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[null,"Prepared By:","Contributors:"]
[null,"Chrysostomides Advocates & Legal Consultants","Alexandros Georgiades"]
[]
[]
[]
["Lex Mundi Global Anti-Corruption Compliance Guide"]
[]
["Report Generated: 11/19/2025"]
[]
["View your report results on next tab"]

{"sheet":"Lex Mundi Global Anti-Corruptio","index":1,"n_rows":13,"n_cols":2,"rows_kept":13,"cut":false,"hidden":false,"merged":[]}
["Question","Cyprus"]
["Anti-Corruption Compliance"]
["What is the key anti-bribery and corruption legislation in your jurisdiction?"," There is no single piece of anti-bribery and corruption legislation in Cyprus and the relevant provisions relating to public and private corruption can be found in various laws, as set out below. \n\n \n\t The Cyprus Criminal Code Cap. 154 (as amended) \n \n\n Pursuant to section 100 of the Cyprus Criminal Code Cap. 154 (as amended), hereinafter (“ Cap. 154 ”), it is a criminal offense for (a) any person employed in the public service to corruptly ask, receive or obtain or agree to receive or obtain, any property or benefit of any kind for himself or any other person on account of anything done or omitted to be done, or to be afterward done or omitted to be done, by him in the discharge his official duties; or (b) any person to corruptly give, confer, procure, promise or offer to give or confer to, upon, or for any person employed in the public service, or to, upon or for any other person, any property or benefit of any kind on account of any such act or omission on the part of such person employed in the public service.  \n\n S.101 of Cap. 154 prohibits any person employed in the public service from taking or accepting from any person for the performance of his duties any reward beyond his proper pay and emolument, or any promise of such reward. \n\n S. 102 of Cap. 154 prohibits any person employed in the public service from receiving any property or benefit for himself, on the understanding, express or implied, that he shall favor the person giving the property or conferring the benefit or anyone in whom that person is interested, in any transaction then pending, or likely to take place, between the person giving the property or conferring the benefit, or anyone in whom he is interested, and any person employed in the public service. \n\n \n\t The Public Service Law 1/90 (as amended) \n \n\n This law applies to all members of the public service, apart from those that do not fall within the jurisdiction of the Public Service Commission or for whom there is a different provision to any other law. Pursuant to S. 69(1) of the Public Service Law , it is prohibited for civil servants to directly or indirectly receive or give any gifts consisting of monies, other goods, free trips or other personal favors, other than the usual gifts from personal friends or to personal friends. \n\n The Council of Ministers has the power to relax the above prohibition in any specific case where the Council deems the rejection of the gift to be undesirable or contrary to public interest.   \n\n In such case, the civil servant must report the gift immediately to his superior and the gift must be disposed of in the usual manner ( S.69(2) ). There is also a general obligation upon civil servants to notify their superiors of the receipt of any gift offered in exchange for their services or for services to be rendered by them in the course of their duty ( S.69(4) ).  \n\n \n\t The Prevention of Corruption Law, Cap. 161 (as amended) \n \n\n Unlike the aforementioned Cap. 154 and the Public Service Law , the provisions of which are confined to corruption in the public sector in Cyprus,  The Prevention of Corruption Law, Cap. 161 (as amended) hereinafter \" Cap. 161 \" also relates to corruption involving foreign civil servants and employees of international organizations, as well as agents in the private sector. \n\n S.3 of Cap. 161 (as amended) prohibits, inter alia:  \n\n \n\t an agent from corruptly obtaining, directly or indirectly, any gift or consideration, either for himself or for any other person, as an inducement or reward for doing or forbearing to do any act in relation to the affairs or business of his principal (or employer) or for showing or forbearing to show favor or disfavor to any person in relation to his principal’s  affairs or business; and   \n\t any person from corruptly giving, offering or promising, directly or indirectly, any or consideration to any agent as inducement or reward for doing or forbearing to do any act in relation to the affairs or business of his principal (or employer) or for showing or forbearing to show favor or disfavor to any person in relation to the affairs or business of his principal (or employer). \n \n\n There is a presumption of corruption in any proceedings under Cap. 161  if it is proved that any money, gift or other consideration has been paid or given to or received by a person in the employment of the Republic or any other government department or public body, by a person or agent of a person, holding or seeking to obtain a contract with the Republic or any government department or public body. \n\n \n\t The Political Parties Law 175(I)/2012 (as amended) \n \n\n Section 5 of the Political Parties Law of 2012 (175(I)/2012) allows political parties or affiliated organizations to receive lawful private monetary or in-kind contributions, whether