Anti-money laundering

The Bank of Greece is the authority responsible for supervising compliance with the legal and regulatory framework on the prevention and suppression of money laundering, terrorist financing (AML/CFT) and the financing of proliferation of weapons of mass destruction, by the institutions under its supervision.

The current institutional framework has been primarily established by incorporating the relevant EU legislation, which is aligned with the "Forty (40) Recommendations against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction" as adopted in February 2012 by the Financial Action Task Force (FATF), which is an international body setting standards and issuing guidelines.

The Bank of Greece, in the context of its supervisory tasks, checks supervised institutions’ compliance with their AML/CFT obligations and assesses the adequacy and effectiveness of their AML/CFT procedures.

In addition, the Bank of Greece has issued an extensive typology of suspicious transactions based on Greek circumstances and international bibliography.

It should be noted that, other than being responsible for checking compliance with the stipulated due diligence provisions when transactions are carried out by supervised institutions, including the obligation to report suspicious transactions to the Anti-Money Laundering Authority, the Bank of Greece is not vested with preliminary investigation powers nor is responsible for investigating suspicious transaction reports. The Anti-Money Laundering Authority is exclusively responsible for investigating thoroughly suspicious transactions and take further actions.

The legal and regulatory framework is established on the basis of the Law, EU directives and regulations, the Governor's Acts, Executive Committee Acts, Credit and Insurance Committee/Banking and Credit Committee Decisions, circulars and explanatory documents.

Legislation

Law 4557/30.07.2018 is the basis of the applicable Greek institutional framework on preventing and combating money laundering and terrorist financing, and incorporates the provisions of Directive (EU) 2015/849 of the European Parliament and of the Council.

EU Directives and Regulations

  • Regulation (EU) 847/2015 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006. The Regulation entered into force on 26 June 2017.
  • Regulation (EU) 847/2015 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006. The Regulation entered into force on 26 June 2017.
  • Directive 2015/849/EU of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC.
  • Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU.
  • Commission Delegated Regulation (EU) 2018/1108 of 7 May 2018 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council with regulatory technical standards on the criteria for the appointment of central contact points for electronic money issuers and payment service providers and with rules on their function.
  • Commission Delegated Regulation (EU) of 31.1.2019 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council with regard to regulatory technical standards for the minimum action and the type of additional measures credit and financial institutions must take to mitigate money laundering and terrorist financing risk in certain third countries.

High-risk third countries

  • Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies.
  • Commission Delegated Regulation (EU) 2018/105 of 27 October 2017 amending Delegated Regulation (EU) 2016/1675, as regards adding Ethiopia to the list of high-risk third countries in the table in point I of the Annex.
  • Commission Delegated Regulation (EU) 2018/212 of 13 December 2017 amending Delegated Regulation (EU) 2016/1675 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council, as regards adding Sri Lanka, Trinidad and Tobago, and Tunisia to the table in point I of the Annex.
  • Commission Delegated Regulation (EU) 2018/1467 of 27 July 2018 amending Delegated Regulation (EU) 2016/1675 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council, as regards adding Pakistan to the table in point I of the Annex.

Implementation of Restrictive Measures (Sanctions)

  1. Guideline on implementation and evaluation of restrictive measures (sanctions) in the framework of the EU Common Foreign and Security Policy.
  2. Update of the EU Best Practices for the effective implementation of restrictive measures (sanctions).

Regulatory Technical Standards, Guidelines and Opinions by European Supervisory Authorities

Regulatory Technical Standards

Draft Joint Regulatory Technical Standards on the measures credit institutions and financial institutions shall take to mitigate the risk of money laundering and terrorist financing where a third country’s law does not permit the application of group-wide policies and procedures.

Regulatory Technical Standards

Draft Joint Regulatory Technical Standards on the measures credit institutions and financial institutions shall take to mitigate the risk of money laundering and terrorist financing where a third country’s law does not permit the application of group-wide policies and procedures.

