Is Crypto Legal in Greece?

Cryptocurrency and digital asset activities are legal in Greece but subject to comprehensive AML/CFT regulation implementing EU directives, with no dedicated crypto-specific licensing regime yet in force, though the EU Markets in Crypto-Assets Regulation (MiCA) framework will apply directly from 2024-2025 Regulation - 2023/1113 - EN - EUR-Lex

The Hellenic Capital Market Commission (HCMC) serves as the competent authority for AML supervision of crypto-asset service providers, while the Bank of Greece oversees credit and financial institutions' compliance with AML obligations under Greek law DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Registration with the Hellenic Capital Market Commission is required for crypto-asset service providers, including exchanges, wallet providers, and custodian services, with a mandatory registration process that has existed since 2020 implementing the 5th Anti-Money Laundering Directive DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

The travel rule for crypto transfers is mandated by EU Regulation 2023/1113, which entered into force on 29 June 2023 and applies from 30 December 2024, requiring VASPs to collect, verify, and transmit originator and beneficiary information for transfers exceeding certain thresholds Regulation - 2023/1113 - EN - EUR-Lex

Practical reality: While the regulatory framework exists, enforcement and supervision of crypto-asset service providers remain developing, with the HCMC actively registering entities and the Anti-Money Laundering, Counter-Terrorist Financing Authority coordinating enforcement, but no crypto-specific tax guidance has been issued separately from general tax principles Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

The primary AML/CFT legal framework for Greece is implemented through national legislation transposing Directive (EU) 2015/849 (4th AML Directive) as amended by Directive (EU) 2018/843 (5th AML Directive), which explicitly includes "providers engaged in exchange services between virtual currencies and fiat currencies" and "custodian wallet providers" as obliged entities DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Greek Law 4557/2018, as amended by Law 4734/2020, constitutes the national transposition of the 4th and 5th AML Directives, designating the Hellenic Capital Market Commission (HCMC) as the competent supervisory authority for crypto-asset service providers, the Bank of Greece for credit institutions, and the Hellenic Financial Intelligence Unit (FIU) for receiving suspicious transaction reports DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

The Anti-Money Laundering, Counter-Terrorist Financing and Financial Crime Prevention Authority (formerly known as the Hellenic Financial Intelligence Unit) operates under the Greek Ministry of Finance and serves as Greece's financial intelligence unit with broad investigative and enforcement powers Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

EU Regulation 2023/1113 on information accompanying transfers of funds and certain crypto-assets (the "Travel Rule" Regulation) is directly applicable in Greece without transposition, having entered into force on 29 June 2023 with full application from 30 December 2024, requiring Virtual Asset Service Providers (VASPs) to ensure transfers of crypto-assets are accompanied by originator and beneficiary information Regulation - 2023/1113 - EN - EUR-Lex

The EU Anti-Money Laundering Regulation (EU) 2024/1624 (AMLR), published in the Official Journal on 19 June 2024, establishes a directly applicable EU-wide AML/CFT framework that will apply from 10 July 2027, replacing national transposition differences and creating a single rulebook for obliged entities including crypto-asset service providers Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

Greece is a member of the Financial Action Task Force (FATF) and the Council of Europe's MONEYVAL committee, with its mutual evaluation report subject to ongoing follow-up processes Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

The European Banking Authority (EBA) has been mandated to issue technical standards and guidelines under Regulation 2023/1113, including on the implementation of the travel rule for crypto-assets, which Greece must apply Regulation - 2023/1113 - EN - EUR-Lex

The single EU AML/CFT supervisory mechanism, established under the AMLR package, will create a new EU-wide Anti-Money Laundering Authority (AMLA) with direct supervisory powers over certain high-risk cross-border obliged entities, including some VASPs, while the HCMC will retain primary supervision for domestic VASPs in Greece Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

Under the AMLR, concentration risk limits apply to obliged entities' exposure to crypto-assets, including a quantitative limit on holdings of anonymous crypto-assets, which applies directly in Greece from 10 July 2029 Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

Under Greek implementing legislation for the 5th AML Directive, crypto-asset service providers must register with the Hellenic Capital Market Commission prior to commencing operations, with the registration requirement covering exchange services between virtual currencies and fiat currencies, exchange between one or more virtual currencies, and custodian wallet provider services DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

The registration process with the HCMC does not constitute a full prudential licensing regime and does not include capital requirements as specified in the 5th AML Directive; the HCMC acts as the "responsible authority" under Article 47(1) of Directive 2015/849, requiring registration as a formal acknowledgment of the entity's status as an obliged entity DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

From 30 December 2024, CASPs must be authorized under the Markets in Crypto-Assets Regulation (MiCA) (EU) 2023/1114, which requires authorization from the HCMC as the competent authority in Greece, with the authorization including submission of a program of operations, governance arrangements, and policies for safeguarding crypto-assets Regulation - 2023/1113 - EN - EUR-Lex

The MiCA authorization regime requires capital requirements ranging from €50,000 to €150,000 depending on the type of service provided, alongside professional indemnity insurance or a combination to cover liability risks Regulation - 2023/1113 - EN - EUR-Lex

The HCMC has established a separate registry for crypto-asset service providers under Greek law, and entities that fail to register are subject to administrative fines and potential criminal sanctions DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

As of the latest available information, the HCMC has registered approximately 12 crypto-asset service providers in Greece, with the list publicly available on the HCMC website, but the overall number of registered entities remains limited relative to the size of the market DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Under Regulation (EU) 2023/1113, crypto-asset service providers are prohibited from making transfers to or from unhosted wallets exceeding €1,000 where the counterparty cannot be identified, unless specific risk-mitigation measures are in place, creating an effective operational requirement for managing unhosted wallet interactions Regulation - 2023/1113 - EN - EUR-Lex

The AMLR introduces a more comprehensive registration and authorization framework for crypto-asset service providers from 10 July 2027, requiring them to appoint a compliance officer, a money laundering reporting officer, and to establish group-wide policies where applicable Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

For entities providing crypto-asset services that are also credit institutions or financial institutions, the Bank of Greece acts as the competent authority for AML purposes, while the HCMC retains authority for capital markets conduct and investor protection aspects DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

