting Indicators
During the submission of the Reports, Obliged Entities select from a predefined list, provided by the Cyprus FIU through the goAML system, one or more ML/TF indicators that raised suspicions and triggered the submission of the Report. The indicators are revised periodically, in order to remain current and proactive, to reflect existing and emerging threats, as well as to capture the changes taking place. The most used risk indicators for the year 2025 were the following:
o Transactions related with Virtual Assets o Use of Money Mules o Transactions between unrelated counterparties o Internet Fraud/Cyber Crime o Money Laundering Comparatively, during 2024 the most used risk indicators were the below:
o Transactions related with Virtual Assets o Internet Fraud/Cyber Crime o No economic rational of activity o Unusual client behavior o No sufficient documentation provided For further details regarding all report indicators selected by the Obliged Entities during 2024- 2025, please refer to Appendix 7.1.
3.4.1 Use of Reporting Indicators by Sector During 2025 for ML/TF
3.4.1.1 Banking Institutions

Ασυνήθιστη συμπεριφορά του πελάτη / Unusual
Client Behaviour
Money Laundering
Ανεπαρκής τεκμηρίωση / No sufficient documentation provided Συναλλαγές σε χαρτονομίσματα μεγάλης αξίας / Transactions in big notes Απάτη (περιλαμβανομένης και διαδικτυακής απάτης) /Fraud (including Cyber Fraud) Main Money Laundering / TF Suspicion Indicators 2025 - PIs A high number of Reports submitted by banking institutions, were based on suspicions of potential fraud, including cyber fraud. In particular, in 2025 an evolving landscape of cyber enabled fraud was identified. New types of cyber-enabled fraud emerged and existing ones evolved in sophistication and scale. This is largely attributed to Technological advancements, emerging technologies and Digital Innovations. During this period, fraudsters increasingly relied on techniques such as smishing, vishing, and phishing to deceive victims and enable fraud. Insufficient documentation was also presented with high frequency. This indicator refers to cases where financial institutions require their clients to provide supporting documents for the execution of transactions. Where customers are unable to comply with this requirement, this may be an indication of suspicious activity.
3.4.1.2 Payment Institutions (PIs)
The most common Money Laundering/TF indicator chosen by Payment Institutions in 2025, was unusual customer behavior. This indicator refers to cases where the behavior of the reported individual or entity, deviates from what would normally be expected, based on the customer profile established through information obtained during the customer due diligence process.

Ανεπαρκής τεκμηρίωση / No sufficient documentation provided Απάτη (περιλαμβανομένης και διαδικτυακής απάτης) /Fraud (including Cyber Fraud) Ασυνήθιστη συμπεριφορά του πελάτη / Unusual Client Behaviour Υποψία για ενδεχόμενη απόκρυψη τελικού δικαιούχου/ Suspicion for possible UBO concealment Αρνητικές πληροφορίες/ Adverse Media Main Money Laundering / TF Suspicion Indicators 2025 - Lawyers
3.4.1.3 Gambling Service Providers
Reports submitted by gambling service providers were largely driven by identified negative information, with insufficient documentation also featuring as a commonly used suspicion indicator.
3.4.1.4 Lawyers
Αρνητικές πληροφορίες/ Adverse Media
Ανεπαρκής τεκμηρίωση / No sufficient documentation provided Ασυνήθιστη συμπεριφορά του πελάτη / Unusual Client Behaviour Αδικαιολόγητη / Ασαφής Προέλευση Κεφαλαίων / Unjustified/Unclear Source of Funds Πλαστά Έγγραφα / Submission of fake documentation Main Money Laundering / TF Suspicion Indicators 2025 - Gambling Service Providers