named or anonymous and limits the amount a natural or legal person may contribute to a party to EUR 50,000 per year. Private contributions from companies registered under the provisions of the Companies Law or from physical persons are permitted as long as the activities of the companies or persons concerned are not illegal \n\n \n\t Illicit Enrichment of Public Officials and Officers Law 51(I)/2004 \n \n\n Section 3 of the Illicit Enrichment of Public Officials and Officers Law 51(I)/2004 , as amended, criminalizes the offense of illicit acquisition of property (movable and immovable property, including monetary or business earnings, shares, securities, bank deposits and all kinds of securities) by abuse or exploitation of a public official’s or officer’s status or office, whether the benefit is obtained directly or indirectly by the perpetrator or through a family member or a relative thereof up to the third degree of kinship. \n\n \n\t Public Procurement Law \n \n\n Pursuant to Section 56(3)(b) of the Coordination of Procedures of Award of Certain Contracts of Supplies, Works and Provision of Services awarded by Contracting Authorities or Bodies in the Defense and Security Sectors and Related Matters Law of 2011 (173(Ι)/2011) , Section 105(3)(b) of the Regulation of Procedures of Procurement by Entities Operating in the Water, Energy, Transport and Postal Services and Related Matters Law of 2016 (140(I)/2016) , Section 43(3)(b) of the Regulation of Procedures of Award of Concession Contracts and Related Matters Law of 2017 (11(I)/2017) , and Section 91(3)(b) of the Regulation of Procedures of Procurement and Related Matters Law of 2016 (73(I)/2016) , any person that without any lawful authority either personally or through another person or on behalf of another person pursues or attempts to influence the judgment or decision, whether final or not, of any authority, body, committee or any member thereof or any person or official, during the exercise of his/her statutory duties or powers in relation to any procedure, examination, clarification, evaluation, assessment or anything relevant to a process of awarding a contract (under the scope of those specific laws) is criminally liable. \n\n \n\t International Conventions \n \n\n Cyprus is also a member of various anti-corruption conventions including the following conventions which aim at combating, inter alia, both private and public corruption: \n\n \n\t The Criminal Law Convention on Corruption of the Council of Europe and the Additional Protocol to the Convention, as ratified by Laws No. 23(III)/2000 (as amended by Law No. 22(III)/2012 ) and 22(III)/2006 (as amended by Law No. 23(III)/2012 ) respectively;  \n\t The Civil Law Convention on Corruption of the Council of Europe  as ratified by  Law No. 7(III)/2004; and   \n\t The United Nations Convention Against Corruption , ratified by Law No. 25(III)/2008. \n\t  \n \n"]
["Has there been a specific anti-bribery and corruption law enacted in your jurisdiction in the last ten years?"," In addition to the various public procurement laws mentioned above,  the following laws have been enacted in the last ten years: \n\n \n\t Law 22(III)/2012 amending Law 23(III)/2000 ; and \n\t Law 23(III)/2012 amending Law 22(III)/2006 (ratifying laws of  The Criminal Law Convention on Corruption of the Council of Europe and the Additional Protocol to the Convention). \n \n\n \n  \n"]
["Is a bribe payment to domestic government officials prohibited by the legislation?","Yes, a bribe payment to domestic government officials is prohibited by \nCap. 154, \nCap. 161, \nLaw 1/1990, \nLaw 23(III)/2000 (as amended by \nLaw 22(III)/2012), and \nLaw 7(III)/2004.\n"]
["Is a bribe payment to foreign government officials prohibited by the legislation?","Yes, a bribe payment to a foreign government official is prohibited by \nCap. 161 and \nLaw 23(III)/2000 (as amended by \nLaw 22(III)/2012)\n"]
["Is requesting or accepting a bribe prohibited by the legislation?","Yes, requesting or accepting a bribe is prohibited by \nCap. 154, \nCap. 161, \nLaw 1/1990, \nLaw 23(III)/2000 (as amended by \nLaw 22(III)/2012), and\n Law 7(III)/2004.\n"]
["Who is subject to the legislation?","Both natural and legal persons. \nCap. 154 and the \nPublic Service Law are confined to corruption in the Cypriot public sector, while \nCap. 161 and the international conventions ratified also relate to corruption involving foreign civil servants, employees of international organizations, and agents in the private sector. In relation to corruption in the public procurement legislation, evidently it is restricted specifically to the Cypriot public procurement sector and the perpetrators can be any natural and legal persons.\n"]
["Is there criminal liability for corporate entities who have either paid or accepted a bribe payment?","Yes. Under Cyprus law, a company can be prosecuted in a similar way as an individual offender; the \nInterpretation Law, Cap. 1, defines a “person” to include any company, partnership, association, society, institution or body of persons, corporate or unincorporated. Consequently, whenever any statute makes it an offense for a “person” to do or omit to do something, that offense can prima facie be committed by a legal entity as well, unless a contrary intention appears in the statute.\n"]