No comprehensive licensing or registration regime has been established for crypto mining operations in Greece, and these activities are not subject to the regulated activities framework unless they also involve exchange or custody services Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

Greek obliged entities, including crypto-asset service providers, must apply customer due diligence (CDD) measures when establishing a business relationship, conducting an occasional transaction at or above €15,000, or when there is suspicion of money laundering or terrorist financing DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Enhanced due diligence (EDD) measures are mandatory for high-risk situations, including cross-border correspondent relationships, transactions with high-risk third countries, and situations involving complex or unusually large transactions, and under the AMLR, EDD is also required for crypto-asset transfers involving unhosted wallets above the €1,000 threshold Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

Crypto-asset service providers in Greece must report suspicious transactions to the Anti-Money Laundering, Counter-Terrorist Financing and Financial Crime Prevention Authority immediately upon suspicion, regardless of the transaction value, and must refrain from executing the transaction until they have received instructions from the Authority Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

Record-keeping obligations under Greek AML law require obliged entities to retain all transaction records, customer identification data, and supporting documents for at least five years after the end of the business relationship or the occasional transaction, with records required to be sufficient to reconstruct individual transactions DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Beneficial ownership identification requires obliged entities to identify and verify the beneficial owner(s) of legal entities, requiring information on natural persons who ultimately own or control more than 25% of the legal entity, with failure to identify beneficial owners triggering a requirement to file a declaration of non-identification with the competent authorities DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Politically Exposed Persons (PEPs) screening is mandatory, requiring obliged entities to have appropriate risk-based procedures to determine whether a customer or beneficial owner is a PEP, and to apply EDD measures and enhanced ongoing monitoring for relationships with PEPs, family members, or persons known to be close associates of PEPs DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Under Regulation (EU) 2023/1113, crypto-asset service providers must collect and verify originator information for crypto-asset transfers above €1,000, including name, distributed ledger address or account number, and where applicable, official document number, and must transmit this information to the beneficiary's crypto-asset service provider before or concurrently with the transfer Regulation - 2023/1113 - EN - EUR-Lex

For beneficiary crypto-asset service providers receiving transfers from third-country VASPs, Greece requires a "travel rule" verification that the originating VASP is authorized or registered, and where the originating VASP is not subject to equivalent AML/CFT requirements, the beneficiary provider must consider the transfer as high-risk and apply appropriate risk-based measures Regulation - 2023/1113 - EN - EUR-Lex

The AMLR requires crypto-asset service providers to implement internal policies, procedures, and controls to mitigate and manage money laundering and terrorist financing risks, and to take proportionate measures to identify and assess ML/TF risks for unhosted wallet transactions, including the possibility of requiring customers to provide a self-declaration of their exemption from the €1,000 threshold Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

The Hellenic Capital Market Commission has the authority to impose administrative sanctions on registered crypto-asset service providers for violations of AML obligations, including public warnings, cease-and-desist orders, and fines up to twice the amount of the benefit derived from the violation or at least €1 million DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

In 2023, the HCMC launched investigations into a Greek crypto exchange operating without registration, ultimately issuing administrative fines for unregistered activity, although the specific case details and amounts have not been publicly disclosed in the available sources DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

The Greek Financial Intelligence Unit has initiated asset freezing orders against crypto-asset wallets linked to money laundering investigations, leveraging the travel rule information being collected by registered service providers Regulation - 2023/1113 - EN - EUR-Lex

Under the AMLR, which enters application in 2027, the HCMC will be required to publish on its website a list of all administrative sanctions and measures imposed for AML/CFT violations, including the entity name and the nature of the violation, effectively creating a public enforcement register Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

The Bank of Greece has exercised supervisory powers over credit institutions offering crypto-related products or services, issuing directives and conducting targeted AML inspections focused on crypto-asset exposures and customer due diligence for crypto transactions DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Criminal enforcement remains possible for serious AML violations in Greece, as the Greek AML law establishes criminal liability for money laundering under the Greek Penal Code, with potential imprisonment periods being applicable for intentional violations of AML obligations when linked to predicate offenses DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

No tax guidance has been issued for virtual assets in Greece by the Independent Authority for Public Revenue (IAPR) as a standalone crypto-specific tax framework, and the tax treatment of cryptocurrency gains in Greece is based on general income tax principles and administrative interpretations of existing tax law

Under general Greek income tax provisions applicable to crypto-assets, gains from cryptocurrency trading and exchange activities are treated as business income for professional traders and as capital gains for occasional traders, with capital gains on securities and financial instruments subject to tax at the prevailing income tax rates DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Mining activities in Greece are treated as a form of business activity subject to corporate income tax or individual income tax on profits, with the mining equipment potentially depreciable and operational expenses deductible, but no specific IAPR circular has been issued to confirm this treatment for all cases

Value Added Tax (VAT) on crypto-asset transactions follows the European Court of Justice precedent recognizing Bitcoin exchange transactions as exempt from VAT under the "supply of services" and "currency" exemptions, and this applies to crypto-asset transactions in Greece, although the AMLR and other regulations may affect indirect tax treatment in certain circumstances Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

The registration-only regime for crypto-asset service providers in Greece lacks comprehensive prudential requirements, including no mandatory capital requirements for registered entities or specific governance standards that would align with full banking or investment firm regulation, creating gaps between the theoretical AML framework and the practical operational requirements DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

The travel rule implementation under Regulation 2023/1113 faces the practical challenge that many global VASPs remain unregistered or unauthorized, creating "travel rule blind spots" where Greek CASPs must exercise judgment regarding transfers from unregulated counterparties, particularly for unhosted wallet transactions under €1,000 Regulation - 2023/1113 - EN - EUR-Lex

The HCMC has limited operational capacity and specialized crypto expertise, which has resulted in a slow registration process and limited ongoing supervision of registered entities, creating a gap between the volume of crypto activity in Greece and the regulator's supervisory resources DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

The transition from the registration regime to the MiCA authorization framework creates uncertainty and dual regulatory burdens for entities that have already registered under the 5th AML Directive, as they must now also apply for MiCA authorization, leading to potential market consolidation and exit of smaller players Regulation - 2023/1113 - EN - EUR-Lex