Αρνητικές πληροφορίες/ Adverse Media
Ανεπαρκής τεκμηρίωση / No sufficient documentation provided Ασυνήθιστη συμπεριφορά του πελάτη / Unusual Client Behaviour Ποινική έρευνα / Law Enforcement Investigation Υποψία για ενδεχόμενη απόκρυψη τελικού δικαιούχου/ Suspicion for possible UBO concealment Main Money Laundering / TF Suspicion Indicators 2025 - Company Service Providers The main suspicion indicators on the basis of which Reports were submitted by lawyers, related to insufficient documentation and potential fraud, including online fraud. Unusual client behavior was also identified with relatively high frequency, indicating a deviation from the declared customer profile. Finally, a notable proportion of Reports were submitted on the basis of suspicion of a potential false declaration of beneficial ownership, which also constitutes an offence under the national legislation.
3.4.1.5 Company Service Providers
Reports were submitted on the basis of negative information identified in relation to their clients, due to insufficient documentation and unusual client behavior, as well as on the basis of suspicions of a potential false declaration of beneficial ownership.

3.4.1.6 Accountants/Auditors
Accountants primarily based their Reports on insufficient documentation, meaning that either supporting documents were not provided or the documents submitted were deemed unsatisfactory. In a number of Reports, it was also noted that the activities of the involved natural and legal persons lacked economic rationale. In addition, several Reports were submitted on the basis of suspicions of potential fraud and the submission of fake documents, both of which also constitute criminal offences under the applicable legislation.
3.4.1.7 Crypto Asset Service Providers (CASPs)
Χρήση Μεταφορέων Χρήματος / Use of Money
Mules
Συναλλαγές μεταξύ μη συνδεδεμένων
αντισυμβαλλομένων/ Transactions between
Unrelated counterparties
Πολλαπλές συναλλαγές την ίδια ημέρα ή σε μικρό χρονικό διάστημα / Multiple transactions within the same day or within a short time period Απάτη (περιλαμβανομένης και διαδικτυακής απάτης) /Fraud (including Cyber Fraud) Αδικαιολόγητη / Ασαφής Προέλευση Κεφαλαίων / Unjustified/Unclear Source of Funds Main Money Laundering / TF Suspicion Indicators 2025 - CASPs Ανεπαρκής τεκμηρίωση / No sufficient documentation provided Δραστηριότητες που στερούνται οικονομικής λογικής / No economic rational of activity Απάτη (περιλαμβανομένης και διαδικτυακής απάτης) /Fraud (including Cyber Fraud) Πλαστά Έγγραφα / Submission of fake documentation Αρνητικές πληροφορίες/ Adverse Media Main Money Laundering / TF Suspicion Indicators 2025 - Accountans/Auditors

Reports submitted by Crypto-Asset Service Providers (CASPs) most frequently relied on the suspected use of money mules as a key suspicion indicator.
3.4.1.8 Investment Firms
The majority of the Reports were submitted on the basis of suspicions of possible fraud, activities lacking financial rationale, unusual customer behavior, submission of false documents and insufficient documentation. Απάτη (περιλαμβανομένης και διαδικτυακής απάτης) /Fraud (including Cyber Fraud) Δραστηριότητες που στερούνται οικονομικής λογικής / No economic rational of activity Ασυνήθιστη συμπεριφορά του πελάτη / Unusual Client Behaviour Υποβολή Πλαστών Εγγράφων / Submission of fake documentation Ανεπαρκής τεκμηρίωση / No sufficient documentation provided Main Money Laundering / TF Suspicion Indicators 2025 - Investment Firms

