Source: UN Security Council Resolutions.

Mechanism: These resolutions are legally binding on all UN member states, including Greece. The EU then implements these resolutions into its own legal framework, making them directly applicable within Greece.

Focus: Target specific individuals (e.g., terrorists, those involved in proliferation of WMDs), entities, or entire regimes (e.g., North Korea, Iran, specific regions).

Obligations: Freezing of funds and economic resources, travel bans, arms embargoes.

Relevance to Crypto: If a UN-sanctioned individual or entity attempts to use or hold virtual assets, those assets are subject to the same freezing and reporting obligations as traditional financial assets.

Source: EU Council Regulations and Decisions.

Mechanism: EU sanctions implement UN resolutions but also include autonomous EU sanctions regimes (e.g., in response to the situation in Ukraine, human rights violations, cyberattacks, terrorism). EU Regulations are directly applicable and binding in their entirety in all member states, without the need for national implementing legislation (though national laws define penalties).

Council Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

Council Regulation (EC) No 2580/2001 on specific restrictive measures directed against certain persons and entities with a view to combating terrorism.

Various specific regulations targeting countries like Syria, Iran, Myanmar, Venezuela, etc.

Obligations: Asset freezes, prohibitions on making funds/economic resources available, trade restrictions (embargoes on goods and technology), travel bans.

Relevance to Crypto: EU sanctions explicitly cover "funds" and "economic resources," which are broad enough to include virtual assets. Recent EU sanctions packages (e.g., related to Russia) have explicitly mentioned crypto assets. VASPs are expected to comply with these restrictions.

Source: U.S. laws and executive orders, administered by the U.S. Department of the Treasury's OFAC.

Mechanism: While primarily U.S. law, OFAC sanctions have significant extraterritorial reach. This is especially relevant for VASPs that:

Deal with U.S. persons (citizens, residents, entities).

Handle transactions denominated in U.S. dollars.

Use U.S.-origin software or technology.

Obligations: Prohibitions on transactions, blocking of assets, reporting requirements.

Relevance to Crypto: OFAC has actively targeted virtual currency mixers, exchanges, and addresses associated with sanctioned entities, illicit finance, and ransomware. Any VASP in Greece with a U.S. nexus or international operations will generally need to screen against OFAC lists (e.g., Specially Designated Nationals and Blocked Persons List - SDN List) to avoid potential secondary sanctions or direct enforcement actions.

EU Anti-Money Laundering Directives (AMLDs): Specifically, the 5th AMLD (Directive (EU) 2018/843) brought VASPs under the scope of AML/CFT regulations. The upcoming MiCA Regulation (Regulation (EU) 2023/1114 on Markets in Crypto-Assets) will further regulate VASPs, including aspects relevant to financial crime compliance.

Greek National Law: Law 4557/2018 (ΦΕΚ Α' 139/30.07.2018) transposed the 4th and 5th AMLDs into Greek law, establishing the legal framework for combating money laundering and terrorist financing for obliged entities, including VASPs. This law designates the Hellenic Financial Intelligence Unit (FIU) as the primary authority for receiving suspicious transaction reports and the Bank of Greece as a supervisory authority for VASPs regarding AML/CFT compliance.

Customer Due Diligence (CDD) / Know Your Customer (KYC): Identify and verify the identity of customers and their beneficial owners.

Sanctions Screening: Screen all customers (new and existing), beneficial owners, and transaction counterparties against relevant sanctions lists (UN, EU, and potentially OFAC). This must be done at onboarding, prior to transactions, and on an ongoing basis.

Asset Freezing: Immediately freeze funds and economic resources (including virtual assets) belonging to or controlled by sanctioned individuals or entities.

Prohibition on Making Funds Available: Do not make any funds or economic resources available, directly or indirectly, to sanctioned individuals or entities.

Report any frozen assets to the relevant Greek authorities (e.g., Hellenic FIU, Bank of Greece) without delay.

Report suspicious transactions (STRs) to the Hellenic FIU if there are grounds to suspect money laundering or terrorist financing, which often involves a sanctions nexus.

Internal Controls: Establish robust internal policies, procedures, risk assessments, and training programs to ensure compliance. Appoint a compliance officer responsible for AML/CFT and sanctions.