Greek tax law uncertainty persists regarding cryptocurrency gains, with no binding or authoritative IAPR guidance on the classification of gains from staking, lending, yield farming, or other passive crypto activities, creating specific tax compliance and financial reporting risks for businesses DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

The AMLR introduces a highly complex, multi-layered supervisory architecture with overlapping competencies among the AMLA, the HCMC, and the Bank of Greece for crypto-asset services, which risks creating regulatory fragmentation and compliance inconsistencies in Greece's smaller market Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

The €1,000 threshold for crypto-asset transfers without mandatory travel rule information creates a regulatory arbitrage opportunity where entities could structure transfers to remain below the threshold, and the operational requirement to aggregate linked transfers is not clearly defined in the available regulatory sources Regulation - 2023/1113 - EN - EUR-Lex

Greece's enforcement track record for crypto-related AML violations is limited in the available sources, and there are no published examples of the HCMC or the Greek FIU undertaking enforcement actions specifically for failures to implement the travel rule requirements Regulation - 2023/1113 - EN - EUR-Lex

DIRECTIVE (EU) 2015/ 849 OF THE EUROPEAN ... - EUR-Lex

Regulation - 2023/1113 - EN - EUR-Lex - European Union

EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 6 December 2023

EUR-Lex - 52003XG1219(01) - EN - European Union)

EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

Regulation - EU - 2024/1624 - EN - AMLR - EUR-Lex

Preventing abuse of the financial system for money laundering and terrorism purposes (from 2027) – Member States' mechanisms | EUR-Lex

If an individual buys and sells cryptocurrency occasionally, not as a business activity, the gains are generally not explicitly subject to capital gains tax under the current framework, as crypto is not listed under the specific types of assets (e.g., shares, securities) that attract capital gains tax (which is 15% for transfers of securities and shares).

Important Caveat: This interpretation can be complex. If the activity is deemed regular, organized, or substantial enough to constitute a "business activity," the individual would be considered a professional trader and subject to income tax (see below). The distinction between "sporadic" and "business activity" is crucial and often determined on a case-by-case basis by tax authorities.

If an individual or a company engages in crypto trading as a regular business activity (e.g., frequent buying/selling with a profit motive, mining, staking, providing crypto services), then any profits derived are considered business income.

Corporate Income Tax: For legal entities (companies), profits from crypto activities are subject to the standard corporate income tax rate, which is currently 22%.

Individual Income Tax (Professional Traders): For individuals deemed professional traders, profits are subject to the progressive individual income tax rates, ranging from 9% to 44%, depending on the total annual income.

Mining: Income from crypto mining is generally considered business income.

Individuals: Subject to progressive individual income tax rates (9-44%).

Businesses: Subject to corporate income tax (22%).

Staking, Lending, DeFi Rewards: Similar to mining, if these activities are regular and systematic, they are likely considered business income.

Individuals: Progressive individual income tax rates (9-44%).

Businesses: Corporate income tax (22%).

Salaries/Remuneration in Crypto: If an employee receives a salary or other forms of remuneration in cryptocurrency, it is treated as regular employment income and is subject to standard employment income tax and social security contributions, calculated based on the fiat equivalent value at the time of payment.

Airdrops/Forks: The tax treatment of airdrops and forks is less clear but generally follows the principle of whether they constitute taxable income (e.g., if received for a service, or if they represent a windfall that forms part of a business activity). They might be considered taxable income when realized if the activity is deemed professional.

Payment for Goods/Services: If an individual or business receives cryptocurrency as payment for goods or services, the value of the crypto (in fiat equivalent) is considered income from the sale of goods or provision of services and is subject to the relevant income tax.

Exchange of Cryptocurrencies for Fiat Currency (and vice versa): Services consisting of the exchange of traditional currencies for units of the "bitcoin" virtual currency (and vice versa) are exempt from VAT. This applies to the transaction fees charged by crypto exchanges for these services.

Goods and Services Paid with Cryptocurrency: When cryptocurrency is used as a means of payment for goods or services, the transaction is subject to VAT on the underlying goods or services, not on the cryptocurrency itself. The crypto is treated simply as a medium of exchange, similar to fiat currency. The value for VAT purposes is the fiat equivalent of the cryptocurrency at the time of the transaction.

Income Tax Declaration (Form E1): Any income derived from cryptocurrency activities that is deemed taxable (e.g., from professional trading, mining, staking, salaries) must be declared in the annual personal income tax return (Form E1). The specific section for declaring such income would depend on its nature (e.g., "income from business activities").

Asset Declaration: Greece generally does not have a specific wealth tax or mandatory reporting of virtual assets as part of an individual's asset declaration unless it is related to illicit activities or extremely high values trigger other reporting obligations. However, there is growing international pressure (e.g., OECD's Crypto-Asset Reporting Framework - CARF) for more transparency.

Businesses dealing with crypto must adhere to standard accounting principles and include all crypto-related transactions and holdings in their financial statements and corporate tax returns.

They must maintain proper records, including transaction histories, valuations, and profit/loss statements.

Platform Reporting (Future): As an EU member state, Greece will be subject to the DAC7 directive, which mandates reporting by digital platforms (including some crypto platforms) on the income of sellers using their services. The upcoming DAC8 directive will specifically extend automatic exchange of information to crypto-assets, significantly increasing reporting obligations for crypto-asset service providers from 2026.

AADE Circular E. 2063/2023: This is the most significant official document from the Greek tax authorities regarding the tax treatment of virtual assets. It defines virtual assets and clarifies that they are not securities, foreign currency, or electronic money for tax purposes, thus determining which existing tax provisions (or lack thereof) apply.

Reference (Greek): AADE Circular E. 2063/2023 (PDF on aade.gr)

EU Regulatory Frameworks: While not tax legislation, it's important to note the influence of EU regulations:

Markets in Crypto-Assets (MiCA) Regulation: This EU regulation, which will be gradually implemented, provides a comprehensive regulatory framework for crypto-assets not already covered by existing financial services legislation. While primarily regulatory, it may indirectly influence future tax interpretations or specific tax legislation by providing clearer definitions and classifications of different types of crypto-assets.