3.4.1.9 Electronic Money Institutions (EMIs)
The main indicator of suspicion used by the Electronic Money Institutions was the suspicion of possible fraud, as well as the use of Money Mules, a trend that it is seen repeatedly highlighted by various sectors. 4 Delivery Methods During 2025 Recognizing the importance of effective collaboration with Obliged Entities and Supervisory Authorities, the Cyprus FIU employs various delivery methods, communicates information, shares strategic insights and provides guidance in order to strengthen this collaboration. These include:
Issuance of strategic Reports: The Cyprus FIU developed and published strategic Reports – Typologies based on the analysis of financial intelligence, reporting trends and sector-specific risk information. Strategic analysis and Typologies developed by the Cy Public Private Collaboration on AML/CFT: A strategic PPP has been set up during 2025, which functions under specific formally agreed Terms of Reference, the Steering Committee of which is headed by the FIU. This PPP- Collaboration is between the FIU, the POLICE and the Cyprus Banks (The Central Bank of Cyprus acts as an observer in this initiative), with the option to extend the participation in specific working groups to other sectors. The PPP initiative has concluded a number of strategic Reports and the work is constantly ongoing within different working groups. Απάτη (περιλαμβανομένης και διαδικτυακής απάτης) /Fraud (including Cyber Fraud) Χρήση Μεταφορέων Χρήματος / Use of Money Mules Αρνητικές πληροφορίες/ Adverse Media Υποβολή Πλαστών Εγγράφων / Submission of fake documentation Συναλλαγές που δεν συνάδουν με το οικονομικό προφίλ του πελάτη /Transactions don’t meet client economic profile Main Money Laundering / TF Suspicion Indicators 2025 - EMIs

Issuance of Annual Report: At the beginning of 2026 the Cyprus FIU published its Annual Report for 2025 in its official website and circulated it to the Competent Authorities and all the Supervisors. The Report contains valuable insight information, typologies, statistical results, priorities, trends, sectorial performance results, overall breakdown of STR/SAR data etc as well as cross border cooperation, geographical areas and asset recovery results, providing thorough feedback and a valuable tool to all the stakeholders, the public sector and the private regulated sector. New Feeback Procedures:

• Indicator-Specific Feedback Reports: At the beginning of year 2026, the Cyprus FIU
  provided feedback to all Obliged Entities and Supervisory Authorities, in the form of a diagram, which shows, in an aggregate way, the indicators which triggered all STRs/ SARs submitted to the FIU by the obliged entities, during the reporting calendar year 2025.
• Direct letters to underperforming Obliged Entities: These communications provide entity￾specific feedback, highlighting identified deficiencies, areas requiring improvement, and the
  corrective actions expected to be implemented within a defined timeframe.
• Direct letters to Supervisory Authorities: Regarding obliged entities falling under their
  supervision or the sector in general, deficiencies identified in reporting, low or non-reporting of the sector.
• Targeted in person meetings with Obliged Entities: Meetings were performed during 2025
  with specific Obliged Entities to discuss the findings of quality reporting deficiencies in specific Reports submitted and provided tailored guidance on compliance with FIU reporting requirements.
• Targeted in person meetings with Supervisory Authorities to discuss general sectorial or
  entity specific, quality reporting issues.
• Specific Dissemination Feedback to Obliged Entities: ALL Reporting Entities are informed
  accordingly by the FIU, in the case intelligence included in the Reports submitted are disseminated to the Law Enforcement Authorities.
• General Annual Feedback: The Cyprus FIU provided General Yearly Feedback for the year
  2025, individually to each Obliged Entity that submitted more than 4 Reports during 2025. Please refer to Appendix 7.3 which sets out the format and structure of the information provided.
• Report Quality Assessment Feedback every four months is to be provided to Supervisory
  Authorities and Obliged Entities which includes a quality assessment on specific predefined report quality measures as per Appendix 7.4.
• Workshops, Webinars, and Training Sessions: Focusing on common reporting weaknesses,
  emerging typologies, and best practices for preparing high-quality Reports. Please refer to
  Appendix 7.2 of this Document for all seminars provided by the FIU during 2025.

