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GOVERNMENT GAZETTE OF THE HELLENIC REPUBLI C
LAW 3691/2008
5 August 2008

Prevention and suppression of money laundering and terrorist
financing and other provisions

CHAPTER Α
Purpose, subject m atter, predicate offences, definitions, obligated
persons

Article 1
Purpose
This Law a ims at reinf orcing and im proving the legislative fram ework on the
prevention and suppression of m oney launde ring and terrorist financing. To this
end, it transposes into legi slation the provisions of Directive 2005/60/E C of the
European Parliam ent and of the Council “on the prevention of the use of the
financial system for the purpose of m oney laundering and terrorist financing”
(Official Journal of the European Union L 309/15/25.11.2005) and certain
provisions of Directive 2006/70/EC of th e European Commission (Official Journal
of the European Union L 214/29/4.8.2006) a nd replaces relevant provisions of La w
2331/1995 (Governm ent Gazette 173 Α), as curr ently in f orce.

Article 2
Subject ma tter
1. The subject m atter of this law is the prevention and suppression of m oney
laundering and terrorist financi ng, as defined below, as we ll as the protection of the
financial system from the risk s entailed by such o ffences.
2. The following conduct shall be rega rded as m oney laundering, i.e.
legalisation of proceeds from the crim inal activities listed in Article 3:
a) the conversion or transfer of property, knowing that such property is derived
from crim inal ac tiv ity o r from an act of participation in cr im inal activity, f or th e
purpose of concealing or disguising the illicit origin of the property o r of assisting
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any person involved in the comm ission of such activity to evade the legal
consequences of his action;
b) the concealm ent or dis guise of the truth, with any m anner or m eans, as it
concerns the dispos ition, m ove ment, use or the place w here the p roperty was
acquired or is at present, or the ownership of the property or right s with re spect to it,
knowing that such property is derived from c rim inal activity or from an act of
participa tion in such ac tivity;
c) the acquisition, possession, adm inistra tion or use of property, knowing, at
the tim e of rece ipt or administr atio n, that such property was derived from crim inal
activ ity o r from an act of participa tio n in such ac tivity ;
d) the utilization of the financial sect or by placing therein or moving through it
proceeds fro m crim inal activ ities for the purpose of lending false legitim acy to such
proceeds ;
e) the setting up of organisation or gr oup com prising two pers ons at lea st, for
comm itting one or m ore of the acts defined abo ve under a to d and the participation
in such organisation or group.

3. Money laundering shall be regarded as such even where the activ ities which
generated the property to be laundered were carried out in the territory of another
country, pro vided that th ey would be a predicate offe nce if committed in Greece and
are punish ab le acco rding to the law of such other country.

4. Terrorist financing is th e offence defined in paragr aph 6 of in Article 187A
of the Penal Code, as amended by paragraph 1 of Article 53 hereof.

5. Knowledge, intent or purpose required as an elem ent o f the activities
mentioned in paragraphs 2 and 3 m ay be inferred from objective factual
circum stances.

Article 3
Criminal a ctiv ities – Pre dicate o ffen ces
“Crim inal activ ities” sh all deno te the comm iss ion of one or m ore of the following
offences (hereinafter ref erred to as “predicate offences”):
a) participation in an organized crim inal group (Article 187 of the Penal Code);
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b) terrorist activities and terrorist fi nancing (Article 187A of the Penal Code);
c) passive bribery (Article 235 of the Penal Code);
d) activ e brib ery (Artic le 236 of the Penal Code);
e) bribery of judges (Artic le 237 of the Penal Code);
f) trafficking in hum an beings (A rticle 323A of the Penal Code);
g) com puter fraud (Article 386A of the Penal Code);
h) sexual exploitation (Artic le 351 of the Penal Code);
i) the offences provided for in Ar ticles 20, 21, 22 and 23 of Law 3459/2006 re:
“Codified Law on narcotic drugs” (Governm ent Gazette 103 A);
j) the offences provided for in Articles 15 and 17 of La w 2168/1993 re:
“W eapons, ammunition, explosiv es etc.” (Govern ment Gazette 147 Α);
k) the of fences provided for in A rticles 53, 54, 55, 61 and 63 of Law 3028/2002
re: “Protection of antiqu ities and cultur al heritage in general” (Government
Gazette 153 A);
l) the offences provided for in Article 8, paragraphs 1 and 3, of Legislati
ve
Decree 181/1974 re: “Protection from ionised radiation” (Governm ent
Gazette 347 A);
m) the offences provided for in Ar ticle 87, paragraphs 5, 6, 7, and 8, and Article
88 of Law 3386/2005 re: “Entry, residenc e and social integration of non-
citizens on Greek territory” (Governm ent Gazette 212 A);
n) the offences provided for in the third, fourth and sixth Articles of Law

2803/2000 re: “Protection of the financ ial interests of the European
Communitie s” (Govern ment Gazette 48 A);
o) bribery of a foreign civil servant and facilitation or concealm ent of the
comm ission of such cri me, as provi ded for in Articles 2 of Law 2656/1998 :
“Ratification of the Conve ntion on Bribery of Fore ign Public Officials in
inte rnational business tra nsacti ons” (Governm ent Gazette 265 A);
p) bribery of em ployees of the Europ ean Communities or of the European
Union Member States, as provided fo r: a) in Artic les 2, 3, and 4 of the
Treaty on Com bating bribery of employees of the European Union or of
European Union Mem ber States, w hich was ra tif ied by th e f irst a rticle of
Law 2802/2000 (Governm ent Gazette 47 A) and b) in the third and fourth
article of Law 2802/2000;
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q) the offences provided for in Articles 29 and 30 of La w 3340/2005 re:
“Protec tion of the capita l m arket f rom actions by persons holding privileged
inform ation and from actions of m arket m anipulation” (Governm ent Gazette
112 A);
r) any other offence punishable by depr ivation of liberty for a m inim um of
more than six m onths and having gene rated any type of econom ic benefit.

Article 4
Definitions
For the purp oses of this Law, the following definitions shall apply:
1. “Property”: assets of every kind, wh ether corporeal or incorporeal, m ovable
or imm ovable, tangible or intangible, a nd docum ents or instrum ents in any form,
including printed, electronic or dig ital, ev idenc ing title to o r inte res ts in such ass ets.
For the purp ose of this law, property shall includ e proceeds.

2. “Credit institution ” :
a) an undertaking whose main business is to receive deposits or other repayable
funds from the public an d to gran t lo an s or other credit for its own account;
b) an electronic m oney institu tion, in the sense of paragr aph 1 9 of Artic le 2 of
Law 3061/2007 (Govern ment Gazette 178 A);
c) non-incorporated branches or re presentative offices in Greece of non-
residen t credit in stitutio ns. Any number of branches in Greece of the sam e foreign
credit ins titu tion shall be d eem ed a single credit institu tion.
For the purposes of this Law, the concept of “cred it ins titution” sha ll include the
Deposits an d Loans Fund and the Bank of Greece.

3. “Financial institu tion ”:
a) leas ing companies ;
b) factoring companies;
c) bureaux de change;
d) interm ediary com panie s in funds transfers;
e) credit com panies ;
f) postal com panies to the extent they a ct as inte rm ediar ies in f unds transf ers;
g) portfolio investm ent companies;
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h) mutual funds m anage ment com panies;
i) mutual funds m anage ment com panies investing in real estate;
j) mutual funds m anage ment com panies of venture capital;
k) investm ent firm s;
l) investm ent interm ediary firm s;
m) insurance companies providing life insurance and/or investm ent services;
n) insurance interm ediaries, as defined in Article 2, paragraph 5, of Presidential
Decree 190/2006 (Governm ent Gazette A 196) , providing life insu rance and/o r
investm ent services, with the exception of affiliated insu rance in termediaries, as
defined in Article 2 paragraph 7, of the said Presidential Decree;
o) non-incorpo rated b ranches or representative of fices in Greece of financial
institutions seated in another country;
p) undertak ing s other than credit ins titu tions wh ose busines s is to acq uire
shares or other fina ncial instrum ents or carry out one or more of the activities
referred to in Article 11, paragraph 1, points b to l, of Law 3601/2007 (Governm ent
Gazette A 178). Other activities m ay be included in the undertakings of this
category by decision of the Mi nister of Econom y and Fina nce, following an opinion
of the Governor of the Bank of Greece.

4. “Financial Group”: a group of companie s from those listed in paragraphs 2
and 3 of this article, consisting of a parent com pany located in Greece, its
subsidiaries and undertakings in which the pa rent com pany or its subsidiaries have a
qualifying holding (holding com panies), undert akings affiliated with the parent
com pany, the subsidiary or the holding com pany, within the m ean ing of Article 42e,
indent 5, po ints b, c or d, of Codifi ed Law 2190/1920 (Governm ent Gazette 37 A)
and undertakings on which the parent com pany, the subsidiary or the holding
com pany ha ve effective control even where they m ay have no equity participation
or with which they have any other close links or with which they are under common
managem ent even witho ut a con tractual or statutory arrangem ent to this effect. For
the m eaning of “parent com pany-subsidiary”, “qualifying holding” and “clos e
links”, the d efinition s of Article 2 of Law 3601/2007 (Governm ent Gazette 178 A)
shall apply.
The group’s largest com pany is the one with the largest asset size as per the closing
balance sheet for the preceding finan cial y ear.
5

5. “Comm ission”: the anti-m oney launderi ng and anti-terrorist financing
comm ission referred to in Article 7 hereof.

6. “Person”: any natura l or legal person.

7. “Electronic funds transfer ”: any transaction that is initiated by electronic
means through a credit institu tion or financial in stitu tion and includ es an order to
transfer an am ount of m oney (cash or cr edit) to another credit or financial
institution; the initiator and the benef iciary m ay be the sam e person.

8. “Cross-border funds transfer ”: a funds transfer where the credit inst itution or
financial ins titu tion re ce iving the o rder f rom the in itiato r is subje cted to a leg al
regim e in another than that in whic h the credit institution or financial institution
paying the f unds to the beneficiary is subjected.

9. “Financial sector”: the sector of the econom y consis ting of legal and natural
persons sup ervised by the Bank of Greece, the Capital Market Comm ission, the
Private Insurance Supervisory Comm ittee a nd the Accounting Standards and Audits
Comm ittee.

10. “Shell bank ”: a cred it institu tion, o r an institu tion engaged in equivalent
activities, incorporated in a jurisdicti on in which it has no physical presence ,
involving m eaningful m ind and m anage ment, and which is unaffiliated with a
financial group that m eets the regulat ory and supervisory requirem ents of
Community legislation or at l eas t equ ivalen t requ irem ents.

11. “Politically exposed persons”: natu ral persons who are or have been
entrusted with prom inent public functions an d i mmediate fam ily mem bers, or
persons known to be close associates of such persons, as specified in Article 22
hereof.

6

12. “Payable th rough acco unts”: correspondent accounts with Greek credit
institutions, which are used directly by th ird parties to transact business on their
own behalf.

13. “Suspicious transaction or activity”: any transaction or activity which is
estim ated to provide significant signs or suspicions of possible attem pt or
comm ission of the offences re ferred to in Article 2 hereof or of the involvem ent of
the person concerned or the beneficial owne r in crim inal ac tivities, on th e basis of
the ev aluation and assessm ent of the circum stances and facts of the transaction
(nature of transaction, type of financial instrum ent, frequency, complexity and
am ount, us e or non-use of cash) and th e person (occupation, financial status,
transaction or business be haviour, reputation, persona l record, other im portant
aspects ).

14. “Unusual transaction or activity”: any transacti on or activity which is
inconsistent with the transaction, business or professional behavi our or the financial
status of the person or has no apparent econom ic, business or personal purpose or
motive.

15. “Business relationship”: a business, pr ofessional or comm ercial relationship
which connects the custom er with the obligated persons, in the context of the
latter ’s ac tiv ities, which is expec ted, at th e tim e when the re lationsh ip is estab lished,
to have an elem ent of dur ation.

16. “Beneficial owner” m eans the natura l person(s) who ultim ately owns or
controls the custom er and/or the natural person of whose beha lf a transaction or
activity is being conducted. The benefi cial owner shall at least include:
a) in the case o f corporate entities :
(i) the natural person(s) w ho ultim ately owns or controls a le gal en tity
through direct or indirect owners hip or control over a sufficient
percen tage o f the shares or voting rights in that le gal en tit y, including
through bearer share holdings, other than a com pany listed in a
regula ted m arket tha t is subjec t to d isclosur e requirem ents c onsisten t
with Community leg islation or su bject to eq uivalen t international
7

standards; a percentage of 25% plus one share shall b e deem ed
sufficient to m eet this criterion;
(ii) the natural person(s) who ot herwise exercises control over th e
managem ent of a legal e ntity ;
b) In the case of legal entities, such as foundations , and legal arrangem ents,
such as trusts, which adm inister and distribute funds:
i) where the future beneficiaries have already been determ ined, the
natural person(s) who is the bene ficiary of 25% or m ore of the
property of a lega l ar ran gem ent or entity ;
ii) where the individuals that bene fit f rom the le ga l arrangem ent or
entity have yet to be determ ined, the class of persons in whose m ain
interest the legal arrangem ent or entity is set up or operates;
iii) the natural person(s) who exercises control over 25% or m ore of the
property of a legal arrangem ent or entity.

Article 5
Obligated persons
1. Obligated p ersons th at are subject to the requ irem ents of this Law sha ll be
the f ollowin g:
a) credit ins titu tions;
b) f inancial ins titu tions ;
c) venture capital com panies;
d) com panies providing business capital;
e) chartered accountants, audit firm s, independent accountan ts and private
audito rs;
f) Tax consultants a nd tax consulting firm s;
g) Real estate agents and related firm s;
h) Casino enterprises and ca sinos operating on ships flying the Greek flag, as
well as public or private sector enterp rises, organisations and other bodies
that organize and/or conduct gam bling and related agencies and agents ;
i) Auction houses;
j) Dealers in h igh-value go ods, only to the extent that paym ents are m ade in
cash in an am ount of EUR 15,000 or more, whether the transaction is
executed in a single operation or in se veral operations which appear to be
8

linked. A joint decision of the Mini ster of Econom y & Finance and the
Minister of Developm ent shall lay d own criteria for class ification und er
this c atego ry;
k) auction eers ;
l) pawnbrokers;
m) notaries and other independent legal professionals, when they participate,
whether by acting on behalf of and for th eir clients in any financial or real
estate transaction, or by assisting in the planning and execution of
transactions for the cl ient concerning the:
i) buying and selling of real property or business entities;
ii) managing of client m one y, securities or other assets;
iii) opening or m anage ment of ba nk, savings or securities accounts;
iv) organisation of contributi ons necessary for the creation,
operation or m anage ment of com panies;
v) creation, operation or m anage ment of trusts, com panies or
sim ilar structures.
The provision of legal advice continue s to b e subjec t to professional
secrecy, unless the lawyer or notary participates in m oney laundering or
terro ris t f inancing a ctiv ities or if his legal ad vice is p rovided for the
purpose of comm itting these of fences or if he is aware tha t his client see ks
legal advice in order to comm it such offences.
n) Natural or legal persons providing serv ices to c ompanies an d trus ts ( trust
and com pany service providers) -ex cept the persons under item s j and m
of this articles- which by way of bu siness provide any of the following
servic es to third par ties:
– for ming companies or other legal persons;
– acting as or arranging for another person to act as a director or
secretary of a com pany, a partner of a partnership, or a sim ilar
position in relation to other le gal persons or arrangem ents;
– providing a registered office, bus iness address, correspondence or
adm inistrative address and any othe r related services for a company,
a partnership or any other legal person or arrangem ent;
– acting as or arranging for another person to act as a trustee of an
express trust or a sim ilar legal arrangem ent;
9

– acting as or arranging for anot her person to act as a nom inee
shareholder for another person other than a com pany listed on a
regulated market, within the m ean ing of Article 17, paragraph 2,
point a, hereof, that is subject to disc los ure requ ire ments in
conf orm ity with Community legis lation or subject to equivalent
international standards. A decision of the Minister of Developm ent
will sp ecify the requirem ents for the inco rporation, autho rization,
registration and the pursuit of busin ess or profession referred to in
this subparagraph, by natural or legal persons.