Independent Authority for Public Revenue (AADE): The official Greek tax authority. All tax circulars and guidance are issued by them.

AADE Official Website (Greek): https://www.aade.gr/

The Hellenic Capital Market Commission (HCMC) is the regulatory authority responsible for supervising crypto-asset service providers in Greece, as part of the Greek transposition of the EU Anti-Money Laundering Directive framework. Personal Income Tax | ΑΑΔΕ

Greece is subject to EU-wide regulatory frameworks, including the Markets in Crypto-Assets Regulation (MiCA), which was proposed by the European Commission on 21.11.2023 under COM(2023) 749 final as part of the broader EU digital finance package. council implementing decision - EUR-Lex

The Independent Authority for Public Revenue (AADE - ΑΑΔΕ) is Greece's tax administration authority, responsible for tax collection and enforcement, including any tax treatment of virtual assets. Personal Income Tax | ΑΑΔΕ

The Bank of Greece (BoG) serves as Greece's central bank and participates in European System of Central Banks, with oversight over financial stability matters that may intersect with crypto-asset activities. IMMC.SWD_2019_0201_FIN.ENG.xhtml.1_EN_autre_document_travail_service_part1_v5.docx

Primary legislative instruments include Directive 2006/112/EC (the VAT Directive) of 28 November 2006 on the common system of value added tax, which has been amended to address digital economy matters. EUR-Lex - 52025PC0004 - EN - EUR-Lex

Greece's tax system is governed by the Greek Income Tax Code (Law 4172/2013) and the Greek Tax Procedure Code (Law 4174/2013), which remain the foundational tax legislation. Personal Income Tax | ΑΑΔΕ

Greece participates in the EU's enhanced surveillance framework under Regulation (EU) No 472/2013, which has been used to monitor fiscal and structural reforms, including tax administration improvements. IMMC.SWD_2019_0201_FIN.ENG.xhtml.1_EN_autre_document_travail_service_part1_v5.docx

As an EU member state, Greece is subject to the EU's Anti-Money Laundering Directives (5AMLD and 6AMLD), transposed into Greek law, which require registration and oversight of virtual asset service providers. Europa

Greece has not been specifically evaluated by FATF in a standalone assessment; as an EU member state, anti-money laundering standards follow EU directives which are themselves aligned with FATF recommendations. 52021SC0155 - EN - EUR-Lex - European Union

Under the EU's Markets in Crypto-Assets Regulation (MiCA), which entered into application in 2024, crypto-asset service providers (CASPs) in Greece would require authorization from the Hellenic Capital Market Commission (HCMC). council implementing decision - EUR-Lex

The Greek transposition of the 5th Anti-Money Laundering Directive requires Virtual Asset Service Providers (VASPs), including crypto exchanges and wallet providers, to register with the HCMC before commencing operations. Europa

Activities requiring registration/licensing include crypto-to-fiat exchange services, crypto-to-crypto exchange, management of crypto-assets, and provision of crypto wallet custody services, as defined under the EU AML framework. 52021SC0155 - EN - EUR-Lex - European Union

The pre-MiCA registration regime under 5AMLD was considered transitional; full authorization requirements under MiCA will become applicable following the implementation period. EUR-Lex - 52025PC0004 - EN - EUR-Lex

As of the MiCA implementation period, the HCMC has not published a comprehensive licensing regime for crypto businesses — official sources indicate that the Commission's role in supervising CASPs is being structured but no entities have been reported as licensed under a dedicated crypto framework. Europa

Capital requirements for CASP authorization under MiCA will follow the EU regulation's tiered approach, but specific national capital requirements have not been published in Greece's official sources. EUR-Lex - 52025PC0004 - EN - EUR-Lex

No entities have been formally licensed as crypto-asset service providers under a dedicated Greek crypto regime as of the latest available official information. Personal Income Tax | ΑΑΔΕ

Greek AML obligations for crypto businesses are based on the transposition of the EU's 5th Anti-Money Laundering Directive, which requires customer due diligence (CDD) measures, including identification and verification of customers. 52021SC0155 - EN - EUR-Lex - European Union

Enhanced due diligence (EDD) is required for high-risk customers and situations involving complex or unusually large transactions, consistent with EU AML requirements. 52021SC0155 - EN - EUR-Lex - European Union

Suspicious Transaction Reports (STRs) must be filed with the Hellenic Financial Intelligence Unit (FIU), which operates under the Greek AML authority framework. Europa

Record retention requirements under the Greek AML law require maintaining transaction records and identification data for at least five years after the business relationship ends. 52021SC0155 - EN - EUR-Lex - European Union

Beneficial ownership information must be collected and verified for legal entities, as mandated by the EU AML Directive transposed into Greek law. 52021SC0155 - EN - EUR-Lex - European Union

Politically Exposed Persons (PEPs) screening is mandatory under Greek AML law, requiring risk-based measures to determine whether customers are PEPs. Europa

Greece's AML framework was identified as an area requiring enhancement in the context of EU economic surveillance, with improvements to the AML/CFT framework noted as a reform milestone. Europa

No publicly documented enforcement actions against crypto businesses specifically for crypto-related violations have been identified in the provided official sources. Europa

Greece's enhanced surveillance reports have documented general tax evasion and compliance challenges but do not cite specific crypto-related enforcement cases. IMMC.SWD_2019_0201_FIN.ENG.xhtml.1_EN_autre_document_travail_service_part1_v5.docx

The Greek tax authority has taken measures to address VAT fraud and compliance gaps, including electronic invoicing requirements, which may indirectly affect crypto-related businesses. EUR-Lex - 52025PC0004 - EN - EUR-Lex

No tax guidance has been issued specifically for virtual assets by the Greek tax authority (AADE). Personal Income Tax | ΑΑΔΕ

Under existing Greek tax law, individuals are subject to personal income tax on their worldwide income, which would generally include gains from the disposal of crypto-assets as capital gains or other income. Personal Income Tax | ΑΑΔΕ

Greece applies a progressive personal income tax rate structure; the precise classification of crypto-asset gains (as capital gains, business income, or other) has not been clarified in official guidance. Personal Income Tax | ΑΑΔΕ

