FiveComply

FiveComply FiveComply assists Investment Firms, Investment Funds, and Payment Institutions in international licensing, establishment, and operations.

It provides expertise in compliance, AML, internal audit, risk management and other related services.

When does a Seychelles Securities Dealer need a separate VASP licence?In her latest article, our colleague Sheila Chua e...
02/09/2026

When does a Seychelles Securities Dealer need a separate VASP licence?

In her latest article, our colleague Sheila Chua explores the regulatory considerations for Securities Dealers looking to expand into virtual asset-related products and services.

From crypto-linked CFDs and stablecoins to cryptocurrency payments and arrangements with third-party VASPs, the article explains why the nature of the activitynot merely the instrument involved—is key to determining the applicable licensing requirements.

The article also considers whether a Securities Dealer and VASP licence can be held by the same entity and highlights the governance, substance, cybersecurity, safeguarding and AML/CFT requirements businesses should consider before expanding into this space.

Read the full article to learn more: https://fivecomply.com/expanding-into-virtual-assets-heres-what-seychelles-securities-dealers-need-to-know/

Something exciting is coming.We can’t reveal too much just yet…Stay tuned. 03.09.2026
28/08/2026

Something exciting is coming.

We can’t reveal too much just yet…

Stay tuned. 03.09.2026

The EU is moving from T+2 to T+1 settlement; meaning securities transactions will generally need to settle one business ...
28/08/2026

The EU is moving from T+2 to T+1 settlement; meaning securities transactions will generally need to settle one business day after the trade date. And no, firms shouldn’t wait until 2027 to prepare.

📅 Two dates to remember:
7 December 2026
New requirements for faster trade allocations & confirmations, with greater use of internationally recognised electronic communication standards.

11 October 2027
T+1 goes live across EU financial markets.

So, what should firms be doing NOW?
• Review trading & settlement processes
• Reduce manual bottlenecks
• Improve automation & standardisation
• Check settlement data & SSIs
• Assess brokers, custodians, vendors & outsourcing providers
• Start end-to-end testing early

Because your firm cannot be T+1 ready in isolation. A weak link anywhere in the settlement chain could mean settlement failures, operational disruption, higher costs and reputational risk.

The takeaway?
2026 is the preparation year.
• 7 December 2026 → Allocations & confirmations
• 11 October 2027 → T+1
⏰ The clock is already ticking.

Need support with the new settlement? Get in touch with our team.
📞 +357 25 34 00 25
📧 [email protected]
🌐 fivecomply.com
📍 Seychelles | Mauritius | Cyprus | UAE

📢 CySEC Publishes Practical Guide on External Whistleblowing in the Financial SectorOn 14 July 2026, the Cyprus Securiti...
27/08/2026

📢 CySEC Publishes Practical Guide on External Whistleblowing in the Financial Sector

On 14 July 2026, the Cyprus Securities and Exchange Commission (CySEC) published a Practical Guide to support the implementation of Circular C608 and the Protection of Persons who Report Breaches of Union and National Law of 2022 (Law 6(I)/2022), as amended. The Guide provides practical clarification on the operation of the external whistleblowing framework within Cyprus' financial sector.

The Guide:
✔️ explains CySEC's role as the competent external reporting authority;
✔️ outlines the external reporting process and applicable timelines;
✔️ identifies who may submit reports, including employees, directors, shareholders, contractors, former employees and job applicants in certain circumstances; and
✔️ provides practical examples of reportable breaches across a broad range of financial services legislation falling within CySEC's supervisory remit.

Although the Guide does not introduce new legal or regulatory obligations, it provides valuable practical insight into how CySEC's external reporting framework operates in practice. It also enhances transparency by clarifying the reporting process, the categories of reportable breaches and the protections available to reporting persons, including confidentiality, personal data protection and protection against retaliation.

