Well, as regulation evolved, it became apparent that senior managers felt that The Regulations were an issue for the Compliance department, and nothing to do with them. The definition clarifies that if you have a management role, then you have a responsibility.
Short version? If you are in scope, get registered. Pronto. By all means get in touch if you want help or advice. It costs nothing to talk.
While they’re far from perfect, following them, and the guidance that accompanies them, constitutes a defence in court. In short, The Regulations are our friend.
Why are we so seduced by acronyms? During presentations, I often start by describing the field of anti money laundering (AML) compliance as “alphabet soup”. “When in doubt, throw an acronym or two about.” It’s the consultant’s creed.
The Cyprus Investment Program was closed as of November 1st. The government made all the right noises about launching law enforcement investigations.