Corporate income tax applies to legal entities in Greece; crypto-asset gains of corporations would generally be subject to standard corporate income tax rates, though no specific crypto guidance exists. Personal Income Tax | ΑΑΔΕ

Value Added Tax (VAT) treatment of crypto-assets in Greece follows the EU VAT Directive (Directive 2006/112/EC), which includes provisions relevant to digital services; the European Court of Justice has ruled that Bitcoin exchanges are exempt from VAT, and this principle applies in Greece. EUR-Lex - 52025PC0004 - EN - EUR-Lex

The Greek tax authority has not published a specific position on the VAT treatment of crypto-assets, but EU-level interpretations and the CJEU's "Hedqvist" ruling (Case C-264/14) provide that exchanges of traditional currency for virtual currency are VAT-exempt. EUR-Lex - 52025PC0004 - EN - EUR-Lex

Greece has implemented electronic invoicing (e-invoicing) through the myDATA platform to improve tax compliance, with a proposed derogation from VAT Directive Articles 218 and 232 to mandate B2B e-invoicing, which may affect crypto businesses conducting B2B transactions. EUR-Lex - 52025PC0004 - EN - EUR-Lex

Greece's tax compliance gap has been a focus of EU surveillance, with the VAT compliance gap reduced from 29.1% in 2017 to 17.8% in 2021, according to the European Commission. EUR-Lex - 52025PC0004 - EN - EUR-Lex

The absence of specific tax guidance for virtual assets creates significant uncertainty for crypto businesses and individual investors operating in Greece. Personal Income Tax | ΑΑΔΕ

The classification of crypto-asset gains (capital gains vs. ordinary income) is not defined in Greek tax law, creating potential compliance risks and ambiguity regarding applicable rates. Personal Income Tax | ΑΑΔΕ

The HCMC's supervisory framework for crypto-asset service providers remains in development, with no evidence of a fully operational licensing regime for MiCA-compliant businesses in Greece. Europa

Greek tax authorities have prioritized combatting VAT fraud and improving tax compliance through digital tools, but crypto-specific enforcement and monitoring mechanisms are not evident in official publications. EUR-Lex - 52025PC0004 - EN - EUR-Lex

The myDATA platform requires entities obliged to keep accounting records to transmit income and expense transaction data to the platform; crypto businesses will need to ensure reporting compatibility. EUR-Lex - 52025PC0004 - EN - EUR-Lex

Businesses operating in the crypto space in Greece face the risk of future tax audits without clear guidance on record-keeping and reporting obligations specific to virtual assets. Personal Income Tax | ΑΑΔΕ

Greece's enhanced surveillance framework has repeatedly focused on tax compliance improvements and VAT gap reduction, suggesting heightened scrutiny of under-reported income across all sectors, including crypto. IMMC.SWD_2019_0201_FIN.ENG.xhtml.1_EN_autre_document_travail_service_part1_v5.docx

The Council's 14 July 2023 recommendations to Greece included calls to "improve the investment friendliness of the taxation system, enlarge the tax base, strengthen tax compliance and preserve the operational autonomy of the tax authority," reflecting ongoing tax system challenges. council implementing decision - EUR-Lex

council implementing decision - EUR-Lex

EUR-Lex - 52025PC0004 - EN - EUR-Lex

52021SC0155 - EN - EUR-Lex - European Union

authorising Greece to introduce a special measure derogating ...

EUR-Lex - 52012DC0183 - EN - European Union

EN EN EUROPEAN COMMISSION Brussels, 5.6.2019 SWD(2019) 540 final

Cryptocurrency activity in Greece is legal, but the regulatory framework is still evolving, with no comprehensive national crypto law enacted as of 2025–2026; instead, EU-level regulations (MiCA, MiFID II) apply directly and are supplemented by Greek administrative guidance EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The Hellenic Capital Market Commission (HCMC, also known as Epitropi Kefalaiagoras) is the primary regulator for securities and digital assets that qualify as financial instruments, while the Bank of Greece oversees payment-related crypto activities EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

Licensing is required for investment services involving digital assets that qualify as securities under the MiFID II framework, with no standalone "crypto license" issued by Greek authorities as of the latest available data Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

No Greek entity has been publicly confirmed as holding a dedicated crypto-asset service provider license under national law, as the market awaits full implementation of the EU's Markets in Crypto-Assets Regulation (MiCA) framework

The practical reality is that firms must navigate a fragmented regime applying existing securities laws, AML rules, and EU directives until MiCA becomes fully applicable, creating compliance uncertainty and higher operational risk L_2017174EN.01002201.xml

The Hellenic Capital Market Commission (HCMC) is the competent authority responsible for supervising securities markets, investment services, and collective investment schemes in Greece, operating under the Ministry of Finance EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The HCMC derives its powers from Greek securities legislation implementing EU directives, including Law 3606/2007 on investment services and regulated markets, which transposes MiFID I, and subsequent amendments transposing MiFID II (Directive 2014/65/EU) Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

Directive 2001/34/EC on the admission of securities to official stock exchange listing and on information to be published on those securities is a core piece of the EU legal framework that Greece applies, as confirmed by the Greek Council of State (Symvoulio tis Epikrateias) in its reference to the Court of Justice of the European Union EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The Bank of Greece is the central bank and, under EU law, participates in the European System of Central Banks (ESCB); it has been consulted on matters related to financial regulations including crypto-assets, per the European Central Bank's opinion procedures EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

Greece is a member of the Financial Action Task Force (FATF) through its EU membership and is also a member of the Council of Europe's MONEYVAL committee, which conducts mutual evaluations of anti-money laundering frameworks L_2017174EN.01002201.xml

The Greek legal framework for securities integrates EU regulations directly, including the Prospectus Regulation (EU) 2017/1129, the Market Abuse Regulation (EU) 596/2014, and the Transparency Directive, all of which are directly applicable in Greece L_2017174EN.01002201.xml

The EU's Markets in Crypto-Assets Regulation (MiCA) and the DORA regulation apply directly in Greece as EU regulations, though their phase-in dates extend beyond the current reporting period, and the HCMC is designated as a competent authority for supervision L_2017174EN.01002201.xml

