Cyprus implements restrictions on Apostille for documents involving sanctioned companies or companies with Russian interests

Cyprus is a signatory to and has ratified the Convention Abolishing the Requirement of Legalization for Foreign Public Documents (the Hague Convention of 5 October 1961). Under this Convention, legal public documents issued by the Government of Cyprus require an "Apostille" seal to be recognised as legal in foreign countries. The Apostille seal eliminates the need for further legalisation and has proven to be instrumental for the purpose of allowing Cyprus companies to participate efficiently in international transactions.

In line with the country's commitment to upholding the legality of documents pertaining to EU sanctions and Russian interests under the Common Foreign and Security Policy, the Ministry of Interior issued two circulars on 26 and 27 March 2024. According to the circulars, documents submitted for certification of signatures and/or Apostille must be accompanied by a responsible declaration signed by the professional firm representing the concerned companies. This declaration should confirm that any company or individual referenced in the document for certification is not listed in any EU or UN sanctions list, and does not represent Russian interests. Furthermore, the declaration should mention that the individuals (i.e. the Directors, Secretary, Shareholders and/or UBOs) of any company referred to in said document are not included in any EU or UN sanctions list.

While this measure does not seem to reflect any direct commitment under the existing EU sanctions framework to this effect, it aims to reinforce the country’s commitment to combatting any attempts to circumvent EU and UN sanctions and safeguards against the misuse of legal documents in the context of EU and UN sanctions. 

For more information please contact any member of the AML Compliance, Sanctions and Investigations team.