Record Keeping: Maintain records of all transactions, CDD documentation, and sanctions screening results for at least five years.

All customers (individual and corporate).

Beneficial owners of corporate customers.

Intermediaries in complex crypto transactions.

UN Consolidated List: Individuals and entities designated by the UN Security Council.

EU Consolidated Financial Sanctions List: This is the primary EU list, combining all individuals and entities targeted by EU asset freeze measures. It is frequently updated.

OFAC Sanctions Lists: Specifically the Specially Designated Nationals (SDN) List, Sectoral Sanctions Identifications List (SSI), and other program-specific lists (e.g., related to cyber, narcotics). While not legally binding under Greek law, screening against OFAC lists is a best practice for international VASPs to mitigate U.S. sanctions risk.

Automated screening solutions are highly recommended given the volume of transactions and the dynamic nature of sanctions lists.

Sanctions lists must be updated frequently (daily is often required or best practice).

A robust "hit management" process is crucial to review potential matches, resolve false positives, and escalate true positives for further action.

Scope: Screening should encompass names, aliases, dates of birth, addresses, passport numbers, and potentially crypto addresses linked to known sanctioned entities, where such information is available and feasible.

Comprehensive Sanctions: Iran, North Korea, Syria, certain regions of Ukraine (e.g., Crimea, Sevastopol, areas of Donetsk and Luhansk, Kherson, Zaporizhzhia).

Targeted Sanctions: Russia (extensive sectoral sanctions, asset freezes on specific individuals/entities), Belarus, Myanmar, Venezuela, Mali, etc.

Implications for Crypto: VASPs must prevent transactions originating from or destined for these jurisdictions, or involving individuals/entities based there, as per the scope of the specific sanctions regime. This often involves geoblocking IP addresses, scrutinizing wallet addresses linked to sanctioned regions, and enhancing CDD for clients with any connection to high-risk or sanctioned areas.

Legal Basis: Greek Law 4557/2018 (Articles 40-45) and other specific laws implementing EU sanctions.

Imprisonment: Individuals (e.g., responsible VASP officers or directors) can face imprisonment for serious breaches, particularly those involving terrorist financing or significant money laundering. Sentences can range from several years up to 10 years or more, depending on the severity and intent.

Fines: Significant criminal fines can be imposed on individuals and legal entities.

Fines: The Hellenic FIU and the Bank of Greece can impose substantial administrative fines on VASPs for non-compliance. These can range from hundreds of thousands to several million euros, or a percentage of the VASP's annual turnover (e.g., up to 10% of total annual turnover for serious breaches), as per AMLD5 requirements.

Withdrawal of Authorization/License: A VASP's operating license in Greece can be suspended or revoked.

Public Censure: Publication of a public statement identifying the VASP and the nature of the breach.

Disqualification: Responsible individuals may be disqualified from holding management positions.

Reputational Damage: Beyond legal penalties, non-compliance can lead to severe reputational damage, loss of customer trust, and difficulties in maintaining banking relationships.

UN Consolidated List: Accessible via the UN website (e.g., https://www.un.org/securitycouncil/sanctions/un-sc-consolidated-list).

Access: The EU Sanctions Map provides a comprehensive overview and access to the consolidated lists: https://www.sanctionsmap.eu/#/main

OFAC Sanctions Lists: For the reasons mentioned above (extraterritorial reach), compliance with OFAC lists is a critical risk mitigation strategy for international VASPs.

Access: The OFAC Sanctions List Search is the primary tool: https://sanctionssearch.ofac.treas.gov/

The SDN List can also be downloaded directly: https://www.treasury.gov/ofac/downloads/sdn.pdf

UN Security Council Sanctions Committees: https://www.un.org/securitycouncil/sanctions/information

EU Sanctions Map (overview and access to consolidated lists): https://www.sanctionsmap.eu/#/main

Council Regulation (EU) No 269/2014 (example of specific sanctions regime, current consolidated version): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0269-20231215

Directive (EU) 2018/843 (5th AMLD, including VASPs): https://eur-lex.europa.eu/eli/dir/2018/843/oj

Regulation (EU) 2023/1114 (MiCA Regulation): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1114

Law 4557/2018 (ΦΕΚ Α' 139/30.07.2018) for AML/CFT and penalties. While a direct, freely accessible English translation URL is hard to provide, its official publication reference is essential. For official Greek gazette (ΦΕΚ) publications, a search on the National Printing Office website (Εθνικό Τυπογραφείο) would be required.