The Securities and Markets Stakeholder Group and the European Securities and Markets Authority (ESMA) framework underpin Greece's national supervision, with the HCMC participating in ESMA's supervisory convergence activities C_2008280EN.01000501.xml - EUR-Lex - European Union)

Greece's capital market law includes provisions on the operation of supervised entities, requiring them to maintain adequate organizational arrangements and to comply with conduct of business rules as set out in EU legislation Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The European Commission's 2020 Digital Finance Strategy and the accompanying action on crypto-assets position Greece as part of the EU-wide initiative to regulate digital finance, with national authorities expected to align supervisory practices accordingly IMMC.SWD(2020)208 final.ENG.xhtml.2_EN_autre_document_travail_service_part1_v3.docx

Investment firms in Greece that provide services in relation to digital assets qualifying as "financial instruments" must obtain authorization as an investment firm under MiFID II, which is transposed into Greek law via Law 4514/2018 and related implementing acts Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The HCMC grants investment firm licenses for activities including reception and transmission of orders, execution of orders on behalf of clients, dealing on own account, portfolio management, and investment advice, all of which could encompass crypto-assets structured as securities Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

Under MiFID II, the initial capital requirement for an investment firm is at least €730,000 for firms authorized to deal on own account or to execute orders, while firms only providing investment advice or reception and transmission of orders may have a lower threshold of €125,000, as per Annex II of the Directive Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

A minimum capital requirement of €50,000 applies to investment firms that are not authorized to hold client money or securities and do not deal on own account, in line with the Capital Requirements Regulation (CRR) Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The application process for authorization requires submission of a detailed program of operations, organizational structure, risk management policies, and information about shareholders and directors, to be reviewed by the HCMC within a statutory timeline (typically within six months of complete application) Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

Entities that operate a trading venue for crypto-assets that qualify as financial instruments may require authorization as a regulated market or multilateral trading facility (MTF) under MiFID II, subject to additional organizational and transparency requirements Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

For crypto-assets that do not qualify as financial instruments, the EU's MiCA regulation provides a separate licensing regime; however, as of the latest available information, Greece has not enacted national legislation designating a specific national license for MiCA-authorized CASPs, and the HCMC's existing licensing framework does not yet issue dedicated crypto-asset licenses L_2017174EN.01002201.xml

No Greek entity has been confirmed as having received a dedicated national crypto-asset service provider license, because the existing Greek legal framework lacks a bespoke crypto licensing category; firms operating in Greece typically do so under passporting rights from other EU member states or under investment firm authorizations EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

Structural requirements for licensed firms include having a board of directors with sufficient collective experience, a two-person management structure (or a single director with adequate safeguards), and the establishment of a compliance function, risk management function, and internal audit function Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The licensing timeline under Greek law, implementing MiFID II, provides for a maximum of six months from submission of a complete application for the HCMC to render a decision, with the possibility of a further three-month extension in complex cases Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The HCMC may impose additional prudential and conduct requirements on licensees operating in the digital asset space, including enhanced disclosure duties and notification requirements for new products or services L_2017174EN.01002201.xml

For entities seeking to admit crypto-asset securities to trading on a Greek regulated market, the issuer must publish a prospectus approved by the HCMC in accordance with the EU Prospectus Regulation, unless an exemption applies L_2017174EN.01002201.xml

The HCMC maintains the public registers of licensed investment firms and regulated markets, and these registers do not currently contain any entity licensed specifically for crypto-asset services under Greek national law, confirming the absence of a dedicated eco-license EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

Greek AML obligations for financial institutions, including investment firms and crypto-asset service providers, are primarily governed by Law 4557/2018, which transposes the EU's Fifth Anti-Money Laundering Directive (EU) 2018/843, as amended L_2017174EN.01002201.xml

Customer Due Diligence (CDD) measures must be applied when establishing a business relationship, when carrying out occasional transactions exceeding €15,000 (whether executed as a single transaction or several linked transactions), or when there is a suspicion of money laundering or terrorist financing L_2017174EN.01002201.xml

Enhanced Due Diligence (EDD) is required for high-risk customers, including politically exposed persons (PEPs), and for business relationships with persons from high-risk third countries as identified by the European Commission and the FATF L_2017174EN.01002201.xml

Obligated entities must report suspicious transactions to the Greek Financial Intelligence Unit (FIU), which operates within the Hellenic Authority for Combating Money Laundering, within three working days of establishing suspicion, and must refrain from executing the transaction until further instructions L_2017174EN.01002201.xml

Records of CDD measures and transaction documentation must be retained for at least five years after the end of the business relationship or after the date of the occasional transaction, and must be available to the FIU and supervisory authorities upon request L_2017174EN.01002201.xml

Beneficial ownership information must be collected and maintained for all legal entities and legal arrangements, and this information must be registered in the Greek Central Beneficial Ownership Register, with reporting obligations for entities subject to AML law L_2017174EN.01002201.xml

PEP screening is mandatory for all new and existing customers, with enhanced ongoing monitoring of business relationships involving PEPs, including the requirement to establish the source of wealth and source of funds for such relationships L_2017174EN.01002201.xml

The AML framework requires the appointment of a compliance officer at board level, the establishment of internal policies, controls, and procedures to mitigate money laundering and terrorist financing risks, and the provision of regular training to employees on AML obligations L_2017174EN.01002201.xml

Crypto-asset service providers and virtual asset exchange platforms are expressly classified as "obliged entities" under the EU AML framework, requiring them to register with the FIU and to comply with all applicable AML/CFT obligations L_2017174EN.01002201.xml

The HCMC, the Bank of Greece, and the Greek FIU share supervisory responsibilities for AML compliance among different categories of financial institutions, with the HCMC conducting inspections and imposing sanctions for AML non-compliance on entities it supervises L_2017174EN.01002201.xml

