Regulatory and Compliance Requirements

Cyprus offers a unique blend of confidentiality and regulatory rigour. While Cyprus International Trusts (CITs) provide substantial privacy and asset protection benefits, they are also subject to strict legal obligations. Horizon Associates ensures all trust structures we coordinate meet the highest compliance standards under Cypriot and international law.

 

Cyprus Beneficial Ownership Register (CyTBOR)

 

Cyprus maintains a Beneficial Ownership Register of Express Trusts and Similar Legal Arrangements (CyTBOR), administered by the Cyprus Securities and Exchange Commission (CySEC). This register became fully operational in May 2022 and aligns with the EU’s 5th Anti-Money Laundering Directive.

 

Key points:

  • All Cyprus International Trusts must be registered in CyTBOR

  • The trustee is responsible for registration, which must occur within 15 days of their appointment

  • The register is not public—only accessible to authorities and persons who demonstrate a legitimate interest

  • The platform was upgraded in March 2025 to enhance compliance and reporting efficiency

 

Disclosure includes:

  • Trust name, jurisdiction, and governing law

  • Full details of trustees, settlors, protectors, and beneficiaries

  • Business or property activity in Cyprus (if applicable)

 

While CyTBOR ensures compliance, it preserves the confidentiality of trust arrangements—data is only visible to competent authorities and vetted third parties under legal provisions.

Trustee Licensing and Regulatory Oversight

Trustees operating in Cyprus must be licensed and comply with the Fiduciaries Law (Law 196(I)/2012). This ensures trustees act with professionalism, integrity, and full accountability.

 

Licensing requirements:

  • Legal entities must hold a CySEC licence to offer trustee services

  • Exemptions apply to regulated lawyers (via the Cyprus Bar Association) and accountants (via ICPAC) acting within their professional capacities

  • Trustees are subject to annual renewals, ongoing CySEC supervision, and strict regulatory standards

 

Mandatory criteria for CITs:

  • At least one trustee must be a permanent Cyprus resident

  • Trustees must maintain fiduciary duties and proper documentation

  • AML compliance and risk-based due diligence are strictly enforced

  • Trustees are required to file relevant reports and notifications with CySEC as needed

 

At Horizon, we work exclusively with licensed trustees, ensuring full compliance from day one.

Accounting and Record-Keeping Standards

Though Cyprus trusts enjoy favourable tax treatment, they are not exempt from financial transparency and documentation rules. Trusts must maintain accurate records and may be subject to audit, depending on the nature and scale of their activities.

Key requirements:

  • Accounting standards: Financial statements must comply with IFRS as adopted by the EU

  • Retention: Trust deeds, records, and documentation must be stored securely for a minimum of six years

  • Transaction records: Every financial activity, distribution, or asset movement must be logged and traceable

  • Trustee minutes, asset valuations, and tax filings must be recorded as part of the trust’s formal governance

 

Audit requirements (if applicable):

  • Trusts with material assets or complex activities may require a statutory audit

  • Audits must be conducted by Cyprus-licensed auditors in accordance with ISA standards

  • Where necessary, annual returns must be submitted to ensure transparency and compliance

 

Even where reporting obligations are minimal, AML law requires that records be complete and verifiable. Horizon ensures that all structures are professionally administered to meet these standards.

Commitment to Regulatory Excellence

Our approach combines global perspective with local compliance. We work exclusively with properly licensed professionals and ensure that every trust we help structure is fully aligned with the laws and obligations of the Republic of Cyprus.

 

If you have any questions about how regulatory requirements may apply to your situation, contact us for a private, no-obligation conversation.