Cyprus: serving expat and cross-border buyers

Agencies in Cyprus meet more and more buyers who do not fit the standard picture: one citizenship, a second country of residence and money held in a third. This briefing sets out what an agent should establish about such a buyer before taking instructions, and what the rules say about checks. It is written for agencies and developers.

Step one: which rules apply to your buyer

Cypriot law distinguishes citizens of EU and EEA states from non-EU nationals. A non-EU buyer generally needs approval from the Council of Ministers to register title, under the Acquisition of Immovable Property (Aliens) Law. Sources disagree on the details. One May 2026 law-firm summary puts the approval time at about three months, another says two to four weeks. Some sources state a limit of one property for a non-EU buyer, others up to two. Tell buyers that the number and the timing must be confirmed with their lawyer before they pay a reservation.

The picture may change. Four parliamentary proposals were reported as submitted by 2 September 2026. They would limit non-EU buyers to one house or apartment, allow small commercial units, and bar the purchase of forest and agricultural land and property near the ceasefire line (see the report on Sigmalive). No source we read says they have passed. Ask for the buyer's citizenship, not only the country of residence, in the first conversation. As we read it, the law looks at nationality, not residence, so a non-EU passport holder living in the EU is still treated as a non-EU buyer. Confirm that with a lawyer.

What to collect before you take instructions

Treat the file as something a regulator might read later. For each buyer, collect:

• a valid passport or national ID, and the residence permit if the buyer lives outside the country of citizenship
• proof of address no older than a few months, such as a utility bill or bank statement
• the tax identification number in the country of residence, and a Cyprus tax number, which the purchase requires
• marital status and who will appear on the title
• for a company buyer: the certificate of incorporation, the register of directors and shareholders, and the identity of the individuals who ultimately own or control it

Cypriot law firms list the same basics: the buyer provides know-your-client documents and evidence of where the funds come from (see this May 2026 summary of the purchase process).

Source of funds: what a useful file looks like

A bank statement showing a balance is not enough. The file should show where the money came from. Typical evidence:

• salary or business income: payslips, tax returns or company accounts, plus the bank statements where the income arrived
• proceeds of selling another property: the sale contract and the statement showing the receipt
• inheritance or gift: the will, probate or gift document
• a loan: the loan agreement
• savings built over years: statements covering a long period, not a single month

Check that the account holder is the buyer. If someone else will pay, ask why and document the relationship. Treat large cash, sudden transfers from unrelated parties and reluctance to explain as red flags.

What the regulatory framework asks of agents

Cyprus applies its anti-money-laundering law of 2007 and the sanctions law of 2016. Real estate agents must do customer due diligence, keep records and report suspicious transactions to the national financial intelligence unit, MOKAS. A January 2026 article reports that a new supervisory authority for the real estate sector is expected to be fully operational by July 2027, and that the extension of obligations to all real estate professionals is a stated aim (see the Mondaq article). At EU level, the anti-money-laundering regulation, Regulation (EU) 2024/1624, is reported to apply from 10 July 2027 and to treat real estate agents as obliged entities, with customer checks for occasional transactions of at least EUR 10,000. Plan your onboarding for that standard now.

Sanctions screening, done by the book

Screen the buyer, any beneficial owner and any third-party payer against the EU consolidated sanctions list and the other lists your bank or lawyer requires. Under EU guidance, an entity owned or controlled more than 50 percent by a listed person is treated as listed too. Keep a dated record of every check. If a red flag appears, stop, take legal advice and report as the national rules require. Never advise a client on how to avoid a check or how to restructure to get around one.

Russian-speaking buyers are one example. Their nationality is not a reason to refuse the file, and it is not a reason to skip checks. In 2022 the European Commission proposed barring Russian nationals without EU residence from buying EU property; press reports say it did not pass. What matters is the person: whether they or their business are listed, who owns the buying entity, and where the money came from.

Banks apply their own rules. Under Article 5b of Regulation 833/2014, banks may not accept deposits above EUR 100,000 per institution from Russian nationals or residents, but the rule does not apply to nationals of EU or EEA states or to holders of a temporary or permanent residence permit in a Member State (see the Commission FAQ on deposits). Do not apply it yourself; just know that a buyer with an EU residence permit is outside that cap, and that banks may still ask detailed questions.

A short checklist for your team

• ask for citizenship and residence status at the first call, and write them down
• collect identity, address, tax numbers and the status documents before any reservation
• build the source-of-funds file before money moves
• screen every party and payer and keep the record
• tell the buyer early about the Council of Ministers approval if they are non-EU
• put translations and apostilles on a timetable, because they take longer than buyers expect
• keep one person responsible for compliance, even in a small agency

Working with D.H. Realting

D.H. Realting is a trilingual (Russian, English, Polish) overseas-property platform. We introduce buyers, including expats and cross-border buyers, and support the process. Agencies that handle the deal locally and want to be introduced to such buyers can contact us through our partners page.

This briefing is informational only and is not legal, tax or investment advice. Facts were checked on 11 October 2026 from the sources named in the text; rules change, so confirm with a local lawyer before relying on any point.