5 Developments and Initiatives During 2026
A. Develop the Quality Report Assessment Feature through the goAML The Cyprus FIU has adopted since 01/05/2026, a new framework and feedback procedure for the quality assessment of STRs/SARs submitted by Obliged Entities. As part of this initiative, a set of quality measures and evaluation criteria has been introduced to assess the completeness, relevance, accuracy and overall quality of submitted Reports. Refer to
Appendix 7.4 for the specific quality measures which were communicated also to the Obliged
Entities.
To enhance transparency and support Obliged Entities in meeting reporting quality expectations, thus improving the AML/CFT overall results emanating from the reporting regime, the FIU will provide from 01/05/2026 (over and above the quality assessment results for 2025 disseminated to the Obliged Entities earlier this year), statistical feedback on the quality and performance of submitted Reports based on the predefined criteria as detailed in
Appendix 7.4, at regular intervals.
The implementation of this framework is intended to:
o Support the submission of high-quality Reports containing sufficient and relevant information; o Enhance the effectiveness and efficiency of the FIU's analytical processes; o Facilitate the timely identification and analysis of suspicious activities and transactions; o Strengthen cooperation and communication between the FIU and Obliged Entities; o Improve compliance with reporting obligations as per Guidance Issued to Obliged Entities recently; o Contribute to the overall effectiveness of the Anti-Money Laundering and Counter￾Terrorist Financing (AML/CFT) regime. B. Update Report Indicators - Specific for CASPs and Real Estate Agents The Cyprus FIU, during 2026 updated and enhanced Report Indicators for Crypto Asset Service Providers (CASPs) and Real Estate to ensure alignment on a risk-based approach with current AML/CFT requirements, sector-specific risk profiles, and emerging typologies. The revised indicators will strengthen the FIU’s ability to monitor suspicious activity, support risk assessments, and improve the quality of intelligence and reporting outcomes.
C. Issue Updated and Enriched Guidelines to Obliged Entities
The Cyprus FIU issued during 2026 updated and enriched guidance to Obliged Entities (OEs) to ensure alignment with current AML/CFT requirements, emerging risks, and reporting expectations. The updated guidelines intend to support a better understanding of compliance obligations and improve the quality of Report submissions.

D. Provision of Seminars to ALL Obliged Entities and Sector-Specific Please refer to Appendix 7.2 of this Document. E. Automated Prioritisation Tool During 2026, the FIU developed and implemented an Automated Prioritisation Tool through goAML, building upon and further improving the functionality of the previously used prioritization matrix system, in order to better enhance the assessment and management of Reports received from Obliged Entities. The tool was designed to support predefined risk￾based criteria. Its implementation has contributed to more efficient case handling, improved identification of high-risk Reports, and strengthened the FIU's ability to respond promptly to potential money laundering, terrorist financing, and other financial crime threats. 6 Executive Summary A commendable improvement in the overall quality and effectiveness of reporting has been observed during the reporting period as evident from the assessed factors, the evidently increased number of financial Intelligence disseminations to the LEA by the FIU and the increase in the amounts of frozen Assets, both in domestic cases as well in cases of cross border cooperation, whereby substantial financial information was provided by the FIU, considerable part of which emanated from STR/SARs. This progress is largely attributed to targeted actions undertaken by the FIU, including the enhanced guidance provided to the Obliged Entities, outreach sessions (educational, informational, support meetings) with Obliged Entities, and ongoing engagement with reporting entities including within the AML/CFT Private Public Partnership. These efforts, which have been guided on a risk-based approach basis, have contributed towards a better understanding of risks, reporting obligations, improved clarity in suspicion narratives, and a gradual increase in the overall usefulness of submitted Reports. Notwithstanding these positive developments, further improvement remains necessary. Enhancing the quality and effectiveness of reporting is an ongoing process that requires sustained commitment and continuous effort from all the stakeholders involved. Regarding quantity, the FIU was faced with a considerable increase in the number of Suspicious Transaction Reports (STRs) received from Obliged Entities during 2025. As explained in detailed in this report, a large number of these reports were submitted by Obliged Entities operating under the free provision of services, licensed in the Republic but providing services within the European area.