2. A joint decision of the Mi nister of Econom y and Fina nce and the Minister of
Justice m ay specify further categories of obligated persons and the corresponding
com petent authoritie s within th e m eaning of Article 6 hereof.

CHAPTER B
Competent authorities and other bodies

Article 6
Competent authorities
1. “Com petent author ities ” shall m ean th e pub lic author ities which super vise the
com pliance of obligated persons with the provisions of this Law.

2. The com petent autho rities are:
a) the Bank of Greece for:
– credit ins titu tions;
– leas ing companies ;
– factoring co mpanies;
– bureaux de change;
– interm ediaries in funds transfers;
– credit com panies ;
– the undertakings of point jf of pa ragraph 3 of Article 4 hereof ; and
– postal com panies, on ly to the exten t that they act as interm ediaries in
funds transfers. The Bank of Greece, in supervising these co mpanies,
10

cooperates with the Ministry of Transport and Communications and
the Nation al Telecomm unicati ons and Post Comm ission;
b) the Hellenic Capital Mar ket Comm ission f or:
– portfolio investm ent companies in the for m of a société anonym e;
– manage ment com panies of m utual funds;
– manage ment com panies of m utual funds investing in real estate;
– manage ment com panies of m utual funds for venture capital;
– investm ent firm s and
– investm ent interm ediary firm s.
c) the Hellen ic Private Insurance S uperviso ry Comm ittee for insurance
com panies and insuranc e inte rm ediaries;
d) the Accoun ting an d Auditing Superviso ry Co mmission f or cha rtered
accountants and audit firm s;
e) The Ministry of Economy and Fina nce (General Directorate for Tax
Audits) for:
– venture capital firm s;
– com panies providing business capital;
– tax consultants, tax expe rts and related firm s;
– independent accountants a nd private auditors;
– real estate agents and related firm s;
– auction houses;
– dealers in high value goods;
– auction eers ; and
– pawnbrokers;
f) the Gam bling Control C omm ission of law 3229/2004 (O.G.G. A 38) for :
– casino en terprises ;
– casinos operating on ships flying the Greek flag;
– com panies, organisations and ot her entities engaged in gam bling
activ ities; an d
– betting outlets;
g) the Min istry of Justice for notaries and lawyers;
h) the Ministry of Developm ent for the persons referred to in point n of
paragraph 1 of Article 5; and
11

i) for branches in Greece of financial institution s having their reg ister
office abroad, the competent aut hority shall be the corresponding
authority responsible f or dom estic financial institutions conducting
activ ities s imilar to thos e of such f oreign f inancial ins titution s.

3. The authorities referred to in paragra ph 2 hereinabove shall have the following
tasks and powers:
a) to supervise the co mpliance of the obligated persons w ith the re quirem ents
im posed by this Law an d issue the r elevan t individual and regulatory adm inistrative
acts ;
b) to specify im ple mentation details regard ing the specific obligations of supervised
persons in accordance with pa ragraph 4 of this Article;
c) to issue appropriate instructions a nd circulars, providing guidance to the
obligated persons, whether generally or to certain obligated persons, on how to treat
specific problem s or on practices of conduct with respect to custom ers, the selection
of appropriate IT system s a nd the adoption of internal pr ocedures for detecting any
suspicious or unusual transactions or activit ies potentially linked to the offences of
Articles 2 and 3;
d) to issue regulatory deci sions specifying the necessary docum ents and inform ation
for the identif ication and identity verif ication carried out by the obligated persons
during the a pplica tion o f standard, sim plif ied or enhanced custom er due diligenc e
measures, or third party custom er due diligence under Article 23 hereof;
e) to inf orm the oblig ated p erson s of any country data and inf orm ation on its
com pliance or not with Community legis lation and FATF ( Financial Action Task
Force) recommendations;
f) to prepare and distribute to the obli gated persons typology lists with data on new
methods and practices used in Greece or ab road to comm it the offences of Article 2.
To this end, they should cooperate with other com petent authorities, the Central
Coordinating Authority, the Comm ission of Article 7 and possibly sim ilar foreign
authorities, they closely m onitor the typology-related work at international fora and
update the afore mentioned typology lists;
g) to ensure through educational programm es, seminars, m eetings or otherwise, the
continuous training and education of their em ployees, especially auditors, as well as
of the obligated persons and em ployees thereof;
12

h) to conduct regular or extraordinary inspections, incl uding on-site exam inations at
the obligated persons’ head offices or other establishm ents, as well as at branches
and subsidiaries located or operating in Greece or abroad , without prejudice to the
legislation of the host country, in order to assess the adequacy of m easures and
procedures in place;
i) to request from the obligated persons a ll evidence or data, of any nature or for m,
as m ay be necessary for the perform ance of their supervisory and auditing tasks;
j) to take ap propria te m easures to en sure that the obligated persons m ana ge properly
and m aintain reco rds d irec tly o r indirec tly re lated to tra nsactions or activities
potentially linked to the offences of Artic les 2 and 3, as well as that such persons
observe con fidentia lity ;
k ) to im pos e disciplinary and adm inistrati ve sanctions on the obligated persons and
their em ployees for any breach of th e oblig ation s arising from this Law, pursuant to
Articles 51 and 52 and
l) any other task or power envisage d by the provisions of this Law.

4. Decisions of the competent autho rities may modify the obligations laid down in
this Law for the obligated persons, taking account in particular of their financial
streng th, the nature of their busine ss activ ities, th e degree of risk of comm itting or
attem pting to commit the of fences of Articles 2 and 3 entailed by such a ctiv ities and
transactions, the legal fram ework governing the business activitie s of such persons
and any objectiv e inab ility of certain catego ries of obligated persons to apply som e
specific m easures. The Bank of Greece, af ter evaluatin g the risks of m oney
laundering and terrorist financ ing entailed by its own operations shall establish
appropriate m easures by a specific decision.

5. Decision s of the com petent a uthoritie s m ay specify addition al or stric ter
requirem ents further to those of the present Law, with a view to addressing risks of
comm itting or attem pting to comm it the of fences laid down in Artic les 2 a nd 3.

6. The Bank of Greece, the Hellenic Capital Market Co mmission, the Private
Insurance Comm ission, the Accounting Standards and Audit Comm ittee and the
General Directorate for Tax Audits of the Ministry of Econom y and Finance shall
each set up special units , adequately staffed with at least three full-tim e employees,
13

having as their task to a ssess the compliance of the obl igated persons under their
supervis ion with the req uirem ents of this Law. Such units sh all be as sis ted by other
staff m embers of the aforem entioned aut horities and especially by e mployees
involved directly or indirec tly in the supervision and controls of the obligated
persons.

7. The com petent authorities referred to in paragraph 2 hereinabove shall subm it on
a biannual basis a detailed report to the Central Coordinating Authority on their
activities, regulatory decisions and circulars, the outcom e of supervisory inspections
and assessments of obligated persons and any m easures or sanctions imposed. The
com petent authorities which supervise a large num ber of obligated persons,
particularly natural persons , perform checks in accordan ce with the risk -based
principle. S uch reporting by the competent authorities to the Ce ntral Coordinating
Authority is effected by way of derogati on from any general or specific provision on
banking, capital m arket, tax or professional secrecy.

8. The competent authorities, in the cont ext of their cooperati on with each other
under Article 40, may enter into bilate ral or m ultilateral m emoranda of
understanding (M.O.U.) for the exchange of confidential and other infor mation,
conducting and facilitating jo int inspections and exam ining ways and m ethods to
achieve convergence of supervisory practices.

Article 7
Anti-Money Laundering and Anti-Terroris m financing Commis sion
1. A Commission under the nam e “Anti-M oney Laundering and Anti-Terrorist
Financing (AML/CTF) Comm ission” is esta blished. It is based in Attica and is
supervised by the Minister of Economy and Finance. By a decision of this Minister
the exact place of its headquarters are specified.

2. The Comm ission consists of a Chairm an and eight m embers appointed for a
term of two years, renewable only once.

14

3. By decision of the Suprem e Judicial Council, a superior acting Public
Prosecutor is appointed as chairm an of the C omm ission with his alternate and
serves on a f ull-tim e basis.

4. The m embers of the C omm ittee are a ppointed by a joint decision of the
Minister of Econom y and Fina nce and the Minister of Justice, published in the
Governm ent Gazette. Of the m embers to be app ointed : (a) two m embers, one from
the General Directo rate of Econom ic Policy and the other from the Special Control
Service are proposed by the Minister of Economy and Fina nce; (b) one Mem ber is
proposed by the Minister of Justice; (c ) one Mem ber fr om the Hellenic Police
Headquarters is proposed by the Minister for the Interior; (c) one Mem ber is
proposed by the Govern or of the Bank of Greece; (e) one Mem ber is proposed by
the Board of Directors of the Hellenic Ca pital M arket Commission ; (f ) one Mem ber
is proposed by the Board of Directors of the Hellenic Private Insurance S upervisory
Comm ittee; and (g) one Mem ber is propos ed by the Board of Directors of the
Accounting and Auditing Supervisory Board. One alternate for each regula
r
Mem ber should be appointed by the sa me procedure. The m embers of the
Comm ission will b e selected from among pe rsons of recogn ised com petence, m oral
integrity and professional experience in the field of banking, finance or law.

5. The Comm ission’s Plen ary consists of the Chairm an and the m embers of the
Comm ittee. Any plenary session shall constitu te a quorum if at least the Chairm an
and five m embers of the Comm ission are pr esent. Decisions s hould be taken by the
absolute m ajority of those present and, if there is equality of votes, the Chairm an
has a casting vote. Minority voting is always reg istered in the Plenary’s decisions.

6. The Comm ission has the following tasks and powers:
a) to co llect, inv estigate and evaluate any infor mation forw arded to it by the
obligated persons and other public or private bodies, on suspicious or unusual
transactions or activities or business, professional or commercial relationships
potentially linked to m oney laundering or terrorist financing, and to request any
additional infor mation as m ay be necessary to carry out its duties;
b) to receiv e, inves tigate and evalu ate an y inform ation concerning transactions or
activities potentially lin ked to the offences referred to in point (a) above, as m ay be
15

forwarded to it by foreign authorities and bodies with wh ich the Comm ission
maintains relationships of cooperation a nd mutual assistance, as well as any
inf orm ation m ade known to it v ia th e inte rnet or by the m edia or any other m eans;
c) to provide guidelines to the obligated persons and the authorities and bodies
referred to in points a and b above for the handling of cases and f or the m ore
efficient con duct of its in vestig ation s;
d) to have access to any type of public docum ents, records and databases, including
those of Teiresias S.A;
e) to c arry out spec ial on-site ins pection s, in situa tions that it con siders to be
serious, at any section of public adm inist ration or at public entities and public
enterprises, potentially in co-operation w ith the com petent authorities or any other
public au tho rity ;
f) to request assistance and inform ation fr om sections of public adm inistration, legal
persons of public or private law and orga nisations of any type, in connection with
any inve stig ation into cases po tentially link ed to the of fences of Articles 2 and 3
hereof; Also, it m ay r equest any inform ation held by judicial, investigation and
prelim inary investigatio n author ities ;
g) to ackno wledge, in writing or b y secure electron ic m eans, receip t of reports sen t
to it and provide the sender of such info rm ation with any further inp ut, withou t
prejud ice to the conf iden tia lity of inv estig atio ns or the pe rformance of its own tasks;
h) to inform the com petent authorities of any failure of the obligated persons under
their supervision to comply with the obligations he reunder or where cooperation
with it is not satisf actory ;
i) to request from the competent au thorit ies and the obligated persons all necessary
inform ation for the conduct of its invest igations, including grouped inform ation
about certain categories of transactions or activities of na tural or legal persons or
dom estic or foreign legal schem es;
j) to exam ine during its investigatio ns in form ation and evidence for the detection of
cases of co mmitting or attem pting to comm it a predicate o ffence, so a s to identif y
any illicit property possibly derived or obtained from m one y laundering, terrorist
acts or terrorist financing;
k) to cooperate and exchange information with the authorities and bodies referred to
in Article 40 hereof;
l) to k eep statis tic s in ac cordance with Article 38 ; and
16

m) to take the actions provided for in Articl e 49 hereof in respect of the applic ation
of property seizure, as provided for by the United Nations Security Coun
cil
resolutions, the decisions of its dependent bodies and EU regulations and decisions.

7. In perform ing their duties, the Chairm an, the m embers and the em ployees of
the Comm ission should respect the principl es of objectivity and im pa rtiality and
refrain fro m exam ining cases wh ere a conf lict of intere st m ay aris e or ca ses
involving fam ily, friends or other persons with whom they have a professional,
business or personal relationship or a s ubordination relationshi p. They are also
bound to secrecy in respect of any inform ation obtained during the perform ance of
their duties. The latter obliga tion s hall c ontinue to apply afte r the voluntary or
involuntary ending of their term of offi ce. Any person who is found guilty of a
breach of th is duty of s ecrecy is pu nish ed by imprisonm ent for no less than three
months.

8. The Commission shall be supported by scientific, adm inistrative and
ancillary personnel seconded fr om Ministries, as well as the bodies referred to in
paragraph 4 hereinabov e; to this end, up to fifty (50) s econdm ent position s are
provided for and allocated to the various services of the Comm ission by the decision
mentioned in paragraph 13 herein below. W ith particula r regard to position s of
scientific personnel, persons with skills and expertis e in dealing with m oney
laundering, terrorist financing and the com bating of serious financial crim es should
be seconded. The secondm ents referred to in the preceding sentences of this
paragraph are effected by way of derogati on from the provisions in force, following
a proposal by the Chairm an of the Commission. More specifically, such
secondm ents are effected as follows: (i) w ith respect to secondm ents from
ministries, by a joint decision of the Mi nister of Economy and Finance and the
relevant Minister as appropr iate; and (ii) with respect to secondm ents from the
bodies referred to in paragraph 4 herein above, by a decision of the Minister of
Econom y, following an opinion from the Gover nor of the Bank of Greece or of the
Presidents or Chairm en of th e other bodies as appropriate.
The above Ministries and bodies should ensure the adequate staffing of the
Comm ission and ensure that em ployees on secondm ent are persons who have a
17

sound em ploym ent background, as well as th e necessary com petence, scien tific
background and expertise to take up specific positions.

9. A decision of the Chairm an may designate certain m embers of the
Comm ission as supervisors to undertake the overall supervision of individual
adm inistrative units, as set up by the decisi on referred to in paragraph 13 of this
Artic le. Such supervisors shall provide for th e training and education of em ployees
in their re sp ectiv e unit a nd th e coordination of the unit’s action with that of other
units and of the Comm ission’s Plenary, evalua te the operatin g efficiency of the unit
and propose to the Plenary ways and m easures to enhance it.