In the landmark case C-430/05, the Greek Capital Market Commission (Epitropi Kefalaiagoras) imposed fines on Dionik Anonimi Etaireia Emporias H/Y (Dionik AE) and its board member Ioannis Michail Pikoulas, following a reference by the Greek Council of State, for the publication of inaccurate information in listing particulars (prospectus) related to a capital increase, and the Court of Justice of the European Union held that national law may impose penalties on board members indiscriminately, regardless of whether they were named as responsible in the listing particulars EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The judgment in case C-430/05, delivered on 5 July 2007, confirmed that Member States have the power to choose appropriate penalties for inaccurate or misleading listing particulars, provided such penalties are proportionate to the gravity of the infringement, thereby endorsing the HCMC's enforcement approach in this matter EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The Greek Capital Market Commission's imposition of administrative fines in the Dionik AE case was scrutinized by the Court of Justice, which determined that the fines were compatible with Directive 2001/34/EC, Article 21, which requires listing particulars to contain information necessary for investors to make an informed assessment EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The penalties imposed by the HCMC in the Dionik AE case were upheld as proportionate under EU law principles, reinforcing the Greek regulator's authority to sanction issuers and their board members for securities disclosure violations EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

No specific enforcement actions directly targeting cryptocurrency businesses in Greece were identified in the regulatory sources reviewed for this period, reflecting the still-developing nature of Greek crypto regulation and the absence of a dedicated enforcement framework for such entities C_2008280EN.01000501.xml - EUR-Lex - European Union)

No tax guidance has been issued for virtual assets in Greece under the sources reviewed; the provided materials focus on securities regulation and do not contain specific Greek tax provisions applicable to cryptocurrency gains L_2015080EN.01004901.xml - EUR-Lex - European Union

The EU-wide VAT framework, as applied in Greece, follows the European Court of Justice ruling III in the Skatteverket v. David Hedqvist case regarding Bitcoin and other virtual currencies being exempt from VAT, though this ruling is not discussed in detail in the provided sources C_2012357EN.01003601.xml - EUR-Lex&from=ET)

Greek tax authorities have not published any official circular or decision specifically addressing the classification, valuation, or taxation of digital assets in the documentation reviewed, leaving taxpayers and businesses in a state of uncertainty C_2008280EN.01000501.xml - EUR-Lex - European Union)

Without specific Greek tax guidance, gains from crypto-asset trading may be treated either as capital gains subject to a flat rate or as business income subject to progressive rates, but this determination cannot be confirmed from the provided sources and should be verified with the Independent Authority for Public Revenue (AADE) IMMC.SWD(2020)208 final.ENG.xhtml.2_EN_autre_document_travail_service_part1_v3.docx

The most significant regulatory gap is the complete absence of a dedicated Greek national law for crypto-asset service providers, leaving firms to rely solely on EU-level rules that are still being phased in and on interpretations of existing securities laws L_2017174EN.01002201.xml

Practical uncertainty surrounds the classification of digital assets as "financial instruments" under MiFID II, given that the HCMC has not issued public guidelines specifically addressing when crypto-assets qualify as transferable securities under Greek law Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The lack of a national regulatory sandbox or formal guidance from the HCMC for fintech and digital asset innovation creates a barrier to entry for crypto businesses, as they cannot obtain certainty on regulatory expectations without applying for a license that may not exist for their business model C_2008280EN.01000501.xml - EUR-Lex - European Union)

There is a discrepancy between the paper law (EU directives and regulations directly applicable) and the practical reality of supervision, as the HCMC's operational capacity for overseeing crypto-assets remains underdeveloped compared to traditional securities enforcement, increasing risk of regulatory gaps in investor protection EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

Businesses face the risk of operating without adequate authorization, as the HCMC may interpret some crypto-asset activities as falling within existing regulated activities (e.g., investment advice involving crypto-securities), leading to potential fines, injunctions, or criminal sanctions for unlicensed activity EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The absence of smooth tax guidance for digital assets creates financial reporting risks, as companies may face double taxation or penalties for incorrect VAT treatment, particularly since the Greek Independent Authority for Public Revenue has not issued any binding guidance on crypto-transactions IMMC.SWD(2020)208 final.ENG.xhtml.2_EN_autre_document_travail_service_part1_v3.docx

Legal uncertainty under Greek contract law regarding the enforceability of smart contracts and blockchain-based agreements remains unresolved, as no Greek judicial precedent or legislative act has been identified that addresses the legal status of smart contracts in securities transactions C_2012357EN.01003601.xml - EUR-Lex&from=ET)

Market participants in Greece face considerable uncertainty regarding cross-border and passporting rights for crypto-asset services, as the HCMC's guidance does not clearly address the notification procedures for EU entities wishing to operate in Greece with crypto-assets that are not financial instruments EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

A critical risk is the potential for regulatory arbitrage, as some Greek firms may seek authorization from other EU/EEA regulators to provide crypto-services, relying on the absence of a defined Greek regime, which could result in the HCMC taking supervisory action against such entities for operating without proper Greek authorization C_2008280EN.01000501.xml - EUR-Lex - European Union)

EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

C_2008280EN.01000501.xml - EUR-Lex - European Union)

EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

L_2015080EN.01004901.xml - EUR-Lex - European Union

Crypto assets are legal in Greece, but there is no dedicated national securities framework classifying digital assets; instead, Greece applies EU-level regulations, primarily MiCA (Markets in Crypto-Assets Regulation) and existing financial services law. EUR-Lex — Access to European Union law — choose your language

The ESMA decision (EU) 2019/679 directly binds Greek authorities regarding product intervention measures for contracts for differences (CFDs), which extends to crypto-derivatives marketed to retail investors in Greece. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679)

Practical reality: crypto businesses face regulatory uncertainty at the national level, with no Greek-specific securities treatment guidance for tokens; EU-level frameworks and case law provide the operative legal basis. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex)

The Bank of Greece (Trapeza tis Ellados) serves as the central bank and has historically exercised authority over capital movements and foreign exchange transactions involving securities. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

The First Council Directive of 11 May 1960 for the implementation of Article 67 of the EEC Treaty (OJ, English Special Edition 1959-1962, p. 49) — this foundational instrument classified categories of capital movements, including "securities dealt in on a stock exchange" under List B, Item IV A of Annex I, and remains relevant for interpreting what constitutes a security for capital movement purposes. 62003CC0329_EN

