Change of Data at the Registrar of Companies for Sanctioned Companies

The Cyprus Registrar of Companies (the “Registrar”) announced on 30 May 2022 that for companies the name of which and/or the name of their shareholders, directors or ultimate beneficial owners (UBOs), are included in the EU and UN sanctions’ lists against Russia and Belarus, the following procedure needs to be applied in relation to submissions of requests for change of data in the records of the Registrar. The procedure is stipulated by the Unit for the Implementation of Sanctions (the “Unit”) of the Ministry of Finance (MOF) of the Republic of Cyprus.

As a first step, an application needs to be filed to the Unit for approval of the change using a specific form (EMEK1), which is available on the website of the MOF. The application must be accompanied by all necessary documentation and information, with a specific reference to the UN Security Council Decision and/or EU Regulation, under which the application is filed.

After examining the application, the Unit will submit to the Minister of Finance a suggestion for approval or rejection of the application. The decision of the Minister will be communicated to the applicant.

If the decision of the Minister is positive, the request for change of data can be filed at the Registrar, together with the approval obtained from the Minister. In case the decision of the Minister is negative or if a positive decision is not submitted together with the request for change of data, the Registrar will not process the request.

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