10. Where a su spicious transaction or ac tiv ity is reported or otherwise made
known to the Comm ission it conducts a prelim inary adm inistrative investigation to
determ ine whether the offences defined in A rticle 2 and the related predicate
offences of Article 3 hereof have taken place. Following such inve stig ation, th e
Comm ission’s Plenary decides whether the adm inistrative investigation should be
continued or the case should be filed in th e archives or referred to the com petent
Public Prosecutor, provided that there is sufficie nt evidence collected, or whether a
prelim inary crim inal inv estig ation sh ould be carried out. A case filed in th e arch ives
may be retrieved at any tim e in order to continue investigation or to link such
investigatio n to ano ther i nvestigation by the Commission of a suspiciou s tran saction
or activity.

11. Where the Comm ission’s Plenary deci des the conduct of a prelim inary
crim inal investigation, it appoints an em ployee or, in exceptional circum stances, if
the case is extrem ely serious, a m ember of the Comm ission, who are deem ed special
prelim inary investigation officials to car ry o ut the p relim inary investiga tion in
accordan ce with the Code of Penal Procedure. In perform ing such investigation, the
em ployee shall be assisted, if req uired, by th e Chairm an or a Member of the
Comm ittee specif ica lly d esigna ted f or this purpos e. During the prelim inar y crim inal
investigation and where deem ed necessary, witnesses or suspects m ay be brought to
the Comm ission for questioning and a house search or a search at the business
estab lishm ents of the natura l or lega l persons su spected f or comm itting the of fences
laid down in Articles 2 and 3 hereof m ay be effected, s ubject to the g uarantees set
18

out in Ar ticle 9 of th e Greek C onstitu tion. Following the com pletion of the
prelim inary investigation, the file shall be forwarded by the Chairm an of the
Comm ission to the competent Public Prosecu tor. The involvem ent of e mployees or
members of the Comm ission in p relim inary in vestig ation in to such a ca se sha ll not
disqualify them from testifying as witnesse s in co urt hea rings rela ting to th at cas e.

12. During such investigations and aud its, no provision requiring banking,
capital m arket, taxation or professional secrecy is valid vi s-à-vis the Commission.
The provision of this paragr aph does not prejudice to Articles 212, 261 and 262 of
the Code of Penal Procedure.

13. A decision of the Ministry of Econom y and Finance, following consultation
of the Commission’s Plenary, lays down the details of the operation of the
Comm ission and notably the organogram , the adm inistrative units, the operating
rules, the ta sks spec ific to the Plena ry, the Chairm an, the mem bers, the supervis ing
members, the em ployees and the ad ministra tiv e units, the ha ndli ng of cases and the
cooperation of the Comm ission with ot her national and foreign authorities.

14. The Chairman, m embers and em ployees of th e Comm ission comm itting,
eithe r inten tionally or o ut of negligence, a breach of their duties and obligations
aris ing f rom this Ar tic le m ay be held discip lina rily liable, re gardles s of whether or
not there is crim inal liab ility. The dis cipli nary proceedings against the Chairm an are
initiated by the com petent organs of the Constitu tion a nd of the Code f or the
Mem bers of the Judiciary. The disciplinary proceedings against th e m embers of th e
Comm ission are initiated by the Ministry of Econom y and Finance before the
Disciplinary Council provided for in pa ragraph 3 of Article 18 of Law 2472/1997
“Protection of individuals w ith regard to the processing of data of a personal
character” (Gov. Gaz. 50 A), which decide s at first and last instance whether the
defendant should be released of all char ges or be rem oved from the Comm ission.
The disciplinary proceedings agains t the em ployees of the Comm ission are effected
by the competent disciplinary organs of their originating m inistries and bodies,
following a report by the Chai rm an of the Comm ission.

19

15. The Commission par ticipates in inte rnational fora for the exchang e of
inform ation between authorities equivale nt to it (F.I.U.’s), both at EU and
international level and notably in FIU-ne t and E gmont Group, participate in their
meetings and, where possible, in th e working groups of such fora.

16. The em olum ents of the Chairm an, m embers, supervis ing m embers of the
Comm ission and any addition al remuneration for the seconded staff shall be
specified by way of der ogation of any othe r provision by a decision of the Minister
of Econom y and Finance. Staff on s econdm ent to the Commission, receive from the
originating Ministry or body, as of the da te of secondm ent, full wages and bonuses
as those applying to their or igina l po sition, as well a s the aforem entioned additional
rem uneratio n and any rem uneration f or overtim e work. Such addition al
rem uneration is not subject to stoppages collected on behalf of third parties.

17. The Chairm an and the m embers of the Comm ission shall each subm it, on an
annual basis, to the Suprem e Cour t Pub lic Prosecutor’s Office the statem ent of
property ref erred to in Law 3213/ 20 03 (Gove rnment Gazette A 309), as in force at
the tim e.

18. During January of every year, the Ch airm an of the Comm ission subm its to
the Ins titutions and Transparen cy Comm ittee of the Greek Parliam ent a repo rt,
stating th e activ ities of the Commission a nd relevant inform ation and statistical
data.

Article 8
Central Coordinating A uthority
1. The Ministry of Econom y and Fi nance is designated as the Ce ntral Coordinating
Authority w ith r espec t to the im plem entation of the provis ions of this Law, the
assessm ent and further reinforcem ent of th e effe ctiveness of anti-m oney laundering
and anti-terroris t finan cing m echanis ms, the coordination of the com petent
authorities and the international rep resenta tion of Greece. Decisions of the Min ister
of Economy and Finance m ay lay down procedures and m easures for the
im ple mentation of the provision of the pr eceding sen ten ce, as well as for th e
exchange of inform ation, in accordance w ith Article 40, whether confidential or not,
20

between the said Ministry, the Commissi on, the com petent authorities and other
pubic autho rities, with a view to enabli ng the more effective fulfillm ent of their
tasks.

2. The Central Coordinating Authority has the following tasks and powers:
a) to ev alu ate and ass ess the effectiv en ess of m easures applied in different
catego ries o f obligated p ersons, as w ell as the degree of compliance of such persons
with the obligations arising from this Law;
b) to revie w, analyse and com pare the biann ual repor ts subm itted to it by the
com petent authorities in accordance with parag raph 7 of Article 6 and propose
appropriate m easures to increase their superv isory effectiven ess;
c) to particularly analyse, the num ber, qua lity and trends of suspicious or unusual
transaction or activity reports sub mitted to the Commission, by category of
obligated persons, in accordance with data provided by it;
d) to seek to continuall y increase the level of c ooperation between com petent
authorities and between com petent author ities and the Comm ission, especially in
areas such as the exchange of inform ati on, the conduct of joint investigations, the
adoption of comm on supe rvisory practices and the provision of harm onised
instructions to the obligated persons, taki ng into account any differences there m ay
be between such persons in term s of nature, econom ic scale and size, operational
capacity or business, co mmercial and professional activities;
e) to hold m eetings, conferences and sem inars, with the participation of
repres entatives from the com petent author ities, the Comm ission and th e obligated
persons, to discuss and address specific i ssues and to inf orm participants abou t
developm ents in international organisati ons and fora concerning the prevention and
suppression of the offenc es set out in Article 2;
f) to coordinate the preparation of dr aft studies and set up working groups to
exam ine specific issues, following consu lta tion of the Strate gy Comm ittee r eferred
to in Article 9, the Comm ission and the com petent autho rities;
g) to be th e central representative o f Gr eece in the in ternational organ isations and
fora m entioned in point e above, and notab ly in the European Union, the Council of
Europe Committee of Experts on the Evaluation of Anti-Money Laundering
Measures (Moneyval Comm ittee) and the Fi nancial Action Task Force (FATF), be
aware of de velopm ents in other internati onal organisations and fora in which the
21

com petent authorities, the Comm ission or th e represen tativ es of certain catego ries
of obligated persons may participate a nd ensure the dissem ination of relevant
inform ation to all such authorities and persons;
h)to p rovid e f or re spo nding to qu estionn air es of , and su bm itting co mments or
suggestions to international organisations and bodies, as well as for preparing and
subm itting Action Plan s and stream lining respo nses to a sse ssm ents by interna tiona l
organisation s and bodies concerning Greece, in co-operation with the Commission,
the com petent autho rities and the re presentatives of obligated persons;
i) to f ully br ief the Chair man of the St rategy Comm ittee provided for in Article 9, so
as to ensu re greater ope rationa l ef fectivene ss to this Comm ittee ; and
j) to comm unicate with, and provid e every possible inform ation a nd support, to the
forum ref erred to in Artic le 11 belo w and to consider its proposals and
recomm endations.

3. The foregoing tasks and powers are be ex ercised by the General Directorate of
Econom ic Policy of the Ministry of Econom y and Finance, with the assistance, if
required, of the other adm inistrativ e units of the said Ministry.

Article 9
Committee f or the Elabo ration of a Strategy an d Policies to deal
with Money Laundering and Terrorist Financin g
1. A comm ittee is hereby established in the Ministry of Econom y and Finance, by
the nam e “ Comm ittee for the Elaboration of a Strategy and Policies to com bat
Money Laundering and Terrorist Financing ” (herein after referred to as “Strategy
Comm ittee”).

2. The composition of such comm ittee is spec ified by a de cision of the Minis ter of
Econom y and Finance published in the G overnm ent Gaz ette and comprises the
following persons:
a) a Chairm an, who is the General Secret ary of the Minister of Econom y and
Finance, and m embers, who ar e senior staff appointed by:
b) The Ministry for Interior Affair s (Hellenic Police Headquarters);
c) The Ministry of Economy and Finan ce (General Directorate of Econom ic
Policy) ;
22

d) The Ministry of Foreign Affairs;
e) The Ministry of Justice;
f) The Ministry of Merchant Marine , Aegean and Island’s Policy;
g) The Anti-Money Laundering and A nti-Te rrorist Financi ng Comm ission;
h) The Bank of Greece;
i) The Hellenic Capita l M arket Commission ;
j) The Hellenic Private Ins urance Supervisory Comm ittee ;
k) The Accounting and Aud iting Su perviso ry Comm ittee;
l) The Gam bling Supervision and Control Committee;
m) The Special Control S ervic e; and
n) The General Directorat e for Tax Audits of the Ministry of Economy and
Finance.

3. Before the Strategy Comm ittee m eets for the first tim e, its m embers should
inform the Chairm an of their s ubstitutes in case of i mpedi ment.

4. Depending on the issues to be exam ined, the Stra tegy Comm ittee m ay invite to its
meetings, as appropriate, representatives of other public or private authorities and
bodies. Such authorities and bodies incl ude in particular the Ministry of
Developm ent, the General Directo rate of Customs of the Ministry of Econom y and
Finance and the Hellenic Bank Association.

5. The Chairm an’s office provide s secretar ial sup port to th e S trategy Comm ittee and
is adequately staffed in this connection.

6. The Strategy Comm ittee has the following tasks:
a) to prepar e and design polic ies spe cifically ta ilored to add ress iden tif ied
weaknesses in the overall national anti-m oney laundering and anti-terrorist
financing mechanism ;
b) to study and design the necessary legisl ative, regulato ry and organisational
measures to im prove the supervisory fr am ewor k and ensu re the com pliance of
Greece with international standard s and requirements;
c) to be aware of the stud ies conducted by the Centra l Coordinating Authority,
the Directorate of Intern ational Relations and Studies of the Commission, the
23

com petent authorities and any other aut horities or bodies and to exam ine and
evaluate such studies;
d) to exam ine ways to increase the effec tiveness of the Comm ission, notably by
providing for the secondm ent of expert sta ff, the deepening of its cooperation with
the com petent author itie s, the inc rea se of the number, and the im provem ent of the
quality, of suspicious and unusual transaction reports vi a the reinforcem ent of the
superviso ry effectiven ess of co mpeten t au thoritie s an d the ac tivation and
involvem ent of other public bodies in reporting to the Commission;
e) to m onitor developm ents in interna tional organisations and fora, notably in
the European Union, the Council of Europe Comm ittee of Experts on the Evaluation
of Anti-Money Laundering Measu res (Money val Comm ittee), th e In ternational
Monetary Fund (IMF) and the Financial Action Task Force (FAFT). The Central
Coordinatin g Comm ission, as a represen tative of Greece in in ternational
organisations and fora, the com petent authorities and the consultation forum
provided for in Article 11 shou ld provide it with a ll inf orm ation relevant to this
task;
f) to m onitor the degree o f com plianc e of Greece with in tern ational an ti-
money laundering and anti-terrorist financ ing standards and ensure rapid and
effective im plem entation of United Nations Security Council resolutions and of the
EU and othe r in terna tion al organisations and bodies’ d ecisions dealing with m oney
laundering and terrorist financing;
g) to ensure ever-growing cooperation between the authorities, bodies and
ministries listed in paragraph 2 hereinabove and prom ote the conclusion of bilateral
or m ultilateral m emoranda of understanding ;
h) to develop initiatives for cooperation w ith the private sect or in order to
exchange ex perien ces an d exam ine the need for adjus tments so as to increas e the
contribution of natural and legal persons of the private sector to count
ering the
offences set out in Article 2;

7. The Strategy Committee meets regul arly once every two m onths or
extrao rdina rily on the Chairm an’s initia tive. The Chairm an may invite to a n
extraordinary m eeting only som e m ember s com petent for specialis ed subjects
and/or m ay entrust the exam inatio n of such s ubjects to relevan t sub -comm ittees.
The Strateg y Comm ittee prepares its own Operating Rules, approved by the
24

Minister of Econom y and Finance. The Oper ating Rules specify the formulation of
the agenda for the meeting s, the decisi on-m aking process, the organisation of
secretarial and scien tific support and other relevant issues.

8. The Strategy Comm ittee prep ares and s ubm its to the Ins titutions and
Transparency Comm ittee of the G reek Parl iam ent an annual re port, stating its
actions and activities and proposing policie s and specific m easures to continually
increase the effectiveness of the nationa l m echanism for preventing and suppressing
the of fences la id down in Article 2. The f irst su ch repo rt sh all be subm itted by the
Strategy Committee in January 2009.

9. The inform ation exchanged in the cont ext of the operations of the Strategy
Comm ittee are deem ed confidential.

Article 10
Other public authorities
1. The administrative units of the Mini stry of Econom y and Finance which are
responsible for collecting a nd m aintaining inform ation and docum entation in respect
of any type of real estate tra nsac tio n, or collec ting tax es an d levies r elated to such
transactions, take all necessary organizati onal m easures to identify possible cases of
the comm ission of the of fences of Artic les 2 and 3 hereof via such transactions.
Such m easures are sup plem entary to “o rigin of wealth” m easures applying to
prospective real esta te buyers and provide for risk assessm ent procedures involving
a class ification of transactions and p arties to transactions, legal or natural persons,
which entail a higher risk and require enhanced control. A d ecis ion of th e Min ister
of Econom y and Finance should specify the units responsible, thei r respective tasks,
the m odalities for their coope ration with their foreign coun terparts, as well as the
procedures and technical details for th e im ple mentation of the above m easures.

2. The com petent custom s and tax authoritie s and the Special Control Service of the
Ministry of Econom y and Fi nance take all necessary organizational m easures to
prevent and suppress the use of cross-bor der and dom estic trade for the purpose of
comm itting the of fences of Artic les 2 and 3 o f this Law. Such m easures sh all
provide for risk assessm ent procedures depending on the t ype and quantity of
25

transpo rted commodities and goods, the count ry of origin or destin ation, the
consistency of these data w ith the f inancia l statu s and the bu siness, comm ercial or
professional activities of the persons involved in such transactions, the reliability of
transport companies and any other relevant elem ent. The aforem entioned authorities
cooperate and cross-check data and info rmation with other dom estic or foreign
public agencies and bodies, as well as with credit institutions carrying out, either
direc tly o r indir ectly, trans action s related to the aforem entioned commercial
operations or m aintaining business relations hips with persons involved in such
transactions. A decision of the Minister of Economy and Finance specifies the units
responsible, their respective tasks and the procedures and techni cal details for the
im ple mentation of the above m easures.

