Greece -- Sanctions Compliance Regulatory Overview

Executive Summary

Crypto activity in Greece is legal but operates under EU-wide frameworks rather than a comprehensive national crypto-specific law. The primary regulators are the Bank of Greece and the Hellenic Capital Market Commission (HCMC), with the Greek Financial Intelligence Unit (FIU) overseeing AML compliance. Greece is subject to EU sanctions regimes adopted under the Common Foreign and Security Policy (CFSP), which are implemented through EU regulations with direct effect in all member states. No Greek entity has yet been granted a full crypto-asset service provider license under the Markets in Crypto-Assets Regulation (MiCA) framework, as the regulatory infrastructure is still being established. The practical reality is that businesses must navigate EU-level obligations transposed into Greek law while awaiting full implementation of MiCA at the national level.

Regulatory Framework

• 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

Licensing Requirements

• 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

AML/KYC Requirements

• 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

Enforcement Actions

• 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

Tax Treatment

• 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

Key Gaps & Risks

• 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

Sources

• 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