["What is the penalty for individuals violating the law?"," There are numerous penalties depending on the applicable legal provision, as follows: \n\n \n\t Breach of Section 100 of Cap.154 outlined above entails up to seven years’ imprisonment and/or EUR 100,000 fine and the property of the perpetrator may be subject to confiscation. \n\t Breach of Section 101 of Cap. 154 outlined above entails up to three years’ imprisonment and/or a fine at the discretion of the court. \n\t Breach of Section 102 of Cap. 154 outlined above entails up to two years’ imprisonment and/or a fine at the discretion of the court. \n\t Breach of Section 3 of Cap. 161 outlined above entails up to seven years’ imprisonment and/or EUR 100,000 fine. \n\t Breach of Section 56(3)(b) of the Coordination of Procedures of Award of Certain Contracts of Supplies, Works and Provision of Services Awarded by Contracting Authorities or Bodies in the Defense and Security Sectors and Related Matters Law of 2011 (173(Ι)/2011) outlined above entails up to two years’ imprisonment and/or EUR 10,000 fine, when the information is not classified, or five years’ imprisonment and/or EUR 20,000 fine, when the information is classified. \n\t Breach of Section 105(3)(b) of the Regulation of Procedures of Procurement by Entities Operating in the Water, Energy, Transport and Postal Services and Related Matters Law of 2016 (140(I)/2016) outlined above entails up to up to two years’ imprisonment and/or EUR 4,000 fine. \n\t Breach of Section 43(3)(b) of the Regulation of Procedures of Award of Concession Contracts and Related Matters Law of 2017 (11(I)/2017) outlined above entails up to up to two years’ imprisonment and/or EUR 4,000 fine.  \n\t Breach of Section 91(3)(b) of the Regulation of Procedures of Procurement and Related Matters Law of 2016 (73(I)/2016) outlined above entails up to up to two years’ imprisonment and/or EUR 4,000 fine. \n\t Breach of Section 4 of Law No. 23(III)/2000 (as amended by Law No. 22(III)/2012 ) or Section 5 of Law 22(III)/2006 (as amended by Law No. 23(III)/2012 ) outlined above entails up to seven years’ imprisonment and/or EUR 100,000 fine; Section 8 of the Political Parties Law 175(I)/2012 (as amended), outlined above, prescribes administrative fines of up to EUR 20,000 for infringements of any of the provisions of the same law, which may be imposed by the Registrar of Political Parties (that person is the Director General of the Ministry of the Interior), with the agreement of the Auditor General of the Republic. \n\t Section 3 of the Illicit Enrichment of Public Officials and Officers Law 51(I)/2004 , as amended, outlined above entails up to seven years’ imprisonment and/or EUR 42,715.04, as well as confiscation of the illicitly acquired property. \n\t  \n \n"]
["Assuming corporate entities are liable for violating the legislation, what is the penalty for corporate entities violating the law?","In view of the rules of interpretation mentioned under the reply to \n\"Is there criminal liability for corporate entities who have either paid or accepted a bribe payment?\" above, the same types of sanctions that apply for individuals also apply prima facie to legal entities. However, since imprisonment cannot be imposed on corporate entities, only fines (and/or the payment of compensation) can be imposed. At the same time, there is no obstacle for both the legal entity and the individual offender to be convicted, i.e. both may simultaneously incur criminal liability and, in particular, a director, shareholder or beneficiary may be imprisoned for the same actions that a company is imposed a criminal fine.\nWe further note that, in principle, there is no need to convict the individual offender in order to convict the company. Where there is no explicit provision as to criminal liability, a legal entity may be criminally liable on the basis of vicarious liability or on the basis of the identification doctrine. If the offense is a strict liability offense, the action of an employee/representative of the legal entity is an act of the legal entity. However, where \nmens rea is required,\n it is necessary for the acts and/or omissions to be imputed by a natural person to the legal entity, regardless of whether the natural person himself/herself is prosecuted or not. \n\n\n \n"]
["Assuming corporate entities are liable for violating the legislation, does having a compliance program designed to prevent bribery constitute a defense?","There is no statutory defense pertaining to such compliance programs. However, such compliance programs may be taken into account by the court as a mitigating factor in case of conviction.\n"]
["Assuming corporate entities are liable for violating the anticorruption law, is it possible for a corporate entity to reach a deferred prosecution agreement or leniency agreement with the enforcement authorities?","Cyprus law has no specific provisions regarding plea agreements, settlement agreements, deferred prosecution agreement or leniency agreement. However, the Attorney General of the Republic, pursuant to \nArticle 113 of the \nConstitution of the Republic, has the exclusive prerogative to initiate, continue or discontinue any criminal proceedings at any time prior to the issuance of the Court judgment. We are not aware of any case where the Attorney General has discontinued criminal proceedings relating to the violation of anti-corruption legislation, on the basis of leniency or other agreement with the defendant. \n"]