3. The competent tax authorities an d the Spec ial Contro l Se rvice of the Minis try of
Econom y and Finance, in cooperation with th e com petent authoritie s of the Ministry
of Developm ent and other m inistries or public bodies, which keep registers of
com panies of any legal form , containing inform ation about the establishm ent,
operation, any am endments to the articles of association s or the constitu ting
docum ents, founding mem bers, partners or shareholders, or approve share capital
incre ases o r have oth er related tas ks with res pect to such com panies, take all
necessary m easures to pr event and suppress the use of com panies or com pany
vehicles f or the purpose of comm itting th e o ffences laid do wn in Articles 2 and 3
hereof. Such m easures include in particular:
a) checking th e reliability and cred ibility of partners and shareholders, board
members or m anagers;
b) laying down procedures to verif y the lawf ul origin of initial a nd subseque nt
capital, especially during increases of the share capital of sociétés anonym es,
whether listed or not on a regulated m arket;
c) providing increased supervision with resp ec t to the prope r a nd lawful use of
nationa l an d Comm unity sub sidies, gran ts and other financia l as sistance to
com panies and other corporat ions or natural persons;
Joint m inisteria l decis ions of the Ministe r of Ec onom y and Fina nce and the Minis ter
of Developm ent or other com petent m inisters, and by decisions of supervisory
public authorities and bodies specify the units responsible, their respective tasks and
the procedu res and tech nical details for specific actions and m easures, based on a
26

assessm ent of risks an d the cost- benef it aspe cts of the imposition o f addition al
obligations on com pani es or additional co ntrols on the part of the relevant
authorities and units, so as to ensure the effective im plem entation of the above
measures.

4. Joint decisions of the Minister of Economy and Finance and the Minister
com petent for the licensing, registration, s ubsidisation or contro l of corporations,
institutions, organisations, a ssociations and other types of non-profit organizations,
should specify m ethods, m easures and pro cedures aim ed at preventing the use of
such entitie s for comm itting the of fences of Articles 2 and 3 hereof . Such m easures
include in particular m aintaining a regist er of the above enti ties by the com petent
author ity f or the respe ctive typ e of entity, the require ment that their m ain
transactions be effected through credit institutions and the conduct of risk-based
random checks in such entities by th e com petent public authorities.

5. The adm inistrative units of the Ministry of Foreign Affairs responsible for the
supervision and subsidisation of non-pr ofit institutions or non-governm ental
organisations should take all necessary m easures to ensure the proper managem ent
of subsidies, grants or fina ncial assistance of any type, especially if such funds are
allocated to programm es of any kind in count ries with high levels of corruption or
crim inality or vulner able to te rro ris m.

6. The m inistries, the com petent authori ties and units and other public agencies
referred to in paragraphs 1 to 5 of this Article sha ll p rom ptly rep ort to the
Comm ission any case f or which the re m ay be evidence or su spicions of comm itting
or attem pting to comm it the offences of Articles 2 and 3 hereof, independently from
any other action they are entitled to take.

Article 11
Anti-money laundering and anti- ter rorist finan cing consultation forum
1. By a decision of the Minister of Econom y and Finance, a special entity shall be
established, bringing together representative s of the variou s catego ries o f obligated
persons, by the nam e “Anti-m oney la undering and anti- terrorist financing
consultation forum ” (hereinafte r ref erred to as “ the AML/ATF Forum ”).
27

2. The General Secretary of the Hellenic Bank Association is appointed as the
Chairm an of the AML/ATF Forum. The m embers of it are propo sed by the
representatives of the va rious categories of obligated persons. The foregoing
persons are appointed for a rene wable term of three years.

3. The A M L/ATF Forum is lo cated at th e prem ises of the H ellen ic Ban k
Association m eets regularly at le ast th ric e a year and extrao rdina rily on the
Chairm an’s initiative. A t the first mee ting the Chairm an and the m embers of the
AML/ATF Forum shall designa te th eir a lte rnate s.

4. The Chairm an m ay invite only so me of the mem bers to an extraord inary m eeting
to discuss sp ecific issues of re levance to these m embers only.

5. The Plenary of the AML/ATF Forum prep ares its own Operating Rules, approved
by the Minister of Econom y and Finance. The Operating Rules specify the
procedure for calling a m eeting, the keep ing of records of discussions, the
preparation of the agen da for the m eetings , secretarial support and other technical
issues and d etails.

6. The Operating Rules stat e the activities of th e AML/ATF Forum , including bu t
not lim ited to:
a) cooperation and consultation between pa rticipants to ensu re the effective
fulfillm ent of their oblig ations und er this Law;
b) exchange of expertise and knowledge of international developm ents, the study of
specif ic pro blem s and identif ica tion of sect ors, activ ities an d circum stances that are
vulnerab le to comm itting or attem pting to comm it the of fence s of Article 2;
c) giving g uidance to the various catego ries of obligated persons on how to deal
with certain technical issues, in acco rdan ce with this L aw and the regulatory
decis ions of the com petent autho rities;
d) dissem ination of infor mation contai ned in typology lists from Greek and
international organisations, st udies and analyses of such reports a nd proposals to the
com petent authorities in re spect of arising issues;
28

e) setting up working groups to discuss topi cs of relevance to all or som e of the
participan ts, in particular ref erring to the effectiv eness and im provem ents in
applicable p rocedures, m easures and practi ces for the detection of suspicious or
unusual transactions or activities, with a view to ensuring m ore effective
com pliance by the oblig ated pe rsons with the ir o bliga tions under this Law;
f) organisation of training sem inars, wo rkshops or conferences and production of
inf orm ation brochures a nd educat ional m ateria l aim ed at ra ising aw areness am ong
the obligate d persons o f threats tha t the offences of Article 2 could pose to the
socie ty and to th eir tr ustworthin ess a nd reputation and warning them of any
disciplinary, adm inistrative or crim inal liability entailed by their non-compliance.

7. In th e co ntext of cou ntry ex am inations carried out by internat ional organisations
and regard ing Greece’ s com pliance with intern ational s tandards again st the offences
of Article 2, the AML/ATF Forum and the re presentatives of the obligated persons
cooperate with the com petent author ities and notify on tim e the Central
Coordinating Authority a ny useful infor mation.

8. The AML/ATF Forum prepares within th e first two m onths of each year a report
on its past year’s activities and subm its it to the competent au thorities, the
Comm ission the Central Coordinating Aut hority and the Strategy Comm ittee. The
report m ust be ava ilab le on the web site of the H ellen ic Bank Associa tion . The f irst
such report shall be submitted in 2009.

9. Inform ation of a confidential nature may not be communicated to the public. The
Chairm an of the Body m ay propose to the Plenary the criteria and categories of
confidential inform ation.

CHAPTER C
Customer due diligence
Article 12
Cases of ap plica tion of due dilig enc e measures
Obligated p ersons app ly custom er due diligence m easures:
(a) when establishing a business relationship;
29

(b) when carrying out occa sional transactions am oun ting to 15.000 € or more,
whether the transaction is carried out in a single operation or in several operations
which appear to be linked;
(c) when there is a susp icio n that an of fence referred to in Article 2 h as either
been comm itted o r atte mpted, rega rdless of any derogation, exem ption or threshold
pursuant to paragraph 10 of Article, paragra phs 2 and 3 of Article 14 and paragraphs
1, 2 and 5 of Article 17;
(d) when there are doubts about the vera city, completeness or adequacy of
previous ly o btained iden tif ica tion d ata a bout the custom er, othe r persons on behalf
of whom the custom er is acting and th e beneficial owner(s) of the customer.

Article 13
Standard due diligence measures
1. Standard cu stom er due diligen ce m easures applied by o bliga ted per sons
should comprise:
(a) identifying the custom er and verifying the custom er’s identity on the basis of
docum ents, data or inform ation obtained from a reliable and independent source;
(b) identifying, where applicable, the beneficial owner(s) of the corporate
custom er, updating the infor mation and taking risk-based and adequate m easures to
verif y his identity so that the ob ligated perso n is satisf ied th at it knows who the
beneficia l o wner(s) is (are), including other natural or le gal persons on behalf of
whom the custom er is acting. As regards ot her legal persons, trusts and sim ilar legal
arrang em ents, obligated persons sh all take risk -based and adequate m easures t o
understand the ownership and control structure of the cu stom er. “Risk” denotes the
strong poss ibility of custom er involvem ent in comm itting or attem pting to comm it
the offences referred to in Articles 2 and 3;
(c) obtaining infor mation on the purpose and intended nature of the business
rela tionsh ip or of im portan t trans action s or activ ities of the cu sto mer or the
beneficial owner;
(d) exam ining with spe cial atten tion an y transac tio n or activity which, by nature
or by virtue of the custom er’s persona l circum stances or capacity, could be
associated w ith m oney laundering or terrorist financing.These tran sactions com prise
especially com plex or unusually large transactions and any unusual kind of
transaction that is conducted with no apparent econom ic or lawful purpose;
30

(e) taking any other appropriate m eas ure, including refraining from the
transaction and refusing to provide serv ices or carry ou t activities, unless the
custom er identif ica tion requir ements are m et;
(f) conducting ongoing monitoring of th e business relatio nship, including
scrutiny of transactions unde rtaken throughout the course of that relationship t o
ensure that the transacti ons being conducted are consis tent with the obligated
persons’ knowledge of the custom er and of the beneficial owner, the business and
risk profile, including, where necessary, th e so urce of funds, accordin g to criteria
determ ined by the relevant au thorities. The obligated p ersons ensu re th at the
docum ents, data or inform ati on held are kept up-to-date.

2. Credit and f inancia l institu tion s, in par ticu lar, m ust als o evalua te the
custom er’s overall business portfolio m aintain ed with the m and/or with oth er
com panies in their group, in the sense of Article 32, paragraph 2, in order to confi rm
that the tran saction is co nsisten t and com patible with such po rtf olio (s).

3. When the c ustom er is acting on behalf of othe r persons, he should state so
and, in addition to proving his own identity under para.1, shall prove the identity of
the third party, natural or legal person, on whose behalf he is acting. In any event,
obligated persons shall verify the accuracy of this inf orm ation when the custom er
does not m ake the said statem ent, but ther e are serious doubts about w hether he is
acting on his own behalf or it is certain that he is acting on behalf of others.

4. If, during the business relationship, the obligated person questions whether
the custom er is acting on his own behalf or it is certa in that he is not acting on his
own behalf, the obligated person should ta ke the required m easures to obtain
inform ation about the true identity of the persons on whose behalf he is acting.

5. Obligated persons apply, at the appropr iate tim e, risk-based due diligence
measures not only to new, but also to existing custom ers. Decisions of the
com petent authorities may determ ine the cr iteria and the method of application of
due diligence to existing custom ers.

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6. In the c ase of jointly h eld accoun ts of deposits, securities or other financial
products, the co-holders should be consider ed as custom ers and due diligence shall
also apply to all of them .

7. Decisions o f the relevant com petent autho ritie s m ay specif y further de tails
on the provisions of Re gulation 1781/2006/EC of the European Parliam ent and of
the Council (L 345/8.12.2006) on inform ati on on the payer accom panying transfers
of funds.

8. Where an obligated natural person perf orm s his professiona l ac tiv ities a s an
em ployee of an obligated legal person, the ob ligations under this law shall apply to
that legal p erson ra ther than to the n atura l person. W hen an obligated natural person
perform s hi s professional activity as an em ployee or associate, under any type of
contract or agreem ent, of a non-obligated legal person, that natural person shall
meet the obligations u nder this law, in accordance with the decisions of the
com petent authority which is th e sup ervis or of the relevant category of persons.

9. Where two or m ore credit instituti ons, financial institutions or other
obligated persons participate in any way what soever in a tra nsaction or a series of
rela ted tran sactions, ea ch of them shall app ly due dilig ence m easures, withou t
prejudice to the provisions of Chapter D. Th is shall be the case, in pa rticula r, with
insurance p olicies, pu rchases and sales of shares, derivatives, bonds or other
financial products and transact ions with cards of any type.

10. Obligated p ersons sha ll apply the c ustom er due dilig ence r equirem ents set
out in paragraph 1, but m ay determ ine the ex ten t of such m easures on a risk -based
basis depending on the type of custo mer, his eco nom ic st atus, business relationship,
product or transaction, in com pliance with the relevant decisions of com petent
authorities m ade pursuant to pa ra.4 of Article 6. Obligated persons should be able to
dem onstrate to the co mpetent au thorities tha t the exten t of the measures is
appropriate in view of the risks of offences referred to in Article 2, that they apply
such m easures consis ten tly and effectively and that they co mply with the decis ions
of the com petent authorities.

32

Article 14
Time of app lica tion of d ue dilig ence
1. The identification and verification of th e relevant data of the custom er and
the beneficial owner and other person(s) on whose behalf the custom er is acting,
should take place before the estab lishm ent of a business relationsh ip or the carrying
out of a transaction.
2. By way of derogation from paragraph 1, the ve rif ication of the iden tity o f
the persons referred to in paragraph 1 a bove, could be allowed to be com pleted
during the establishm ent of a business rela tionship if this is necessary not to
interrupt the norm al conduct of business a nd where there is lit tle risk of m oney
laundering or terrorist financ ing occurring. In such situ ations, these procedures
should be completed as soon as prac ticable after the initial contact.
3. By way of derogation from para graphs 1 and 2, in relation to lif e
insuranc e c ontrac ts, the verif ication of the identity of custom er and/ or of the
beneficiary under the policy could be allo wed to take place after the business
relationship has been established. In that cas e, verification sh all take place at or
before the tim e of payout or at or before the tim e the benef iciary intend s to car ry
out a transaction, includi ng but not lim ited to exerci sing rights vested under the
policy. Verification sho uld also ta ke place in th e case of Article 17, par agraph 5,
point (a), second sentence.
4. W here the o bliga ted per son is unab le to com ply with paragraph 1 of this
article or of points (a) to (c) and (f) of paragraph 1 of Article 13, it m ay not carry
out the transaction or esta blish a business relationshi p a nd c oul d t erminate t he
business r elationsh ip, c onsider ing the necessity of subm itting a repor t to the
Comm ission. The previous se ntence does not apply to la wyers when they are in
the cour se o f ascerta inin g the leg al p osition of their c lien t or perf orm ing their tas k
of defending or representing that client in or concerning j udicial proceedings,
including advice on instituti ng or avoiding proceedings.

33

Article 15
Anonymous accounts
Credit and financial institutions m ust not keep secret, anonymous or identified-by-
num ber accounts or an onym ous passbooks or accounts in fictitious nam es or
accounts without the full nam e of their hol der, in accordance with the identity
certification docum ents.

