A practical AML and client-fund checklist for Cyprus advocates handling property settlement funds, with the controls regulators expect to see.
As an advocate your AML supervisory authority is the Cyprus Bar Association — under the Advocates Law (Cap. 2) and the AML Law of 2007 — not CySEC. You are an obliged entity: customer due diligence, ongoing monitoring, record-keeping, and reporting suspicion to MOKAS, alongside an absolute prohibition on tipping off.
The client-fund controls a review tests are segregation in a designated client account, matter-level ledgers, regular reconciliation, dual authorisation on payments, segregation of duties, a defined funds flow, and call-back verification of any change to beneficiary details.
A regulated escrow layer moves large settlement balances off your own client account to a licensed provider — with segregation, sanctions and PEP screening, conditional release and a complete audit trail built in — reducing your safeguarding, reconciliation and fraud risk while you keep the legal work. That is what REXE is built to do.
The Cyprus Bar Association is the designated AML supervisory authority for advocates and advocates' firms, under the Advocates Law (Cap. 2) and the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007. It is not CySEC; CySEC supervises a different sector, including investment firms and certain service providers. Advocates report suspicious activity to MOKAS, the Cyprus financial intelligence unit.
Client money must be held separately from the firm's own funds in a designated client account, never used for the firm's purposes, reconciled regularly, and released only on proper authority with a clear record. Regulators also expect dual authorisation on outgoing payments, segregation of duties, defined funds-flow instructions, and a complete audit trail for every receipt and disbursement.
Identify and verify the client and, for corporate clients, the directors, shareholders and ultimate beneficial owners with their shareholding and voting percentages and an ownership-structure chart. Verify identity with certified documents and address with recent evidence, establish source of funds and source of wealth with supporting documentation, screen against sanctions and PEP data, and apply ongoing monitoring throughout the matter.
Yes. Where an advocate knows or reasonably suspects money laundering or terrorist financing, they must report to MOKAS, in practice through the goAML system. Tipping off the client or any third party that a report has been or may be made is a separate criminal offence, so the duty to report sits alongside an absolute duty not to disclose it.
Customer due diligence records and transaction records must generally be retained for at least five years after the end of the business relationship or the completion of the transaction, and made available to the supervisory authority and MOKAS on request.
It moves large settlement sums out of the firm's own client account and into a regulated escrow account held by a licensed provider, with segregation, dual authorisation, sanctions and PEP screening, conditional release against evidence, and a complete, exportable audit trail. The firm keeps control of the legal work while reducing its safeguarding, reconciliation and fraud exposure.
Figures are indicative for 2026 and depend on your circumstances. This is general information, not legal, tax or financial advice — confirm your position with your advocate and tax adviser.