Hellenic Financial Intelligence Unit (FIU): https://www.hellenicfiu.gr/

OFAC Sanctions List Search: https://sanctionssearch.ofac.treas.gov/

Specially Designated Nationals (SDN) List: https://www.treasury.gov/ofac/downloads/sdn.pdf

The European Central Bank (ECB) issued an opinion on 25 August 2022 concerning Greek legislative proposals, indicating that EU-level monetary and financial regulatory oversight extends to Greek financial activities, including those related to digital assets. EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

EU sanctions (restrictive measures) are adopted under Article 29 of the Treaty on European Union (TEU) and implemented through regulations based on Article 215 of the Treaty on the Functioning of the European Union (TFEU), and these apply directly in Greece as a member state. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

The general framework for EU sanctions is established through Council decisions and regulations, creating obligations that Greece, like all EU member states, must implement and enforce. General framework for EU sanctions | EUR-Lex

The European Commission is responsible for monitoring the implementation and enforcement of sanctions regulations by member states, including Greece, and publishes guidance notes and answers to interpretation questions raised by national competent authorities. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

EU sanctions may include freezing of funds and economic resources owned by targeted individuals or entities, restrictions on admission, economic measures such as restrictions on imports and exports, and prohibitions on the export of arms and related equipment — all of which apply to Greek businesses and individuals. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

Council Regulation (EU) No 216/2013 of 7 March 2013 on the electronic publication of the Official Journal of the European Union establishes that as of July 2013, only the electronic edition of the Official Journal published on EUR-Lex is authentic and produces legal effects in Greece and all member states. Access the Official Journal - EUR-Lex

The Official Journal of the European Union comprises two series: L (Legislation) containing EU secondary law including regulations, directives, and decisions; and C (Information and Notices) containing preparatory acts and announcements — both applicable in Greece. Access the Official Journal - EUR-Lex

The legal basis for EU action in Greek financial matters includes Article 191 of the Treaty establishing the European Economic Community and decisions of the Councils of the European Economic Community and the European Atomic Energy Community of 15 September 1958. Access the Official Journal - EUR-Lex

Greece is subject to European Commission oversight on State aid matters, as demonstrated by Commission Decision (EU) 2015/455 of 23 July 2014 concerning State aid SA.34826 (2012/C), SA.36005 (2013/NN) implemented by Greece for Piraeus Bank Group. L_2015080EN.01004901.xml - EUR-Lex - European Union

The Greek financial system has been the subject of EU-level regulatory oversight, including the approval of the 'Greek Banks Support Scheme' by the Commission on 19 November 2008, designed to ensure the stability of the Greek financial system. L_2015080EN.01004901.xml - EUR-Lex - European Union

The Hellenic Financial Stability Fund (HFSF) operates in Greece subject to EU State aid rules, having provided bridge recapitalisations and equity injections to Greek banks with Commission approval. L_2015080EN.01004901.xml - EUR-Lex - European Union

Greece's banking sector restructuring, including the Private Sector Involvement (PSI) programme of February 2012, occurred under EU regulatory oversight and affected the financial landscape in which crypto businesses operate. L_2015080EN.01004901.xml - EUR-Lex - European Union

The European Commission maintains oversight over Greek financial institutions through State aid procedures, as evidenced by the approval of restructuring plans for Greek banks, which demonstrates the broader EU regulatory framework applicable in Greece. Official Journal L 80/2015 - EUR-Lex - European Union

EU restrictive measures, including asset freezes and economic restrictions, are autonomous or implement UN Security Council resolutions, and Greek authorities and businesses must comply with these obligations. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

No specific Greek crypto-asset service provider licensing framework was identified in the provided sources; the sources focus on EU-level frameworks rather than a Greece-specific licensing regime. EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

The EU legal framework described in the sources does not specifically address crypto-asset licensing for Greece, and no Greek entity was identified as having been licensed for crypto activities in the provided source material. Access the Official Journal - EUR-Lex