Article 16
Casinos
1. Casinos ope rating in Greece m ust verify the ide ntity of their custom ers on
entry in the gam bling fa cilities and take a ppropriate m easures to identify suspicious
cases that m ight relate to the offences refe rred to in Article 2. They should exam ine,
in par ticu lar:
a) custom ers who place larg e am ounts to any type of gam bling, when, according to
the inform ation available to the casino, the custom er does not have or does not
appear to have the corre sponding econom ic m eans; and
b) custom ers who win large am ounts in casino gam bling and there is evidence of
comm ission of the offenc es referred to in Article 2.
2. When casinos keep records on winnings and paym ents of chips in the nam es
of custom ers, thes e re co rds sha ll b e m aintain ed for at least five years pursuant to th e
procedures stipulated in th e decision s of the competent cas ino authority m entioned
in paragraph 4 hereof. This information sh all be m ade availab le to th e com petent
authority and the Com mission for inspection.
3. The provisions of this article appl y also to casinos operating on ships flying
the Greek flag.
4. Decisions of the relevant authority may further specify the above m easures
and other obligations of casinos under this law.
Article 17
Simplified c ustomer due dilig ence
1. By way of derogation from points a, b and d of Article 12, paragraph 1 of
Article 13 and paragraph 1 of Article 14, oblig ated persons are not be subject to the
34

requirem ents provided for in those provisions where the cu stom er is a credit or
financial in stitu tion situated in th e European Union or a third cou ntry whic h
im poses requirem ents equivalent to those la id down in Directive 2005/60/EC and is
supervised for com pliance with those requirem ents.
2. By way of derogation from points a, b and d of Article 12, paragraph 1 of
Article 13 and paragraph 1 of Article 14, oblig ated persons are not be subject to the
identity ve rif ication requ irem ents in r espect of :
a) lis ted co mpanies wh ose sha res are adm itte d to trad ing on a regu lated m arket
within the m eaning of Ar ticle 43 of L aw 3606/20 07 (Govern ment Gazette A 195) in
one or m ore Me mber States and listed com pani es from third countries which are
subject to disclosure requirem ents consis tent with th e provi sion s of Directiv e
2004/39/EC (L145/30.4.2004);
b) com panies operating as undertakings for collective investm ent in transferable
securities pu rsuant to Article 2 of Law 3283/2004 (Government Gazette A 210) and
com panies that operate as undertakings fo r collective investm ent in transferable
securities, are based in the European Un ion and operate in consistency with the
provisions of Directive 85/611/EEC (L 375/31.12.1985, p.3), as currently in force;
c) Greek p ublic au tho rities o r le gal per sons of public law or en terpr ises or
organisations in which the State ha s a participation of at least 51%;
d) public authorities or p ublic bodies that fulfil all of the following criteria:
i) they have been entru sted with public f unctions pursuan t to the Tre aty on the
European Union, the Treaties o n the Communities or Community secondary
legislation;
ii) their identity is publicly available, tr ansparent and certain;
iii) their activities, as well as thei r accou nting practices are tran sp arent;
iv) eithe r they are accoun table to a Co mmunity institu tion or to the author ities
of a Mem ber State, or appropriate check and supervising proce dures exist ensuring
contro l of their a ctiv ity.
3. In the cases referred to in paragr aphs 1 and 2, obligated persons should
gather suf ficient inf orm ation to es tab lish if the c ustom er qualif ies f or an exem ption
as m entioned in these paragraphs and sha ll decide on the basis of risk m anage ment
procedures. Decisions of the competent au thorities m ay specify th e sufficient
inform ation to be gathered.
35

4. The Ministry of Econom y and Fina nce, as the Central Coordinating
Authority inf orm s the European Comm issi on and the relevant Ministries of the
other Mem ber States of cases where it c onsiders that a third country m eets the
requirem ents of paragraphs 1 or 2 hereof, as we ll a s of cas es where it c onsiders that
the technical criteria establish ed in accord an ce with Article 40(1)(b ) of Directiv e
2005/60/EC are m et.
5. By way of derogation from points a, b and d of Article 12, paragraph 1 of
Article 13 and paragraph 1 of Article 14, oblig ated persons are not be subject to the
identity ve rif ication requ irem ents in r espect of :
a) life insurance policies, where the annual prem ium is no m ore than EUR
1,000 or the single prem ium is no m ore than EUR 2,500. W hen the prem ium
payable within a year increas es to m ore than EU R 1,000, the insured’s identity shall
be verified;
b) a pension, superannuation or sim ilar schem e that provides retirem ent
benefits to em ployees, where contributi ons are m ade by way of deduction from
wages and the schem e rules do not perm it the a ssignm ent of a m ember’s in ter est
under the schem e;
c) insuranc e polic ies f or pension s chem es concluded on the basis of
em ploym ent contracts or of professional ac tiv ities of the insur ed, provid ed that th ere
is no surrender clause and the polic y can not be used as collateral;
d) electronic money, as defined in Article 14(3) of Law 3148/2003
(Governm ent Gazette A 136), where, if the device cannot be recharged, th e
maximum a mount stored in the device is no more than EUR 150, or where, if the
device can be recharged, a lim it of EUR 2,500 is im pose d on the total am ount
transacted in a calendar year. W hen an amount of EUR 1,000 or m ore is redeem ed
in that sam e calendar year by the b earer as referred to in paragraph 6 of Article 14
of Law 3148/2003, identity veri fication should be conducted.
6. The com petent au thorities m ay issu e decisions specifying the details and
criter ia f or the de term ination of th e f oreign f inancia l in stitutions ref erred to in
paragraph 1 and the public authorities referred to in paragraph 2, point d.

36

Article 18
Non-reliable third coun tries
Where the European Comm ission adopts a decision pursuant to Article 40(4) of
Directive 2005/60/EC, oblig ated persons shall be prohibited from applying
sim plified due diligence to the legal persons ref erred to in Artic le 17(1 ) and (2)( a)
that are situated in the thir d country referred to in the sa id decision of the European
Comm ission.
Article 19
Enhanced Customer Due Diligenc e
Obligated persons shall apply, on a risk-based basis, enhanced custom er due
dilig ence m easures, in addition to the m eas ures ref erred to in Articles 13 and 14,
paragraph 1 hereof. More specifically, wit hout prejudice to Article 14, paragraph 2,
when obligated persons find that ther e are increas ed risks, they shall:
a) apply in a consisten t an d effective manner the m easures defined in Articles
20, 21 and 22, in the cases referred to in such Articles;
b) take any other appropriate m easur e decided b y the com petent au thority
supervising them to pre vent the commission of the off ences m entioned in Article 2 ,
includ ing th e caref ul e xam ination of the total portf olio( s) of the custom er, the
beneficial owner, the person(s) on whose be half the custom er is acting, the relatives,
the spouses, partners and close associates of those persons for at least the three
preced ing calendar y ears.

Article 20
Transaction s without th e physic al presence of the customer –
Risks from new products and technologies
1. Obligated p ersons tak e specific and adequate m easures to co unter the h igher
risk in cas es where the custom er is no t ph ysica lly p resent f or id entif ica tion
purposes, mainly by applying one or more of the following measures:
a) ensuring that the custom er’s identity is verified by additional documents,
data or inform ation;
37

(b) taking supplem entary measures to ve rify or certify th e docum ents supplied,
or requiring confirm atory certification by a credit or financial institution based i n
the European Union;
(c) ensuring that the first paym ent of t he operations is carried out through a n
account opened in the custom er’s nam e with a cred it in stitu tion bas ed in the
European Union.
Decisions o f the com petent autho rities spec ify the m easur es ref erred to in th is
paragraph and determ ine procedures for their effec tive application.
2. Obligated persons pay special attenti on to any product or transaction which
might favour anonym ity and which, by nature or by virtue of infor mation about the
prof ile of th e chara cteris tic f eatures of the custo mer, m ay be associated with m oney
laundering or terrorist financi ng and take appropriate m eas ures to avert this risk.
3. The com petent authorities take appropriate m easures to ensure that obligated
persons implem ent organiza tional, functional and tech nological procedures t o
prevent the risks associated with technological advances or new financial products.
Article 21
Cross-border correspon dent banking
1. In respect of cross-border corresp ondent banking relationships of greek
credit institutions with respondent institutions from third (non-European Union)
countries, credit institutions should:
a) gather sufficient information about a respondent institution to understand
fully the nature of the respondent’s business and to determ ine from publicly
available inform ation the reputation of the institution and the quality of supervision
on it;
b) assess the respondent institu tion ’s an ti-m oney laundering and anti-terro rist
financing controls;
c) provide for the approval from senior m anage ment before establishing new
correspondent banking relationships;
d) docum ent the respective responsibilitie s of each party to the corresponding
banking agreem ent;
e) with respect to payable-through account s, be satisfied that the respondent
credit institution has verified the id en tity of and perform ed ongoing due diligen ce
38

on the custo mers having direct access to accounts held in the correspond ent and that
it is able to provide relevan t cus tom er due d ilig ence data to th e co rresponden t
institution, upon request.
2. Credit institutions are prohibited from entering into or continuing a
correspondent banking relations hip with a shell bank and shall not engage in or
continue correspondent banking relationships with a bank that is known to perm it its
accounts to be used by a shell bank. The Bank of Greece shall ensure cred it
institutions’ com pliance with the abo ve ob ligations and m ay define which of these
requirem ents are applicable to corresponde nt banking relationships with credit
institutions authorized in Europ ean Union m ember countries.
Article 22
Politically exposed persons
1. For the purposes of this Article, “po litically exposed pe rsons who are or
have been entrusted with prom inent public functions” include the following natural
persons:
a) heads of State, heads of government , m inisters and deputy or assistant
ministers;
b) m embers of parliam ents;
c) members of suprem e courts, of con stitu tion al c ourts o r of other h igh- level
judicial bodies whose decisions are not su bject to further app eal, except in
exceptional circum stances;
d) m embers of cour ts of au ditors ;
e) members of the boards o f central b anks;
f) am bassadors and chargés d’affaires;
g) high-ranking officers in the arm ed forces;
h) members of the adm inistrative, m anage ment or supervisory bodies of State-
owned enterprises.
None of the categories set out in points (c) to (h) shall be understood as covering
middle ranking or m ore junior officials.

2. The categories set out in points b to g of paragraph 1 include positions
at
Community and inte rnational lev el.
39

3. For the purposes of this Article, “ immediate family me mb ers” include the
following:
a) the spouse;
b) any partner considered by nationa l law as equivalent to the spouse;
c) the natural or adopted childre n and their spouses or partners;
d) the parents.

4. For the purposes of this Article, “per sons known to be close associates”
include the f ollowing:
a) any natural person who is known to have joint beneficial ownership of legal
entities or legal arrangem ents, or any othe r close business relations, with a person
referred to in paragraph 1;
b) any natural person who has sole bene ficial ownership of a legal entity or
legal arrangem ent whic h is known to have b een set up for the benefit de facto of the
person referred to in paragraph 1.

5. W ithout prejudice to the application, on a risk-sensiti ve basis, of enhanced
custom er due diligence m easur es, where a p erso n has ceased to be en trus ted with a
prom inent public f unctio n within the m eani ng of paragraph 1 for a period of at least
one year, obligated persons ar e not be obliged to consider such person as politically
exposed.

6. As regards transactions or business relationships with po litically exp osed
persons, obligated persons m ust:
a) have appropriate risk-based procedures to determ ine whether th e cus tomer is
a politically exposed person;
b) have senior m anage ment approval for establishing business relationships
with such cu stom ers;
c) take adequate m easures to establish the source of wealth and source of funds
that a re invo lved in the b usine ss relationship or transactions;
d) conduct enhanced ongoing m onitori ng of the business relationship.

40

7. The com petent authorities m ay specify by decisions the m anner of
im ple mentation of the above obligations.

8. Politically exposed persons do n ot include persons resident in Greece.
Standard due diligence m easures shall apply to such persons.

CHAPTER D
Performa nce of customer due diligence by third parties

Article 23
Eligible thir d parties an d their ob lig ations
1. The obligated persons referred to in para graph 5 of this Article m ay rely on
third pa rties to m eet the requir ements laid down in points a and b of paragraph 1 of
Article 13. Such third parties m ust reco mm end or introduce persons only from
am ong their own custom ers and must al ways conduct cus tom er due dilig ence in
accordan ce with this Law. However, the u ltim ate responsibility for m eeting the
aforem entioned requirem ents shall rem ain w ith the obligated person which relies on
the third party.

2. For the purposes of this Law, “third parties” sh all m ean:
a) cr edit institutions;
b) investm ent firm s;
c) m utual funds; and
d) insurance com panies only in r espect of insurance in term ediarie s, which a re
located in a Mem ber State of the Europ ean Union or in a FATF m ember third
country. W here obligated persons rely on a third party, they m ust always identify
the custom er, any third person on behalf of whom the custom er m ay be acting and
the beneficial owner.

3. Persons relying on a third party m ust al so ensure that such third party
a) can m ake imm ediately available, u pon request, any inform ation obtained while
applying the custom er due diligence m easures in respect of the custom er, any third
person on behalf of whom the custom er m ay be acting and the beneficial owner; and
41

b) can forward imm ediately, upon request, a ny copy of identification and identity
verification docum entation obtained while applying the custom er due diligence
measures in respect of th e persons m entioned in (a).

4. If the third party’s busine ss re lationship with their cust omer ends for any reason
whatsoever, the obligated person shall verify the identity of the custom er and apply
the com plete custom er due diligence m easures.

5. The obligated persons covered by this Law may rely on third parties on ly if they
are cr edit o r financial in stitu tion s. If not, their re spective co mpet ent authorities m ay
set out the criteria and requirem ents for th e sup ervised natu ral and legal persons to
be able to do so, in conform ity w ith the prov isio ns of this Ar tic le.

Article 24
Status of th ird countries
1. The Ministry of Econom y and Fina nce, as the Central Coordinating
Authority, inf orm s the o ther Mem ber Sta tes and the European Comm ission of cases
where it considers that a third country m eets the conditions laid down in paragraph
l(b) of article 15 of Directive 2005/60/EC. It shall also receive assessm ents by other
Mem ber States and shall notify accordingl y the appropriate com petent authorities,
which shall then convey the relevant info rm ation to the obligated persons, with
instructions on how to handle such infor mation. Such assessm ents by other Mem ber
States are not binding.

2. Where the E uropean Co mmission ad opts a decision pursuan t to Article 40 (4)
of Directive 2005/60/E C, the obligated pers ons m ay not rely on third parties from
the third country concerned in order to m eet the requirem ents laid down in
paragraph 1 of Article 23.The Ministry of Economy and Finance should infor m the
com petent authorities of any such decisions.

Article 25
Exemptions and decisions by competent authorities
42

1. Article 23 does not apply to outsourci ng or agency relationships where, on
the basis of a contractual arrangem ent, th e outsourcing service pr ovider or agent is
to be regarded as part of the obligated person.

2. The com petent au thor ities m ay spec ify deta ils for th e im plem entation o f the
provisions of this Chapter.

CHAPTER E
Reporting obligations and prohibition of disclosure

Article 26
Reporting o f suspic ious transactions to the Commiss ion
1. The obligated persons and their staff, including m anagers, must:
a) prom ptly inform the Comm ission, on their own initiative, where they know,
suspect or have reasonable grounds to su spect that m oney laundering or terrorist
financing is being or has been committed or attempted; and
b) prom ptly furnish the Comm ission or other anti-m oney laundering and anti-
terrorist financing authoritie s, when requested, with a ll necessary inform ation, in
accordan ce with the p rocedures establis hed by the applicable legisla tion.

2. The persons referred to in points e, f and m of paragraph 1 of Article 5 hereof
shall no t be subject to the requirements of the preced ing p aragr aph in respect of
inf orm ation rece ived f rom or regar ding any of their clients while th ey are in the
course of ascertaining the lega l position for their client or representing that client in
or concern ing judic ial proceed ings, incl ud ing advice on institu ting o r avoiding
proceed ings, irresp ective of whether the in formation is received before, during or
following th e proceed ings.

3. Foreign branches an d rep resen tative o ffices of Greek cred it and financial
institutions should forward the inform ation referred to in paragraph 1 above to the
foreign equivalent of the Comm ission – whether a body, a unit or other authority of
the host country– and to their respective parent com pany, notw ithstanding Articl e
32(2) and (4) below.

