Compliance officers often differ regarding what is, and more importantly, what is not, a shell company for the purposes of anti-money laundering compliance. The Central Bank of Cyprus recently issued a Circular on the subject of shell companies and entities, sometimes known in Europe as letterbox companies. Issued on November 2, 2018, the Circular is directed to money laundering compliance officers.
The Circular deserves your attention, not just for the finite nature of the definition of the term, but for the enumeration of "circumstances [that] could indicate economic activity,"specific facts which take a company outside the textbook definition of "no established economic activity in its country of incorporation/registration."
The Circular may be accessed here.
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