7 Appendices
7.1 Report Indicators during the period 2024-2025

2025

2024

7.2 Seminars Provided by the FIU During 2025
Date Organisation and Participants Location Subject 28/02/2025 25/06/2025 Police Academy - (Participants: Police Officers) Police Academy AML/CFT Legislation and Asset recovery. 28/05/2025 30/05/2025 05/09/2025 08/09/2025 03/10/2025 09/10/2025 10/10/2025 13/10/2025 14/10/2025 Police Academy - (Participants: Police Officers) Police Academy The prevention and suppression of Money Laundering and Terrorist Financing Laws. 24/9/2025 Real Estate Agents Registration Council of Cyprus - (Participants: Real Estate Agents) GOLDEN BAY HOTEL LARNACA The prevention and suppression of Money Laundering and Terrorist Financing Laws. - Submission of Suspicious Activity and Suspicious Transaction Reports to the Unit 20/11/2025 ACAMS CYPRUS CHAPTER 10th Anniversary Event (Participants: Banks, Designated Non-Financial Businesses and Professions, E-money Institutions) ROYAL HALL NICOSIA Conference marking 10th Anniversary of ACAMS CYPRUS
CHAPTER "A Decade of AML Progress, A Future of Resilience".
Workshop by MOKAS on producing effective, high quality reports.
28/11/2025
CYFA - CYPRUS FIDUCIARY ASSOCIATION
(Participants: Administrative Service
Providers (ASP's) in Cyprus)
CLEOPATRA HOTEL
"When Suspicion Matters: A practical Guide to STRs and Red Flag Indicators"

7.3 General Yearly Feedback for 2025

7.4 Measures of Quality Report Assessment
Topic A/A Quality Measure Assessment Criteria
GENERAL INFORMATION 1
Timeliness of report-Late submission over 1 year Time elapsed between the occurrence of the event, its analysis by the RE and the submission of a Report to the FIU. 2 Timeliness of report-Late submission between 6 months and 1 year Time elapsed between the occurrence of the event, its analysis by the RE and the submission of a Report to the FIU. 3 Incorrect report type selected Appropriate report type selected (STR/SAR) 4 Other Circumstances Other Circumstances PERSONS 5 Missing/Innaccurate Identification details Full name, DOB, nationality, ID details provided 6 Role clarity is insufficient Role clearly defined (subject, beneficiary, signatory, etc.) 7 Missing Core Persons Missing Core Persons ENTITIES 8 Missing/Inaccurate Entity Details Legal name, registration number, jurisdiction provided 9 Missing/Inaccurate Beneficial ownership BO information complete and accurate 10 Missing/Inaccurate Nature of business Business activity and expected behavior described 11 Missing Core Entities ACCOUNTS 12 Missing /Inaccurate Account details Account number, type, currency, status provided 13 Missing Core Accounts Missing Core Accounts 14 Missing/Inaccurate Linkage Clear link between accounts, persons, and entities TRANSACTIONS 15 Missing Core Transactions All relevant suspicious transactions included 16 Missing/inaccurate amounts, dates, currencies Amounts, dates, currencies correctly recorded INDICATORS 17 Non Relevant Indicators selected Indicators selected are applicable to the suspicion and transaction 18 Missing Core Indicators Missing Core Indicators REASON FOR SUSPICION 19 Poor Narrative clarity Clear, structured, and readable narrative 20 Poor Analytical depth Clearly explains why activity is suspicious 21 Insufficient Logical linkage with transactions and indicators Narrative aligns with transactions and indicators 22 Unclear Relevance of suspicion Vs Attachements Attachments directly support the suspicion ATTACHMENTS 23 CDD/Supporting Documentation not provided All relevant attachments are included 24 Insufficient Referencing of attachments in narrative Attachments referenced in the narrative NO QUALITY ISSUES IDENTIFIED 25 No Quality Issues Identified No Quality Issues Identified