43

4. Suspicious transaction reporting to the C omm ission by credit and financial
institutions and financial groups is effect ed in accordan ce with the provisions of
Article 44.

Article 27
High-r isk tr ansactions – Refraining from exe cuting suspicio us transactions
1. In the cases of high-risk transactions as described in point d of paragraph 1 of
Article 13 and provided that an officer has been appointed under paragraph 1 of
Article 44, such officer should be promptly inform ed, a report shall be prepared and
the need for reporting to the Comm ission shall be exam ined.

2. The obligated persons m ust refrain from carrying out transactions, engaging in
activities or providing any services, which th ey know or suspect to be related to the
offences set out in Article 2, unless refraining in such m anner is im possible or likely
to frustrate efforts to pu rsue the cu stom ers, the beneficial ow ne rs or the persons on
behalf of w hom the custom ers may be acting ; in the latter ca se the oblig ated persons
shall execute the aforem entioned operations and sim ultaneously infor m the
Comm ission.

Article 28
Reporting o bligations o f compe tent authorities and market operators
1. The com petent au thorities m ust prom ptly inf orm the Comm ission if , in the course
of inspectio ns carr ied out in the obliga ted persons, or in any other way, they
discover facts that could be related to the offences set ou t in Artic les 2 an d 3.

2. Operators of m arkets for stocks, bonds, other financial instrum ents, financial
derivatives and foreign exchange must have in place adequate m echanism s and
procedures for the prevention and i mmediate detection of possible cases of
comm itting or attem pting to comm it the of fence s set out in Artic les 2 and 3, and
report to the Comm ission without delay all cases where they reasonably suspect that
any of the above m ay be happening, also providing all the relevant inform ation and
44

data and an y assistan ce as necessary for th e investigation of such cases. Included in
the above m arkets are the Electronic S econdary Securities Market (HDAT), the
Multila tera l System s for Trading in f ina ncial instrum ents provided for in Law
3606/2007 (Governm ent Gazette A 195), as well as in-house m arkets for financial
instrum ents operating within a credit institution or an investment firm .

3. The supervisory bodies which oversee th e m arkets referred to in paragraph 2
above take all appropriate m easures to ensure m arket operato rs’ com pliance with
their obligations, the effec tive operation of their system s and the adequate training
of their em ployees.

Article 29
Reporting o bligations in relation to offences
against tax or customs legislation
Where predicate offences consist in offen ces against tax or custom s legislation or
other offences that fall within the fields of responsibility of the Special Audits
Service (YPEE), the follow ing procedure applies:
a) The YPEE is authorised to bring to justice any cases of m oney laundering
relating to sm uggling, tax evasion and cases that fall within its other fields of
responsib ility, after having prepared a conc lusiv e report. Th e report is s ubm itted to
the com petent Public P rosecutor an d is imm ediately communicated to the Central
Service of the YPEE, 3rd Directorate of Special Cases, Departm ent B – Special
Econom ic Cases, and to the Comm ission. The YPEE m ay refer to the Comm ission
any cases for which it has not prepared a conclusive report, a nd cooperate with it,
includ ing b y joint inv estig ation s into cases for which they have a shared
responsibility.
b) For th e aforem ention ed cases that are exam ined by the In ternal Revenue Offices
or the Local and Regional Tax Audit Centers or Custom s Offices, reports should be
subm itted to the Comm ission and the YPEE, through the relevant General
Directo rates of Tax and Custom s Controls.
c) The obligated persons m ust report to th e Comm ission any suspicious transactions
which are likely to be re lated to the above offences . An exception is m ade for
lawyers who m ay repor t such trans action s to th e spec ial co mmittee p rovided f or in
Article 34.
45

Article 30
Protection of reporting employees
A joint decision of the Minister of Econom y and Finance and the Minister of Justice
may specify m easures to protect th e ob ligated persons’ employees and obligated
natura l pe rsons repor tin g, eith er internally or e xterna lly to the Comm ission or the
Public Pros ecutor, susp ected cas es of committing or atte mpting to comm it the
offences set out in Article 2, for m threats or ho stile acts.

Article 31
Prohibition of disc losur e
The obligated persons and their directors and em ployees must not disclose to the
custom er concerned or to other third pers ons the fact that inform ation has b een
transm itted or shall b e transm itted to the Commission or o ther public authorities or
has been sought by them or that an investig ation is being or shall be carried out in
relation to the offences of Article 2 and 3 hereof. The above also applies to the
Chairm an, the board m embers and staff of the Comm ission, m anagers and staff of
the com petent autho rities, as well as to other public servants who m ay be aware of
the facts referred to in the preced ing sent ence. Natural p ersons who intentionally
violate their duty to observe secrecy are punished by i mprisonm ent for not less than
three m onths and a pecuniary penalty.

Article 32
Exemptions from the p rohibition of disclosur e
1. The disclosure of inf orm ation provided fo r in Articles 26 to 29, either internally
to the com petent s tructu re of the leg al pers on or externally to the Comm ission or the
Public Prosecutor, by the persons referred to in Artic le 3 1 shall not constitute a
violation of the disclosure prohibiti on im posed by Article 31 or by any other
legislative, regulatory, adm inistrative or contractual provi sion and shall not involve
these persons and the relevant legal persons in liability of any kind, unless they have
not acted in good faith.

2. The prohibition laid down in Article 31 shall not prevent the exchange of
inform ation between credit or financial ins titutio ns situated in Greece or in another
Mem ber State and belonging to the sam e gr oup a s defined in paragraph 4 of Article
46

4. This also applies to the exchange of inf ormation b etwe en cred it or financia l
institutions situated in Greece and sim ilar institutions of the sam e group which are
situated in a third country that im pos es requi rements at least equiva lent to those laid
down herein and which are subject to supe rvisio n of their com pliance with those
requirem ents.

3. For th e o bliga ted pe rsons ref erred to in points e, f and mof paragraph 1 of Article
5, the prohibition la id down in Ar tic le 31 sha ll no t p reve nt dis closu re between
persons operating in Greece and p ersons reside nt in ano ther Mem ber State, o r in a
third country which i mposes requirem ents at least equivalent to those laid down
herein, provided that they perf orm th eir professional activities, whether as
em ployees or not, within the sam e le gal person, financial group or network. For the
purposes of this Ar tic le, a “ne twork ” m eans the larg er s truc ture to whic h the lega l
persons belong and which share common ownership, m anagem ent or com pliance
control.

4. The obligated persons referred to in poi nts a, b, e, f a nd m of paragraph 1 of
Article 5 which are situated or co nduct their business in Greece m ay exchange
inf orm ation with person s f rom the s ame profess ional category regarding the sam e
custom er and the sam e transactions or act ivities involving two or m ore of the above
persons. The foregoing shall also apply to the exchange of infor mation between
resident obligated persons and natural or legal persons from the sam e professional
catego ry situated or con ducting their busine ss in another Member State or in a third
country that im poses requirem ents at least equivalent to those laid down herein,
provided that such persons are from the sam e professional cate gory and are sub ject
to at lea st e quivalen t obliga tions as re gards professional secrecy and personal data
protection. The inform ation exchanged is used exclusively fo r the prevention and
suppression of the offenc es of Article 2.

5. W here lawyers and notaries seek to dissu ad e a client from e ngaging in illegal
activ ity, th is does no t co nstitu te a v iolation of th e proh ibitio n la id down in Ar tic le
31.

47

6. Decisions of the competent au tho rities m ay further specif y the provisions of this
Article and requirem ents for the exchange of inform ation.

Article 33
Non-reliable third coun tries
Where the European Comm ission adopts a decision pursuant to Article 40(4) of
Directive 2005/60/EC, it shal l be prohibited the disclo sure of any infor mation
between the obligated persons referred to in paragraphs 2, 3 and 4 of Article 32
hereof and legal or natural persons situ ated, operating or c onducting their business
in the third country concerned.

Article 34
Committee of lawyers
A comm ittee of lawyers, com posed of five mem bers, appointed for a three-year
term by the Plenary of the National Federa tion of Bar Associations, located at the
prem ises of the Athens Bar Assoc iation, is establish ed with the task to rec eive
lawyers’ rep orts on susp icious o r un usual a ctiv ities or tr ansa ctions, to a ssess th eir
com pliance with the provisions herein a nd f orward them wit hout delay to the
Comm ission. A decision of the Minister of Justice, following consultation of the
above Plen ary, shall s pecify the operating p rocedures o f the comm ittee, the
procedure for its receiv ing lawyers ’ repor ts fro m all over Greece, as well as th e
procedure for its cooperation and communication with the C omm ission.

CHAPTER F
Record keeping and statistical data

Article 35
Record and data keepin g by obligated persons
48

1. Obligated persons shall keep the following docum ents and infor mation for use in
investigations into any possi ble attempt or actual comm ission of any of the offenc es
referred to in Article 2 by the Comm issi on, the com petent authority supervising
them or any other competent public au thority, including th e prosecutorial and
judic ial au thorities :
a) the custom er identif ication inform ation and data on its verification, upon the
conclusion of any agreem ent, for a period of at lea st f ive years af ter the business
rela tionsh ip with the cu stom er has ended;
b) the authoriza tion docum ents, the photocopies of docum ents on the basis of
which the identity of th e custom er was cer tified and verified, a nd th e origin als o r
copies of the docum entation of all kinds of transactions, fo r a tim e perio d of at leas t
five years f ollowing th e end of the busine ss relationship o r the execution of each
transaction;
c) the internal docum ents c oncerning approvals or verifi cations or proposals in cases
rela ted to in vestig ation s into th e abo ve of fences or case s rep orted o r not reported to
the Comm ission, for a tim e period of at l east five years following the end of the
business relationship with the custom er involved in the above cases;
d) data on business, commercial and profe ssional corresponden ce with custom ers,
as these m ay be specified by the competent autho rities.

2. All the data and docum ents referred to in subparagraphs (a), (b), (c) and (d) of
paragraph 1 shall be kept in writing or in electron ic form, for the tim e period
referred to in these subpa ragraphs, unless a longer ti me period is required by
another provision of la w or regulatory decision.

3. The above data shall be kept in such a way as to enable the obligated person to
respond promptly to any request of the Commission, the competent authority or any
other com petent public authority without dela y f or the establishm ent of a udit trails.

Article 36
Record and data keepin g b y subsidiar y compan ies and bran ches in
other countries
1. Credit an d f inancial institu tion s shall app ly in their sub sidiary com panies, with in
the m eaning of para. 4 of Article 4, and in their branches in other countries
,
49

measures which are at least equivalent to those ref erred to in ar tic le 35 on reco rd
and data keeping. W here the legislation of a non-EU country does not allow the
im ple mentation of such m easures, wholly or partly, the above persons shall inform
to this effect the Commission, the co mpetent authorities and the Central
Coordinating Authority.

2. The Cent ral Coordinating Authority sha ll in form the European Comm ission on
any situations where the legislation of a non-EU country does not perm it, wholly or
partly, the application of the m eas ures referred to in Article 35.

3. Credit an d financial institu tion s shall, where the leg islatio n of a non-EU country
does not perm it the application of the m easures required unde r article 35, take
additional m easures to effectively m anage the risk of comm ission of the offences
ref erred to in Artic le 2 . The com petent author ities m ay specif y these addition al
measures by their decisions.

Article 37
Application of procedures and systems
1. Credit and financial institutions shall hav e in place p rocedures a nd system s
enabling them to respond fully and rapi dly to any request or enquiry by the
Comm ission, the com petent authority supe rvising them or any other com petent
public auth ority, as to whether they m aintain or have m aintained, during the
previous five years, a business relationshi p with specific natural or legal persons,
the natu re of this r elation ship a nd any other relevant transaction.

2. By decisions of the com petent authori ties supervising obligated persons other
than c redit a nd f inancia l institu tions, oblig ations of these oblig ated perso ns sim ilar
to those referred to in para . 1 can be specified on an ad hoc basis .

Article 38
Collection, keeping and processing of statistical data by public authorities
1. All pub lic author ities invo lve d, includ ing the M inistry of Justic e, the
Comm ission, the com petent and judicial authorities, th e prosecutorial, police and
tax authorities and services, shall keep co mplete and updated sta tistical data relating
50

to areas or m atters f alling within their scope of authority. These data shall be
collected by the Central Coordinating Authority every calend ar sem ester.

2. These sta tistics sha ll cover at least:
a) The number of reports of suspicious or unusual transact ions or activities
subm itted to the Commi ssion, the classification of these rep orts according to sender,
the num ber of findings reports submitted to the Public Pro secutor f or inv estig ation,
the num ber of archived cases, and data on the international cooperation of the
Comm ission with foreign peers;
b) the collection, classificati on and processing of the data referred to in Article 39;
c) the sta tis tical da ta ref erred to in para graph 7 of Article 6 which are included in
the half -ye arly repor ts of the com petent autho ritie s; and
d) the sta tistic al da ta m entioned in th e regulatory d ecis ions of the com petent
authorities.

3. The Ministry of Justice, the Commissi on and the competent au thorities sha ll
publish agg regated s tatis tics in orde r to inform the public fully and adequately.

Article 39
Collection of judicial data and information
1. A decision of the Minister of Jus tice shall lay down the procedure and the
technical details for the collec tion, classif ication and processing of statistical data on
the cas es th at com e before the cou rts of any degree of jurisdiction and concern the
offences referred to in A rticle 2, the num ber of cases investig ated and the num ber of
persons prosecuted, the relevant court j udgm ents or decrees, and any property
confiscated or seized. T he sam e decision shall also lay d own the procedure for
monitoring the jud icia l progress of the repo rts subm itted by the Comm ission to the
com petent Public Prosecutor.

2. The services of the Ministry of Jus tice shall also ensure th e colle ction ,
registration and processing of data sim ila r to the above on the m ost im portant
catego ries o f predicate offences, requesting inf orm ation fr om the secretariats of
Public Prosecutors’ Offi ces and Courts and fr om police services.
51

CHAPTER G
Implementation measures

Article 40
Cooperation and exchange of confidential information
1. During an adm inistrative investigation carried out by the Comm ission into any
case, the Prosecutorial Authority and the investigating judge may request
confidential inform ation. Once the investig ation has ended and the case has been
archived, they m ay request data or the entire f ile of the case.

2. The Commission m ay forward confidenti al inf orm ation to the com petent
authorities, Prosecutorial Au thor itie s, the Spec ial Control Service, the Nationa l
Inte llig ence Service, th e com petent servic e of the Hellenic Coast Guard and the
units of the Hellenic Police, as s pecified by a joint Decision of the Minister of the
Econom y and Finance and the Minister of the Interior, where such inf orm ation is
deem ed use ful for the investigating tasks of the aforem ention ed agencies and for the
fulfilm ent of their m andate. This inf orm ati on is f orwarded eithe r at the initiativ e of
the Comm ission or following a reasoned request by the said agencies, without
prejud ice to the pre ceding paragraph.

3. The Comm ission m ay request inform ation on the results of any investigation that
has been carried out by the aforem enti oned agencies, with the exception of
prosecutorial and investigating judicial au thorities, on the basis of the infor mation
supplied under paragraph 2, as well as any inform ation provided for in Article 7 of
this Law.

4. The competent authorities m ay excha nge confidential inform ation about the
fulfilm ent of their oblig ations under this Law and shall inform each other about the
52

results of relevant investigations. B ila ter al or m ultilate ral mem oranda of
understanding m ay specify the m oda lities for such exchange of infor mation.

