The House will vote on three bills during a plenary session on Thursday, that include, among other provisions, the establishment of a national sanctions implementation unit.

Some of the bills have been revised multiple times following consultations and parliamentary discussions before reaching their current form.

The sanctions implementation unit, whose creation hinges upon the approval of the first bill, will be established within the Finance Ministry.

It is defined as the competent authority responsible for enforcing the restrictive measures of the European Union, the sanctions imposed by the United Nations Security Council, and the national sanctions imposed by the Republic.

It is also in charge of coordinating the authorities responsible for enforcing sanctions in the country.

This is done following European Union laws, including Council Regulation (EU) No 269/2014 from March 17, 2014, which deals with restrictions related to actions threatening Ukraine’s territory and independence.

It also follows Directive (EU) 2024/1226 from April 24, 2024, which defines criminal offences and penalties for breaking these EU sanctions, updating an earlier directive from 2018.

The second bill, called ‘The Law on Criminalising Breaches of the EU’s Restrictive Measures of 2025’, aims to update the law to match a new EU rule from April 2024.

This rule defines crimes and penalties for breaking the EU’s sanctions and updates an earlier law from 2018.

The third bill, called ‘The Law on Protecting Whistleblowers (Amendment) of 2025’, aims to change the current law that protects people who report violations of EU and national laws, so it follows a specific part of the new EU rule from April 2024.

A representative of the Finance Ministry explained during parliamentary discussions that the responsibilities of the sanctions implementation unit primarily include the application and supervision of the EU’s restrictive measures and the United Nations Security Council’s sanctions relating to economic sanctions.

It also involves coordinating the authorities and state services responsible for applying the sanctions framework in the Republic.

Ensuring common priorities concerning the EU’s restrictive measures between law enforcement authorities and the authorities charged with their enforcement is another key responsibility.

The unit is tasked with collecting information and cooperating with other state authorities and bodies in the Republic and competent foreign authorities, as well as exchanging information with them.

Receiving and submitting reports for which it is designated as the competent authority in the Republic falls under its remit.

The unit may impose administrative fines in cases of failure to respond to requests for information collection.

It also coordinates the identification and tracking of funds and financial resources belonging to designated persons, entities, or bodies.

In addition, the unit prepares reports on its work, statistical reports, and reference reports.

It also issues instructions, circulars, guidelines, clarifications, and guidance for the purposes of implementing sanctions in the Republic.

The same Finance Ministry representative added that in terms of supervisory authorities and the entities they supervise, the bill provides for the retention of powers and responsibilities of supervisory authorities on sanctions matters over supervised entities.

It also defines the obligations of supervised entities concerning sanctions.

Moreover, the bill permits supervisory authorities to impose administrative fines on supervised entities.

There is provision for the exchange of information between supervisory authorities, the sanctions implementation unit, and other competent authorities in the Republic on sanctions matters.

What is more, supervisory authorities may issue instructions or regulations to supervised entities regarding their obligations.

Supervised entities must submit information to the sanctions implementation unit regarding any potential sanctions breaches in the course of their activities.

Concerning the second bill, the Ministry of Finance representative stated that it proposes repealing the ‘Law on the Implementation of the Provisions of United Nations Security Council Resolutions or Decisions (Sanctions) and Decisions and Regulations’ of the Council of the European Union (Restrictive Measures).

The new legal framework it establishes specifically criminalises the disposal of funds or financial resources to designated persons.

It also criminalises failure to freeze funds or financial resources belonging to designated persons in violation of the Union’s restrictive measures. Facilitating the entry of a designated person into the Republic is also criminalised.

The execution of commercial transactions, import, export, sale, purchase, transfer, transit, or movement of goods where prohibition or restriction constitutes an EU restrictive measure is included.

Provision of financial services or engagement in financial activities, when prohibited or restricted under EU restrictive measures, is criminalised.

Furthermore, the bill defines penalties for the related offences and facilitates investigation and prosecution through provisions for cooperation, information exchange, and specific reporting of asset freezes.

Regarding the third bill, the Finance Ministry representative explained that it includes special provisions for the protection of persons who report breaches of the European Union’s restrictive measures.

Representatives from several bodies expressed agreement with the aims and objectives of the bills.

These bodies include the Customs Department, Ministry of Foreign Affairs, and the Department of Registrar of Companies and Intellectual Property under the Ministry of Energy, Commerce and Industry.

Also included were the Cyprus Police, Deputy Ministry of Shipping, the Unit for Combating Money Laundering, the Central Bank of Cyprus, the Office of the Commissioner for Personal Data Protection, and the Cyprus Banking Association.

Representatives of the Cyprus Bar Association, the Cyprus Chamber of Commerce and Industry (Keve), and the Cyprus Employers and Industrialists Federation (Oev) did not disagree with the objectives of the bills.

However, they expressed reservations about specific provisions. They also submitted written memoranda with their suggestions.

The Cyprus Chamber of Commerce and Industry’s comments were focused on the first bill.

It included calls for the issuance of regulatory administrative acts of instructions and regulations of every supervisory and competent authority regarding compliance with existing statutory obligations to ensure their binding effect.

They also called for the possibility of imposing administrative measures by supervisory and competent authorities in cases of non-compliance with regulations or instructions.

Keve highlighted the obligation of the sanctions implementation unit to inform supervisory authorities about every decision it takes concerning the approval or rejection of licence or exemption requests relating to economic and other sanctions or the modification, suspension, and revocation of licences concerning supervised persons under the relevant supervisory authority.

Additionally, the chamber requested the exchange of information between the unit and foreign competent authorities and bodies with similar responsibilities.

They also called for the participation of supervisory authorities in the advisory committee supporting the unit’s work to ensure its autonomous operation.

Furthermore, they proposed increasing the administrative fines foreseen in the bill and making them public for transparency purposes.

Oev’s comments mainly concerned provisions incompatible with the European acquis. They stated that the exclusion of sectoral and thematic sanctions from the scope of the bills.

Furthermore, they criticised the ambiguity and complexity of procedures for granting licences or exemptions regarding sanctions.

Concerns were expressed over the level and proportionality of proposed administrative fines, while questions were also raised regarding the authority of bodies charged with enforcing sanctions and restrictive measures.

Issues of personal data protection in the transmission of information to the unit from obligated entities were also mentioned during the discussion.

The Cyprus Bar Association’s reservations related mainly to the application of the principles of legal certainty and legality and the observance of lawyer-client privilege as derived from the decisions of the European Court of Justice and the European Court of Human Rights of the Council of Europe.

Following these observations and reservations, the committee called on the Finance Ministry to conduct further consultations with stakeholders and, after reviewing their views, to submit revised bill texts if deemed appropriate.

In this context, the Finance Ministry submitted revised texts of the first and second bills, with the final texts deposited on June 12 and May 26, 2025, respectively.

During the committee session on June 16, 2025, the Finance Ministry informed of the need for further minor amendments to the first bill for technical legislative purposes and subsequently submitted a revised text on June 18, 2025.

In the revised text of this bill, amendments were made including provisions concerning the safeguarding of lawyer-client privilege.

It also included the ability of the sanctions implementation unit to examine licence and exemption requests.

The unit must also inform the Foreign Ministry of its decisions on the granting of licences or exemptions concerning economic and other sanctions for which it is the competent authority in the Republic.