The sources do not contain information on capital requirements, application processes, or structural requirements for crypto-asset service providers in Greece. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

The ECB opinion of 25 August 2022 addresses Greek legislative proposals but does not specify licensing requirements for crypto-asset activities. EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

No evidence in the provided sources indicates that any crypto-asset service provider has been licensed in Greece. General framework for EU sanctions | EUR-Lex

The Commission Decision (EU) 2015/455 concerning Piraeus Bank relates to banking sector licensing and recapitalisation under State aid rules, not crypto-asset licensing. L_2015080EN.01004901.xml - EUR-Lex - European Union

EU sanctions regulations, which apply in Greece, require member states and their financial institutions to freeze funds and economic resources of targeted individuals and entities, which implies customer due diligence obligations for financial institutions. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

The freezing of funds and economic resources is a mandatory requirement under EU sanctions regimes, and Greek financial institutions must implement procedures to identify and freeze assets of sanctioned parties. General framework for EU sanctions | EUR-Lex

The European Commission supports individuals, businesses, and member states in applying sanctions by publishing guidance notes and answering questions of interpretation raised by national competent authorities, which would include Greek authorities. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

The sources do not contain specific Greek AML/KYC requirements for crypto-asset businesses, including CDD, EDD, STR reporting, record retention, beneficial ownership, or PEP screening requirements. EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

The sources contain no enforcement actions against crypto-asset businesses in Greece. Access the Official Journal - EUR-Lex

Commission Decision (EU) 2015/455 of 23 July 2014 concerned State aid SA.34826 (2012/C) and SA.36005 (2013/NN) implemented by Greece for Piraeus Bank Group relating to recapitalisation and restructuring, and while not a crypto enforcement action, it demonstrates EU oversight of Greek financial institutions. L_2015080EN.01004901.xml - EUR-Lex - European Union

The Commission's formal investigation procedure opened on 27 July 2012 regarding the first bridge recapitalisation of Piraeus Bank represents an example of EU regulatory scrutiny of Greek financial transactions. L_2015080EN.01004901.xml - EUR-Lex - European Union

No penalties, fines, arrests, or cases against crypto businesses in Greece are documented in the provided sources. General framework for EU sanctions | EUR-Lex

No tax guidance has been issued for virtual assets in the provided sourced material. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

The sources do not contain information on how crypto gains are taxed in Greece, whether as income tax, capital gains tax, or VAT treatment. Access the Official Journal - EUR-Lex

No Greek tax authority documentation or guidance on crypto-asset taxation appears in the provided sources. EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

No comprehensive Greek national crypto-asset regulatory framework is identified in the sources, creating uncertainty for businesses operating in the Greek market. Access the Official Journal - EUR-Lex

The sources indicate that Greece relies on EU-level frameworks for financial regulation, and no Greece-specific crypto regulation is documented. EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

Businesses in Greece must navigate EU sanctions obligations that apply directly and can include asset freezes and economic restrictions, without a documented Greek-specific compliance framework for crypto assets. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

The lack of documented Greek regulatory guidance on crypto-asset AML/KYC requirements creates compliance uncertainty for businesses. General framework for EU sanctions | EUR-Lex

No Greek crypto-asset licensing regime is documented in the sources, meaning there are no clear licensing pathways for businesses and no guarantee of legal operation. Access the Official Journal - EUR-Lex

The sources show that EU State aid rules have been applied to Greek financial institutions, but no equivalent framework is documented for crypto-asset businesses. L_2015080EN.01004901.xml - EUR-Lex - European Union

The absence of Greek-specific tax guidance for virtual assets creates uncertainty for crypto businesses regarding their tax obligations. Sanctions (restrictive measures) - EUR-Lex - Europa.eu

While EU sanctions regulations provide some compliance requirements, the sources do not document specific Greek enforcement mechanisms or guidance for crypto-asset service providers. General framework for EU sanctions | EUR-Lex

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

Access the Official Journal - EUR-Lex

Sanctions (restrictive measures) - EUR-Lex - Europa.eu

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

Official Journal L 80/2015 - EUR-Lex - European Union

General framework for EU sanctions | EUR-Lex