5. A decision of the Minister of Econom y and Fi nance lays down the procedures for
the exchange of confidential informati on between the Comm ission, the com petent
authorities, the tax and custom s authorities and the Special Control Service, for the
fulfilm ent of their oblig ations ar ising f rom this Law.

6. Joint decisions of the Minister of Ec onomy and Finance and of the relevant
Minis ter sp ecify the procedures and sc ope of the exchange of confidential
inform ation between the Comm ission and th e competent authorities on the one hand
and the s ervices of the Hellenic P olice, the N ationa l In telligenc e Serv ice and the
com petent service of the Hellenic Coast Gu ard on the other, f or the f ulfilm ent of
their oblig ations ar ising f rom this Law.

7. The agen cies referred to in parag raphs 4, 5 and 6 of this article m ay carry out
joint investigations into cases of co mmon interest and responsibility, for the
fulfilm ent of their oblig ations ar ising f rom this Law.

8. The inf orm ation ref erred to in th is article in cludes any inf orm ation which the
agencie s tra nsm itting o r exchang ing it hav e obtained in the con tex t of their
international cooperation with their fore ign counterparts, provided that this is
perm itted by the term s and condition s of such cooperation.

9. For the purposes of the im ple mentation of the provisions of this Law, confidential
inform ation m eans any i nfor mation about th e business, professional or comm ercial
behaviour of legal or natural persons, data and facts regard ing their trans action s and
activ ities, or tax re cords and inf ormation on crim inal offences and breaches of tax,
custom s or other adm inistra tive laws and regulations.

Article 41
Internal procedures
1. The obligated persons should apply ad equate and approp riate policies and
procedures with respect to custom er due di ligence and the actual beneficial owner,
53

reporting of suspicious transactions; r ecord -keeping ; interna l con trol; ris k
assessm ent; continuous assessm ent of th e de gree of compliance and internal
communication, in order to prevent transactions and activities that m ay be
associated w ith th e offences referred to in Article 2.

2. Credit and financial institutions ensure that the provisions of this law are
also im plemented by th eir subs idia ries, with in the m eaning of pa ragraph 4 of Article
4, provided that the latter are obligated pe rsons , as well as by their branches and
representative offices abroad, unless this is wholly or partly forbidden by the
relevant foreign legislati on. In that case they must inform the Comm ission, the
com petent authority sup ervis ing them a nd the Central Coordinating Authority. In
any case, they should apply the stricter law between th e Greek law and the law of
the host country, to the extent allo wed by the law of the host country.

3. The com petent autho rities superv ising obligated persons other than credit
and financial institutions m ay further specify by decisions the obliga tion s ref erred to
in paragraph 1, taking into account the fact ors referred to in pa ragraph 4 of Article
6, in pa rticu lar the d istin ction b etwee n ob liga ted natura l pe rsons and obligated legal
persons.

Article 42
Education and Training
The obligated persons take appro priate m easures so that their em ployees are
inf orm ed about the p rovisions of this law and the re levan t regu lato ry decis ions.
These m easures in clud e, inte r alia , the com petent em ployees’ participation in
special training courses that help them id entify activities that m ay be associated
with the of fences ref erred to in Article 2 a nd train them to take proper action in such
cases.

Article 43
Conditions of incorpor ation, opera tion and reg istra tion
1. W ithout prejudice to the provisions governing the author isation of incorporation,
operation or regis tration , the com petent author ities sha ll ref use to au thorise the
incorporation, operation or registration of obligated leg al p ersons unle ss they are
54

convinced that the persons holdi ng a substantial stake in th e capital or controlling or
actually m anaging the undertaki ngs of such persons or thei r actual beneficial owners
are appropriate and honourable persons.
2. In orde r to pursue th eir bus iness activ ities, paym ent institu tions ref erred to in
Directive 2007/64/EC on paym ent services in the internal m arket shall obtain
authorisation of operation from , be regi stered and supervised by, the com petent
authority.

Article 44
Compliance offic ers – O bligations o f financia l g roups
1. Each credit or financial institutio n appoints a m anage me nt officer (the
com pliance officer) to whom all other m anage ment officers and e mployees should
report any transaction they consider as unus ual or suspicious a nd suggestive of an
attem pt at, or comm ission of, the offences re ferred to in Article 2, and any event of
which they are aware in the context of their duties th at co uld be an indication of
such acts. In branches or special dep artm ents or units, such events shall be reported
directly to the m anager of the branch or departm ent or unit, who shall report them
imm ediately to the com pliance officer, provide d that he shares the suspicions. If the
manager or his alternate is unavailable or refuses or shows negligence or does not
share the su spicions of the reporting em ployee, then the em ployee m ay report to th e
com pliance officer. The latter shall inform the Comm ission by phone or a
confidential docum ent or secure electr onic m edium , providing any usef ul
inform ation or data, if after an exam ination he judges that the inform ation and
existing data justify such report. The provisi ons of this paragraph shall also apply to
other obligated legal persons, determ ined accord ing to the criteria laid down by the
relevant decisions of the com petent authorities.

2. Every financial group shall appoint a manage ment officer from the largest
com pany in the group as coordinator respons ible for ensuring com pliance with the
requirem ents of this law by the group’s co mpanies. T o this end, this officer
cooperates and exchanges info rm ation with the m anage ment officers of the group’s
com panies defined in paragraph 1; is info rm ed about any reports m ade by them to
the Comm ission; and m ay subm it reports to the Comm ission him self, providing data
from all the com panies of the group.
55

Decisions o f the com petent autho rities supervising the largest com pany of each
group m ay law down procedures and obligatio ns to be complied with by groups and
the com panies of each group.

CHAPTER Η΄
Criminal and administrati ve sanctions, seiz ure
and confiscation of assets

Article 45
Criminal sa nctions
1.a) Person s who have comm itted m oney laundering s hall be pu nished with
im prisonm ent of up to 10 years and a pecuniary penalty of €20,000 to
€1,000,000.
b) The perpetrator of the o ffence referred to in (a) a bove shall be punished with
im prisonm ent (i.e. a term from 5 to 20 years) and a pecuniary penalty of
€30,000 to €1,500,000 if he acted as an em ployee of an obliged legal entity or
the p redic ate of fence is inc luded in the o ffences ref erred to in Ar tic le 3 (c), (d)
and (e) abo ve, even if a term of i mpris onm ent of less than 5 years is envisaged
for these offences.
c) The perpetrator of the offence referred to in (a) above shall be punished with
im prisonm ent of at least 10 years and a pecuniary penalty of €50,000 to
€2,000,000 if he engages in these activities pr ofessionally or out of habit or he is
a recidivist or has acted on behalf of, for the benefit of, or as a m ember of a
crim inal or terrorist organisation or group.
d) An e mployee of an obliged legal enti ty or any other person obliged to report
suspiciou s transac tions shall b e pun ished with a term of imprisonm ent up to 2
years if he intentionally fails to report to the co mpetent authorities susp icious o r
unusual tran sactions or activ ities o r provi des false or m islead ing data, in breach
of the relevant legal, ad ministrative or regulatory pr ovisions and rules, provided
that his act is not punishable w ith heavier crim inal sanctions.
e) Crim inal responsibility for the predicat e offence shall not exclude the punishm ent
of offenders (the principal and his accom plices) for t he offe nces referred t o in
56

item s (a), (b) and (c) of this paragraph, if the circum stances of the ML a cts are
different from those of the predicate offence.
f) If the envisaged penalty for the pred icate of fence is a- term of im prisonm ent u p
to 5 years, offender shall be punished for th e ML offence with a term of
im prisonm ent of at least 1 year (up to 5 years) and a pecuniary penalty of
€10,000 to €500,000. The sam e sanction shall apply to any ML perpetrator who
is not an accom plice to the predicate offe nce if he is a lineal re lative of the
perpetrator of the predicate offence by bl ood or affinity, or a collateral relative
of up to second degree, or a spouse, adop tive parent or adopted child thereof.
g) If the perpetrato r of the pred icate offence was conv icted for th is offence,
im posed on him or a third person of those referred to in the second sentence of
item (f) for comm itting ML of the illic it proceeds gen erated by the sam e
predicate of fence, m ay not exceed the penalty imposed for the comm ission of
the pred icate offence.
h) The provisions of item s f” and g’ shall not apply to the circum stances of item c’
above and to the predicate offences re ferred to in case b’ of this article.
i) If the envisaged sanction for the pred icate of fence is a te rm of i mprisonm ent up
to 5 years and the ille gal gains do not exceed €15,000, the penalty for m one y
laundering shall be a term of i mprisonm ent of up to 2 years. If the circum stances
ref erred to in item (c) apply to the perpet rato r of the pred icate offence or to a
third person, the penalty for m oney launde ring shall be a term of i mprisonm ent
of at least 2 years and a pec uniary penalty from €30,000 to €500,000.

2. Crim inal prosecution and conviction of th e perpetrator of the predicate offence
shall not be a precondition for prosecu ting and convicting som eone for m oney
laundering.

3. W hen the respondent’s crim inal liability is rejected by the Court, he is acquitted
because the act is no longer prosecutab le or because th e person who suffere d
dam age has obtained satisfaction for the pr edicate offence (provided that under the
law satisfaction m ay bring about this resu lt), crim inal liability shall also be
elim inated o r the of fender sha ll b e acquitted of the relevant ML acts. This provision
shall not apply where crim inal liability has been elim inated due to prescription.

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4. W here this article provides for cum ulative custodial sentences and pecuniary
penalties, Article 83(e) of the Crim inal Code shall not apply.

5. The felonies provided for by Article 2 shall be tried by the Three-Judge Court of
Appeal for Felonies 1.

Article 46
Confiscation of assets
1. Assets derived from a predicate offence or the of fences ref erred to in Artic le 2 o r
acquired directly or ind irectly out of th e proceeds of such offences, or the m eans
that we re u sed or were going to b e used f or comm itting these of fenc es sha ll b e
seized and, if there is no le gal reason for returning them to the owner according to
Article 310(2) and the last sentence of Article 373 of the Code of Crim inal
Procedure, shall be compul sorily confiscated by virtue o f the court’s sentence.
Confiscation shall be im posed even if the assets or m eans belong to a third person
provided that such person was aware of the predicate offence or the offences
referred to in Article 2 at the tim e of their acquisiti on. The provisions of this
paragraph shall also apply in cases of attem pts to comm it the above offences.

2. W here the assets or p roceeds referred to in para. 1 above no longer ex ist or have
not been found or cannot be seized, assets of a value equal to that of the said assets
or proceeds as at the tim e of the court sentence shall be s eized and c onfiscated
accord ing to the conditio ns of para. 1. Their valu e shall be determ ined by the court.
The court may also im pose a pecuniary penalty up to the value of the said assets or
proceeds if it rules th at there are no add itio nal asse ts to be confiscated or th e
existing ass ets f all sho rt of the valu e of the said assets or proceeds.

3. Confiscation shall be ordered ev en wher e n o crim inal proceed ings have been
initiated because of death of the offende r or where pro secution was term inated or
declared inadm issible. In these cases, c onfiscation shall be ordered by a decree of
the com petent judicial council or the c ourt decision term inating prosecution or
declaring p rosecution in adm issible. If no cr im inal p roceed ings have been institu ted,
1 Felon ies are seriou s crimin al o ffe nces puni shabl e by a t erm of im prisonment of at least 5 yea rs.
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confiscation shall be ordered by a d ecree of the council of m isdem eanours’ 2 court
judges having com petence ratione loci . The provisions of Ar ticles 492 and 504(3)
of the Code of Cri minal Procedure shall also apply by way of analogy to this case.

4. The provisions of Article 310(2) and the la st sentence of Artic le 373 of the Code
of Cri minal Procedure shall also appl y by way of analogy where confiscation has
been ordered against th e assets of a thir d person who was not tried or summoned t o
the tria l.

Article 47
Compensation of the State
1. The State m ay, on an opinion from the St ate Legal Council, raise a claim before a
civil court against anyone convicted to im prisonm ent of an offence referred to in
Articles 2 and 3above, in order to receive any other assets acquired by him through
anot her offence referred t o in Articles 2 and 3, ev en if no crim inal proceedings were
instituted for such offence becaus e of d eath of the offender or if prosecution was
term inated o r declared in adm issible.

2. If the assets referred to in paragraph 1 have been transferred to a third person, the
convicted person shall be liable to com pensa tion equal to the value of the assets as
at the tim e of the hearing of the action. Th e above claim m ay also be raised against
a third person who acquired assets without consideration, provided that at the tim e
of acquisition such person was a spouse or lineal rela tive by blood or a brother/
sister or adopted child of the convicted person, as well as against any third person
who acquir ed assets a fter the ins titu tion of crim inal pr oceedings a gainst the
convicted person for the above crim e, provide d that at the time of acquisition he was
aware of th e initiati ng of crim inal proceed ings ag ainst the convicted person. The
third person and the convicted pe rson shall be severally liable.

Article 48
Freezing and prohibition of sale of assets
2 M isdem eanou rs a re cri minal of fence s pu nishabl e by a t erm of im pri sonment from one to five y ears .
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1. During a regular investigation for the of fences ref erred to in Article 2, the
investigatin g judge m ay, with the cons ent of the pub lic prosecu tor, freeze any
accounts, securities or financia l products kept at a credit or financial institution, as
well as any safe deposit boxes of the accu sed, including th ose owned jointly with
any other person, provided that there are well-founded suspicions that these
accounts, securities, financia l products or safe depos it boxes contain m oney or
things derived from the comm ission of the offences referred to in Article 2. The
sam e shall apply when a predicate offence i s investig ated and there are well-
founded suspicions that the accoun ts, secur ities, financial products or safe deposit
boxes contain m oney or things derived from the comm ission of the above offence or
are subject to confiscation accordin g to Ar ticle 46 above. In case of a prelim inary
exam ination or investig ation, freezin g of accounts, securities, financial products or
safe deposit boxes m ay be ordered by the judicial council. The order of the
investigating judge or the decree of the judicial council shall have the power of a
seizure report and shall be issued without prior summ oni ng of the accused or third
person. It is not necessary that the order mentions any specific account, security,
financial product or safe deposit box and shall be served upon the accused and a
managem ent of ficer of the cred it or financ ial in stitu tion ref erred to in Artic le 44,
paragraph 1 above or to the m anager of th e branch where the i nvestigating judge or
the public prosecuto r is based. In case of jointly owned accounts, securities,
financial products or safe deposit boxes, it shall also be served upon the third
person.

2. The freezing referred to in the preceding para graph shall apply from the tim e of
service of the order of the i nvestigating judge or the decr ee of the judicial council
upon the credit or financial institution. From this tim e, the safe deposit box m ay not
be opened and any withdrawal of money from an account or any sale of securities or
financial products shall be null and void ag ainst the State. Any m anagem ent officer
or em ployee of the credit or financial in stitution who intenti onally violates the
provisions of this paragraph shall be puni shed with a term imprisonm ent up to 2
years and a pecuniary penalty.

3. If the conditions of paragraph 1 of this article are m et, the i nvestigating judge or
the judicial council m ay prohibit the sale of a specific real estate of the accused. The
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order of the investigating judge or the d ecree or the judicial council shall have the
power of a seizure repo rt, shall be issu ed witho ut prior sum moning of the accus ed
and served upon the accused and the com peten t registrar, w ho shall m ake a note in
the appropriate books the sam e day and file the docum ent served upon him . A
decis ion of the Min iste r of Justice sh all spec ify the deta ils f or the im plem entation of
this provision. Any juridical act, m ortgage, attachm ent or other act reg istered by the
mortgage registry after th e registration of the above note shall be null and void
agains t the S tate.

