The Cyprus Securities and Exchange Commission has issued a circular (No C204 dated 4 May 2017) to Cyprus Investment Firms it regulates requiring them to review their existing third-country-passports to provide investment and ancillary services and undertake investment activities overseas, and to provide confirmation that all requisite authorisations are in place.
Specifically, they should assess their existing third-country-passports and obtain confirmation from their external lawyers or from the competent authority of the host country, confirming that they hold the appropriate authorisation to carry out the activities they undertake, or that they are exempt from the requirement for authorisation. No later than 31 May 2017 they must send a letter signed by all board members confirming compliance with these requirements, accompanied by a list of all third countries in which they undertake activities, specifying for each country whether legal advice or confirmation from the overseas authority has been obtained. There is no need to submit the relevant supporting evidence with the confirmation, but it must be kept available for inspection if required.