Read the full article here:
👉 https://fivecomply.com/cysec-publishes-practical-guide-on-external-whistleblowing-in-the-financial-sector/

📞 +357 25 34 00 25
📧 [email protected]
🌐 fivecomply.com

The Financial Intelligence Unit of Mauritius has issued Supplementary STR Guidance Note 4.1, effective from 19 August 20...
25/08/2026

The Financial Intelligence Unit of Mauritius has issued Supplementary STR Guidance Note 4.1, effective from 19 August 2026, providing an important clarification on STR reporting timelines.
The key point?

Receipt of an internal STR does not, by itself, start the statutory five-working-day reporting period.
The clock begins when the MLRO/DMLRO, following a reasonable preliminary assessment, determines that reasonable grounds for suspicion exist.

Once that threshold is met, the STR should be submitted promptly and without unnecessary delay on the same day where reasonably practicable and in all cases within five working days. The FIU makes it clear that five working days is the maximum permitted period, not the expected reporting timeframe.
Importantly, the preliminary assessment should not become a reason to delay reporting. It should be proportionate and completed within a reasonable timeframe. The MLRO/DMLRO is not expected to conduct an investigation or establish proof of an offence before filing an STR.

For terrorist financing or proliferation financing, the position is even clearer: once reasonable grounds for suspicion are established, reporting should be immediate.

What should Reporting Persons do now?
Review internal STR procedures, establish clear assessment timeframes, ensure direct escalation to the MLRO/DMLRO, and maintain clear records of when concerns were received, assessed, determined and reported.

At FiveComply, we support regulated firms in strengthening their AML/CFT frameworks, STR reporting procedures and regulatory compliance controls.

Need support with your AML framework? Get in touch with our team.
📞 +357 25 34 00 25
📧 [email protected]
🌐 fivecomply.com
📍 Seychelles | Mauritius | Cyprus | UAE

High-quality suspicious reporting is more than a regulatory obligation—it is a cornerstone of an effective AML/CFT frame...
24/08/2026

High-quality suspicious reporting is more than a regulatory obligation—it is a cornerstone of an effective AML/CFT framework.

Through CySEC Circular C781, regulated entities have been informed that MOKAS has issued revised Guidelines on the submission of Suspicious Transaction Reports (STRs), Suspicious Activity Reports (SARs) and Additional Information Files (AIF-A and AIF-T).

The updated Guidelines aim to improve the quality, consistency, accuracy and intelligence value of suspicious reporting by providing sector-specific guidance and enhanced ML/TF indicators.

Key takeaways for obliged entities:
✅ Review and update internal procedures and reporting processes.
✅ Ensure STR and SAR submissions meet the revised quality expectations.
✅ Incorporate the updated guidance into transaction monitoring and staff training.
✅ The revised Guidelines are available to all obliged entities through the goAML web application under the Help menu.
✅ Firms that have not yet registered with the goAML system should complete their registration to ensure they can submit reports to MOKAS in a timely and effective manner.

If you would like assistance aligning your reporting procedures with the revised Guidelines, the FiveComply team is here to help.

📞 +357 25 34 00 25
📧 [email protected]
🌐 fivecomply.com

📍 Seychelles | Mauritius | Cyprus | UAE

The Financial Services Authority of Seychelles has issued the Code of Corporate Governance, introducing enhanced governa...
20/08/2026

The Financial Services Authority of Seychelles has issued the Code of Corporate Governance, introducing enhanced governance expectations, including new expectations around Internal Audit, internal controls and board oversight.

Organisations should review their existing governance arrangements to ensure they align with the requirements under Principle 8: Internal and External Audit.

In our latest article, we highlight some of the key Internal Audit requirements, including:
✔️ Establishment of a dedicated and independent Internal Audit function
✔️ Effective internal control frameworks and annual adequacy assessments
✔️ Alternative assurance arrangements where Internal Audit is not established
✔️ Audit Committee oversight of risk management, internal controls and Internal Audit effectiveness

At FiveComply, we help organisations strengthen their governance frameworks, establish effective internal control environments and implement Internal Audit solutions aligned with regulatory expectations and internationally recognised standards.

