THE ESTABLISHMENT OF THE NATIONAL SANCTIONS IMPLEMENTATION UNIT (NSIU)

The establishment of the National Sanctions Implementation Unit (NSIU) with the Greek acronym: EMEK,  through The Law on the Establishment of the NSIU (L.150 (I) 2025  with effect as of 25th July 2025, constitutes a major development in Cyprus’ sanctions legal framework.

The House of Representatives plenary approved the "National Sanctions Implementation Unit Law" (NSIU). Statements emphasized Cyprus’ commitment to high international and EU standards, enhanced protection of the financial system, and strengthened mechanisms to prevent and penalize sanctions evasion.

The formation of the NSIU was supported by three legal instruments:

• The Law on the Establishment of the NSIU

• The Law criminalizing violations of EU restrictive measures

• An amendment to the Law on the Protection of Persons Reporting Violations of EU and National Law

The broad powers of the NSIU include among others:

• Investigating suspected violations of national, EU and UN sanctions and imposing administrative fines (up to €100,000 plus €100 per each day for non-compliance)

• Reviewing applications and issuing sanctions-related licences and exemptions

• Issuing binding directives, circulars and guidance

• Coordinating enforcement efforts across local regulatory and law enforcement authorities

• Collecting and exchanging information with local and foreign authorities 

• Freezing assets

Individuals and legal entities have the obligation to report to the NSIU of funds or assets belonging or controlled by sanctioned persons and designated persons listed in EU sanctions have the obligation to disclose to the NSIU all funds and assets owned or controlled.

Non-compliance with the above, gives the right to NSIU to impose administrative sanctions which may have potential criminal liability.

The NSIU is expected to be fully operational by the end of 2025.

How MPC can assist

MPC Legal closely monitors the developments relating to EU sanctions and may assist with the evaluation of the application of the new framework, provide tailored advice and prepare, submit and monitor relevant applications to the NSIU.