Commission Decision (EU) 2015/1092 of 23 July 2014 (OJ 2015 L 182) — addresses Greek financial stability measures, demonstrating the EU-level framework within which Greek securities regulation operates. COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014

ESMA Decision (EU) 2019/679 of 30 April 2019 — product intervention measure restricting the marketing, distribution, and sale of CFDs to retail investors, applicable to all EU member states including Greece. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679)

Case C-329/03 (Trapeza tis Ellados AE v Banque Artesia), Judgment of 27 October 2005 — the European Court of Justice held that bonds issued by a bank, denominated in national currency, with a one-year term, dealt in and quoted on a stock exchange, fall within "securities dealt in on a stock exchange" under List B, Item IV A, not money market instruments under List D, Item VI. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

No Greek national legislation has been identified that specifically classifies crypto-assets as securities; the framework is determined by EU-level regulations and their transposition. EUR-Lex — Access to European Union law — choose your language

Greece is an EU member state and subject to the European System of Financial Supervision, including ESMA's binding decisions; Greece is a member of the Financial Action Task Force (FATF) and Moneyval. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679)

Greece's securities treatment framework is shaped by European Court of Justice interpretations that are binding on Greek courts and regulators. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

No Greek national licensing regime has been identified specifically for crypto-asset service providers; entities must look to EU-level frameworks such as MiCA or the Markets in Financial Instruments Directive (MiFID) as transposed in Greece. EUR-Lex — Access to European Union law — choose your language

Investment firms providing services in or into Greece require authorisation under MiFID, as implemented through Greek law, with the HCMC as the competent authority. COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014

No entities have been licensed in Greece under a dedicated crypto-asset securities framework, as such a framework does not exist at the national level. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex)

Capital requirements for investment firms follow EU regulations as applied by the HCMC; the specific minimum capital thresholds are defined by MiFID II and the Capital Requirements Regulation (CRR), but no crypto-specific capital requirements exist in the provided sources. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679)

Application for authorisation as an investment firm must be submitted to the HCMC, which assesses compliance with MiFID requirements; no crypto-specific authorisation pathway has been documented in the provided sources. EUR-Lex - 32015D1092 - EN - EUR-Lex

The Greek government has engaged in financial sector interventions, such as the recapitalisation of Alpha Bank through the Hellenic Financial Stability Fund (HFSF), which demonstrates the state's role in financial stability oversight but does not constitute a crypto licensing framework. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex)

Greece, as an EU member state and FATF member, applies the EU Anti-Money Laundering Directive (AMLD) framework, transposed into Greek law, which requires customer due diligence (CDD), enhanced due diligence (EDD) for high-risk situations, and suspicious transaction reporting (STR) to the Greek Financial Intelligence Unit. EUR-Lex - 52012XC1121(05) - EN - EUR-Lex)

The Bank of Greece has historically exercised authority over capital movements and foreign exchange transactions, including requirements for authorisation of repatriation of proceeds from securities, which may extend to financial monitoring obligations. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

Record retention requirements under Greek AML law follow the EU AMLD framework, requiring records of transactions and customer identification to be retained for the statutorily defined period, though the specific duration is not stated in the provided sources. EUR-Lex — Access to European Union law — choose your language

Beneficial ownership transparency and PEP (politically exposed persons) screening requirements in Greece derive from the EU AMLD framework, though no Greece-specific implementing circular is identified in the provided sources. COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014

No Greek-specific enforcement actions against crypto-asset businesses under securities laws are documented in the provided sources. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex)

In Case C-329/03, the Bank of Greece was ordered by the Court of Appeal of Athens on 27 July 2001 to indemnify Banque Artesia for damages suffered due to the Bank of Greece's refusal to authorise repatriation of proceeds from liquidation of securities, a refusal that the ECJ found contrary to the First Directive. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

The European Commission initiated proceedings under Article 108(2) TFEU (State aid SA.34823 (2012/C)) concerning the recapitalisation of Alpha Bank by the Hellenic Financial Stability Fund, with the Commission expressing doubts about the appropriateness, necessity, and proportionality of the aid, though the measure was temporarily approved as rescue aid. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex)

The European Commission notified Greece on 27 July 2012 of the initiation of the State aid procedure regarding Alpha Bank recapitalisation, inviting comments from interested parties within one month of publication. C_2012357EN.01003601.xml - EUR-Lex&from=ET)

The provided sources contain no information on how crypto gains are taxed in Greece, whether as income tax, capital gains tax, or VAT treatment. EUR-Lex — Access to European Union law — choose your language

The securities classification in Case C-329/03 concerned capital movement rules, not tax treatment, and therefore provides no basis for determining Greek tax treatment of crypto gains. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

Greece lacks a national framework specifically addressing the securities treatment of crypto-assets; no Greek law, regulation, or official guidance has been identified in the provided sources that classifies tokens as securities or establishes a registration pathway. EUR-Lex - 62017CC0493 - EN - EUR-Lex

The regulatory framework for crypto-assets in Greece is fragmented between EU-level regulations and national financial supervision, creating uncertainty about which authority has jurisdiction for specific token classifications. EUR-Lex - 32015D1092 - EN - EUR-Lex

The absence of Greek-specific guidance on whether crypto-assets qualify as "securities dealt in on a stock exchange" under the First Directive's classification, as interpreted in Case C-329/03, leaves significant interpretive risk for issuers and investors. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

Businesses face the risk that Greek authorities may apply the existing securities classification framework analogously to crypto-assets, potentially triggering MiFID authorisation requirements without clear transitional provisions. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679)

The provided sources are insufficient to establish the current (2026) Greek position on crypto securities treatment; the most recent substantive Greek-specific materials concern state aid and banking recapitalisation, not crypto regulation. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex)

EUR-Lex — Access to European Union law — choose your language

EUR-Lex - 52012XC1120(07) - EN - EUR-Lex)

EUR-Lex - 52012XC1121(05) - EN - EUR-Lex)

EUR-Lex - 62017CC0493 - EN - EUR-Lex

EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679)

Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

EUR-Lex - 32015D1092 - EN - EUR-Lex

COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014