📩 If you would like to assess whether your current governance and Internal Audit arrangements meet the expectations of the Seychelles Corporate Governance Code, our team is here to help.
📞 +357 25 34 00 25
📧 [email protected]
🌐 fivecomply.com

📍 Seychelles | Mauritius | Cyprus | UAE

📖 Read the full article on our website:
https://fivecomply.com/meet-the-new-internal-audit-requirements-under-the-seychelles-corporate-governance-code/

A strong AML framework starts with a strong AMLCO.The AMLCO plays a central role in helping firms identify, assess and m...
18/08/2026

A strong AML framework starts with a strong AMLCO.

The AMLCO plays a central role in helping firms identify, assess and manage AML/CFT risks while ensuring ongoing compliance with regulatory requirements.

At FiveComply, we work closely with regulated firms to strengthen their AML frameworks through practical compliance and AML support, independent reviews, training and regulatory guidance.

Here's a quick overview of 11 key responsibilities every AMLCO in a CySEC-regulated firm should be covering.

📩 Need support with your AML framework? Get in touch with our team.
📞 +357 25 34 00 25
📧 [email protected]
🌐 fivecomply.com

📍 Seychelles | Mauritius | Cyprus | UAE

The first half of 2026 has brought a number of significant regulatory developments for Securities Dealers in Seychelles....
13/08/2026

The first half of 2026 has brought a number of significant regulatory developments for Securities Dealers in Seychelles.

Viewed individually, each legislative amendment, regulatory requirement and regulatory communication addressed a specific objective. Viewed collectively, however, they reveal a broader supervisory direction.

At FiveComply, we believe four key themes emerge:
• Corporate Governance – A clear shift towards stronger Board accountability, governance frameworks and risk oversight, reinforced by the new Code of Corporate Governance.
• Operational Substance – The introduction of the Resident Director requirement, Local Complaints Liaison Officer, increased minimum paid-up capital and other reforms reflects a greater focus on meaningful local governance and accountability.
• Proactive Risk Management – SDLs are increasingly expected to identify and assess risks before introducing new products, business practices or technologies.
• Continuous Compliance – Ongoing AML/CFT obligations, FIU registration requirements and enhanced monitoring expectations reinforce that compliance is an ongoing governance responsibility

In our view, the FSA's supervisory approach is evolving beyond technical compliance, placing greater emphasis on governance, effective risk management and demonstrable Board oversight.

Read our full analysis on our website: https://fivecomply.com/what-the-first-half-of-2026-tells-us-about-the-fsa-seychelles-regulatory-priorities/

Do you agree with our assessment? We'd be interested to hear your perspective.
📞 +357 25 34 00 25
📧 [email protected]
🌐 fivecomply.com
📍 Seychelles | Mauritius | Cyprus | UAE

Telemarketing can be an effective way to reach customers—but only when it's done in compliance with the applicable regul...
11/08/2026

Telemarketing can be an effective way to reach customers—but only when it's done in compliance with the applicable regulatory requirements.

The UAE's Capital Market Authority (CMA) (ex. SCA) has established clear rules governing telemarketing activities. Non-compliance can expose firms to regulatory action, financial penalties and reputational damage.

In this infographic, we've highlighted 12 common reportable telemarketing violations that regulated firms should be aware of.

At FiveComply, we help firms build robust compliance frameworks, strengthen their internal controls and navigate evolving regulatory requirements across the UAE and beyond.

📩 If you're unsure whether your telemarketing practices meet the latest requirements, our team is here to help.
📞 +357 25 34 00 25
📧 [email protected]
🌐 fivecomply.com

📍 Seychelles | Mauritius | Cyprus | UAE

Address

Emelle Building, 135 Arch. Makarios III Avenue, Office No. 32, 3rd Floor
Limassol
3021

Opening Hours

Monday 09:00 - 18:00
Tuesday 09:00 - 18:00
Wednesday 09:00 - 18:00
Thursday 09:00 - 18:00
Friday 09:00 - 18:00

Telephone

+35725340025

Website

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