4. The accused, the person suspected of comm itting the offences referred to in
Articles 2 and 3 and the third person sha ll have the right to de mand the revocation
of the investigating judge’s order or of the judicial council’s decree, by an
application addressed to the j udicial council and filed with the investigat ing judge or
the public prosecutor within 20 days from th e service of the order or the decree. The
investigating judge m ay not be a mem ber of the judicial council. The decree of the
judicial council m ay be appealed agai nst by the above pers ons and the Public
Prosecutor of the Misdem eanours’ Court (i.e. first-instance crim inal court) or of the
Court of Appeal before a Board of Appe llate Court Judges, which shall decide
irrevocably on such appeal. The subm ission of the application shall not suspend the
enforcem ent of the order or the decree. The order or the decree m ay be revoked if
there is new evidence.

5. W here the Comm ission conducts an adm inistrative investigati on or a crim ina l
prelim inary investigation accordin g to Article 7, paragraph 11, the freezing of
accounts, securities, financial products or safe deposit boxes or the prohibition of
sale or transfer of any ot her asset m ay be ordered in em ergencies by the Chairma n
or the m ember of the Committee sup ervis ing the investigatio n (in the firs t case) and
the Chairman (in the second case), subj ect to the conditions provided for by
paragraphs 1-3 of this article. In bot h cases, the data con cerning such freezing and
the case f ile shall be transm itted to the competent Public Prosecu tor by the
Chairm an of the Comm ission. This shal l not prevent the c ontinuation of the
adm inistrative investigation by the Co mm ission. Any person affected by such
freezing sh all hav e the rights p rovid ed for in paragraph 4 of this article. The Public
Prosecutors of the Mi sdem eanours’ Court and the Cour t of Appeal shall have the
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sam e rights. In the abov e cases, even after the issuance of an irrevocab le decree by
the judicial council on the application fo r lifting such freezing, the Prosecutor m ay
decide that the inves tigation has not been com pleted and eithe r return the case f ile to
the Comm ission or com plete the inv estig ation h imself .

6. In the cases of paragraphs 4 and 5 of this article, the applican ts m ay only question
the fulfilm ent of the con ditions for freezing o r prohibition.

7. The provisions of this article shall apply by way of analogy, in addition to credit
and financial institutions, also to the other obligated pers ons referred to in Article 5.

Article 49
Enforcemen t of sanction s imposed
by international organisations
When the freezing of assets belonging to states, legal entities or unincorporated
entities and natura l pe rsons is im posed by re solu tions of the United Nations Secur ity
Council and organs or by Regulations and decisions of the European Union for the
purpose of com bating terrorist financing, the following procedure shall apply after
the transpos ition of the above resolutions o r Regulations to Greek law according to
the provisions in force:
a) The above resolutions and Regulations shall be forwarded upon their issuance by
the Ministry of Economy a nd Finance and the Ministry of Foreign Affairs to the
Comm ission referred to in Article 7 above.
b) The Comm ission shall prom ptly inf orm all cr edit and f ina ncial institutions on the
above resolutions and Regulat ions and shall dem and a thorough investigation for the
identification of assets of any nature belonging to the afore mentioned natural
persons and legal entities.
c) The Comm ission m ay also forward the re levant information to other obligated
persons referred to in Article 5 above if it cons iders tha t th ey m ay identif y relevant
assets.
d) As soon as the Comm ittee is advised of the existence of any assets, it shall infor m
the Minister of Economy and Finance (G eneral Directo rate for Economic Policy ),
providing any relevant infor mation.
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e) The Minister of Econom y and Fi nance shall issue a decision freezin g the assets,
accounts and safe deposit boxes belonging to th e natural persons and legal entities
nam ed in the above resolutions and Regulat ions, prohibit the pr ovision of financial
or investm ent services to these persons and entities and take any other m easure
provided for in the above resolutions and Re gulations. This decisi on shall be served
upon the above natural pers ons and legal entities.
f) The natu ral pe rson o r lega l en tity whose ass ets have been frozen m ay attack the
relevant decision of the Mi nister of Econom y and Finance before the adm inistrative
courts within a tim e li mit of 30 days fr om the service of the above decision. The
provision of Article 48, paragraph 6 a bove shall apply in this case too.
g) The Minister of Econom y and Financ e m ay grant, following a petition by the
persons con cerned, a sp ecial perm it to unfreeze or use all or any of the frozen assets,
for the reaso ns and according to the p rocedure m entioned in th e relevan t resolution s
of the United Nations Security C ouncil or R egulations of the Council of the
European Union.

Article 50
Access of th e judicial au thorities to records and data
In case of a prelim inary judicial exam inati on, investigation or trial for the offences
ref erred to in Articles 2 and 3, the public prose cutor, the inv estig ating ju dge and the
court of law shall have access to th e books and records that the oblig ated persons
are requ ired to keep according to th e legis lation in f orce an d m ay attac h to the ca se
file only extracts from these books or record s containing the entrie s that concern the
investigated person. Th e accuracy of the ex tracts shall b e certified b y the legal
representative of the obliged legal entity or by the obligated natural person. The
public prosecutor, the investigating judge and the court of law shal l have the right to
contro l these books and records in order to verify the accuracy of the entries in the
extra cts o r the exis tence of other en trie s that co ncern th e af orem entioned person.
This person m ay only control the existence of the entries allegedly concerning him .

Article 51
Liability of legal entities
1. W here any of the of fences ref erred to in Articles 2 and 3 is comm itted with the
purpose of providing a financial benefit to a legal entity and at least one or m ore
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persons who m anage or adm inister its bus iness knew or ought to have known that
the benefit derived from such offence, th e following sanctions shall cum ulatively or
alternatively apply, after summ oning the responsible persons to provide
explanations at leas t ten days earlier:
a) W here the obliga ted person is an obliged leg al entity or a com pany listed in a
regulated m arket, a decision of the com petent author ity re ferred to in Artic le 6
above shall impose:
i) an adm inistrative fine of €30,000 to €3,000,000 increased by the benef it acquired;
ii) prov ision al or f inal withdrawal or susp ension of authorisation or prohibition of
carrying out its business;
iii) prohibition of the carrying out of specif ic busine ss activ ities or of the
estab lishm ent of branch es or cap ital increase, for the sam e tim e period;
iv) provisional or tem porary exclusion from public benefits , aid, subsidies, award of
public works and serv ices, procurem ents, advertis ing and tende rs of the pub lic
sector or of legal entities of th e public sector, for the sam e period.
The adm inistrative fine referred to in (i) above shall always apply, regardless of the
im position of other sanctions.
The Hellenic Capital M arket Committee shal l b e the com petent au thority to im pose
the above sanctions on com panies listed on a regulated m arket which are not
supervised by other com petent author ities referred to in Article 6 above.
b) Regarding non-obliged lega l entities, the following sanc tions shall be imposed by
a join t decision issued by the Min ister of Justice and the com petent m inister:
i) an adm inistrative fine of €20,000 to €2,000,000, increased by any benefi
t
acquired;
ii) the sanctions listed in subparagraph (a), item s (ii) , (iii) and (iv) above.
Com petent m inister shall be considered the Mi nistry in charge of a m inistry that has
the f ollowin g powers, in prior ity o rder:
– to supervise the proper and legitim ate opera tion of the legal en tity and to
im pose sanctions;
– to gran t th e requi red authorisation;
– to keep a register in w hich the deed of incorporation is recorded;
– to keep a professional register in which the lega l entity is re corded;
– to finance and provide subsidies or econom ic aid.
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The above powers m ay be exercised by agenci es or other bodies subordinated to, or
supervised by, the relevant m inistry.

2. W here the person s lis ted in the precedi ng p aragraph were negligen tly unaware of
the orig in of the illeg al asse ts or benef it, th e f ollowing sanctions shall app ly
cum ulatively or alternatively, under the sam e conditions :
a) In the case referred to in paragraph 1a above:
– an adm inistrative fine of €10,000 to €1,000,000;
– the sanc tio ns listed in para graph 1a, item s (ii), (iii) and (iv) for a tim e period of six
months.
b) In the case referred to in paragraph 1b above:
– an adm inistrative fine of €5,000 to €500,000;
– the sanc tio ns listed in para graph 1a, item s (ii), (iii) and (iv) for a tim e period of six
months.

3. For the cumulative or altern ativ e im position of the sanctions lis ted in the
previous paragraphs and determ ination of thes e sanctions, the f ollowing shall in
particular be taken into acc ount: the gravity of the offence; the degree of culpability;
the financial condition of the legal pers on; the am ount of il legal gains and the
acquir ed be nef it; any re cidiv ism ; and the othe r c ircum stance s.

4. The enforcem ent of the provisions of the preceding paragraphs shall be
independen t and sha ll n ot af fect th e civil, d isciplina ry or c rim inal liability of the
persons who m anage or adm inister the f unds or affairs of the legal entities.

5. The sanctio ns referred to in the p reced ing pa ragraphs sh all b e im posed
unless other provisions envisage m ore se ver e san ctions again st leg al en tities.

6. The prosecutorial and poli ce au thorities, th e Special A udits Agen cy and the
Comm ission shall inform the com petent author itie s and the M iniste r of Justice about
cases where a legal en tity with in the m eaning of paragraph 1 is implicated in
attem pts or in the com mission of the of fences listed in Article s 2 and 3, as well as
about any relevant cour t judgm ents issued.

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Article 52
Administra tive sanc tion s
1. The com petent au thor ities that sup ervise ob lig ated leg al pe rsons im pose on them ,
when they fail to comply with their obligations under this law, Regulati
on
1781/2006/EC and the regulatory decisions, cumula tively or alternatively, either the
obligation to take concrete corrective m easures within a specific tim e period, or one
or m ore of the following sanctions, af ter summoning the obligated persons to
provide explanations, at least 10 days earlier:
a) a fine on the corporation of €30,000 to €2,000,000 and, in case of recidivism , of
€50,000 to €3,000,000;
b) a fine of €10,000 to €300,000 on the di rectors, the m anaging director,
manage ment officers or other em ployees of the corporation who are responsible for
the viola tion s or exercise of insuff icient control and supervision of the services, the
em ployees and activities of th e corporation; in case of recidivism , a fine of €20,000
to €500,000 shall be im posed;
c) rem oval of the directors, the m anaging director, m anagem ent offic ers or other
em ployees for a specific tim e period and prohibition of assum ing othe r im portant
duties;
d) prohibition of the corporation from ca rrying out cer tain activ ities, establishin g
new branches in Greece or abroad or increasing its share cap ital;
e) in case of serious and/or repeated viol ations, final or provi sional withdrawal or
suspension of authorisati on of the corporation for a s pecific time period or
prohibition to carry out its business.

2. The sanctions referred to in paragraph 1a to e above shall be independent from
the sanc tion s listed in Artic le 51 f or the of fences ref erred to in Artic les 2 and 3
above. These sanctions shall be justif ied and publicised provided that their
publication is unlikely to cause disproportio nate dam age to t he legal entity on which
the sanction is im posed.

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3. Every competent authority supervising fina ncial corpo rations sha ll sp ecif y in its
publicised decisions:
a) the individual obligations of corporations, their officers and em ployees, either
separately or by category;
b) the degree of im portance of each oblig ation or category of obligations, with
indicative reference of possi ble sanctions in case of non-compliance therewith;
c) other general or special criteria taken into account by the com petent authority in
determ ining and com puting the sanctions.

4. W here an obligated natural person br eaches its obligations under th e provisions
of this law and the relevant regulatory deci sions, if disciplinary control is exercised
accord ing to the provisions in force by a special discip lin ary body, the com petent
authority sh all refer th e obligated natural person to the said body, trans mitting to it
all the details of such breach.

5. The sanctions referred to in the previous paragraphs sh all be im posed unless other
provisions provide for strict er s anctions agains t their em ployees and th e obligated
natural persons.

6. The f ines ref erred to in this and the preceding article th at are im posed by the
public bodies m entioned therein shall be certif ied by the relevant authorities and
collected according to the pr ovisions of the Code of Co llection of Public Revenue.

CHAPTER I
Transitional, repea led and other p rovisions

Article 53
Other provisions
1. Para.6 of article 187A of the Penal Code shall be re placed as follows:
“6. Whoever provides information or mater ials or receives , collects, p rovides or
manages in any way funds within the meani ng of paragraph 1 of Article 1 of Law
3034/2002 (Government Gazette 168A) with the aim of facilitating or supporting the
execution of terrorist a ctivities according to p aragraphs 1 , 3 and 4 either b y a
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criminal organisation or an individual terrori st shall be punished with a sentence of
up to ten years”.

2. W ithin th e Audit Dir ector ate of the Ge neral Directo rate for Tax Audits of the
Ministry of Econom y and Finance, a Sect ion E entitled “AML/CTF Supervision and
Control Section” shall be established. It shall support and coordi nate the actions of
the General Directo rate for Tax Audits of the Ministry of Econom y and Finance as
com petent authority for the supervision of the obligated persons referred to in
Artic le 5 of this law. Th e powers of the af orem entioned competent au tho rity which
concern the control of obligated persons a nd the i mposition of the relevant sanctions
accord ing to points (h), (i) and (k) of paragr aph 3 of Article 6 shall be exercised by,
in addition to Section E (the provisions of this law on the exercis e of th ese powers
and the relevant issues in general applying by w ay of analogy), also the Regional
Audit Centres, Inter-regiona l Audit Centres and the Inte rnal Revenue Offices, which
are responsible for the tax audit of oblig ated persons. Especially for the im position
of the sanctions referred to in point (k ) of paragraph 3 of Article 6 by the above
auditing services, except for the i mposition of fines and corrective measures, the
consent of the General Director for Tax Audit shall be required.
This Section shall be h eaded by an of ficer of the Tax Officer Branch, holder
of a university degree, failing which a technol ogical institution degree, failing which
a secondary education graduation diplom a.

Article 54
Transitional provisions
1. The regulatory decisions and other adm inistrative acts of the m inisters or
com petent author ities r eferred to in Article 6 shall rem ain in f orce until th eir
am endm ent or abolition, provi ded that they do not run contrary to the provisions of
this law.

2. W here a legislative or regulatory provisi on m entions the Comm ittee r eferred to in
Article 7 of Law 2331/1995 or the AML Au thority referred to in law 3424/2005, it
shall be understood as the AML/CTF Comm ission referred to in Article 7 of this
law.

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3. As from the entry into force of this la w, the National AML Au thority referred to
in Article 7 of Law 2331/1995, as replaced by Article 7 of Law 3424/2005, shall b e
abolished.

Article 55
Repealed provisions
1. As from the publication of this law, the following provisions shall be repealed:
a) the provisions of Arti cles 1 to 9 (Chapter A ΄) of Law 2331/1995 (Governm ent
Gazette 173 A);
b) th e prov isions of Articles 1 to 11 of Law 3424/ 2005 (Governm ent Gazette 305A),
except for A rticle 10 thereof;
c) Article 8 of Law 2928/2001 (Governm ent Gazette 141A);
d) indent (e) of Article 2 of Law 2331/1995, as added by Article 17 of La w
3472/2006 (Governm ent Gazette 135 A);
e) paras. 1 and 2 of Article 34 of Law 3556/2007 (Government Gazette 91A);
f) every other provision of any law, pres iden tial decree o r regulato ry decision which
runs contrary to the provisions of this law.

Article 56
Final provis ions
The provisions of this law shall enter into force as from its public ation in the
Governm ent Gazette.
Athens, 14 July 2008
THE MINISTERS
G. Alogoskoufis S. Hadzigakis
MINISTER OF EC ONOMY AND F INANCE MINISTER OF JUSTIC E
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