Guidelines

Guidelines on risk-based approach (Risk Factors Guidelines)

Joint Guidelines under Articles 17 and 18(4) of Directive (EU) 2015/849 on simplified and enhanced customer due diligence and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions.

Guidelines on risk-based supervision

Joint Guidelines on the characteristics of a risk‐based approach to anti‐money laundering and terrorist financing supervision, and the steps to be taken when conducting supervision on a risk‐sensitive basis.

Guidelines to prevent transfers of funds from being abused for ML and TF

Joint Guidelines under Article 25 of Regulation (EU) 2015/847 on the measures payment service providers should take to detect missing or incomplete information on the payer or the payee,  and the procedures they should put in place to manage a transfer of funds lacking the required information.

Opinions

Opinion of the European Banking Authority on communications to supervised entities regarding money laundering and terrorist financing risks in prudential supervision

Joint Opinion on the risks of money laundering and terrorist financing affecting the Union’s financial sector

Opinion on the use of innovative solutions by credit and financial institutions in the customer due diligence process.

Joint Opinion on the risks of money laundering and terrorist financing affecting the Union’s financial sector.

Opinion of the European Banking Authority on the application of customer due diligence measures to customers who are asylum seekers from higher-risk third countries or territories.

Governor's Acts and Decisions

Governor's Acts and Credit and Insurance Committee/Banking and Credit Committee Decisions

In pursuance of Law 3691/2008, the Bank of Greece has issued Banking and Credit Committee Decision no. 281/17.03.2009, which streamlines and specifies, based on the principle of proportionality, the obligations of all entities supervised by the Bank of Greece.

Governor's Acts and Credit and Insurance Committee/Banking and Credit Committee Decisions

In pursuance of Law 3691/2008, the Bank of Greece has issued Banking and Credit Committee Decision no. 281/17.03.2009, which streamlines and specifies, based on the principle of proportionality, the obligations of all entities supervised by the Bank of Greece.

This Decision obliges all credit institutions and financial institutions supervised by the Bank of Greece to have in place a documented policy to combat money laundering and terrorist financing, which will be approved by their Board of Directors. Also, the Decision strengthens the role and specifies the duties of the competent executive that every supervised entity should appoint to report suspicious or unusual transactions to the Anti-Money Laundering Authority.

It also provides detailed guidelines to supervised entities on how to implement a methodology to deal with money laundering and terrorist financing by customer and transaction risk category, with particular emphasis on categories such as offshore enterprises, countries that do not implement adequately the FATF recommendations, transactions without the customer being physically present etc.

Furthermore, if a customer requests to withdraw an amount of over €50,000, this decision recommends that credit institutions should deliver the money by cheque or an order for payment to a bank account.

Moreover, Banking and Credit Committee Decision no. 290/12/11.11.2009 on the Framework governing the imposition of administrative sanctions on institutions supervised by the Bank of Greece in accordance with Article 52 of Law 3691/2008, classifies separate compliance obligations of the entities supervised by the Bank of Greece by type and degree of importance as follows: particularly important, important, and ordinary, and further specifies the criteria for identifying, measuring and publishing such administrative sanctions.

Decision no. 154/5Α/31.08.2009 of the Private Insurance Supervision Committee's Board of Directors applies to the supervision of life or unit-linked insurance companies and insurance mediators by the Bank of Greece for the purpose of combating money laundering and terrorist financing.

Banking and Credit Committee Decision No. 281/17.03.2009 on Prevention of using credit and financial institutions supervised by the Bank of Greece for money laundering and terrorist financing. 

Banking and Credit Committee Decision No. 285/6/9.7.2009 on Indicative types of unusual or suspicious transactions within the meaning of Article 4(13), (14) of Law 3691/2008.

Banking and Credit Committee Decision no. 290/12/11.11.2009 on the Framework governing the imposition of administrative sanctions on institutions supervised by the Bank of Greece in accordance with Article 52 of Law 3691/2008".

Banking and Credit Committee Decisions no. 281/5/17.03.2009 and 290/12/11.11.2009 were supplemented by Banking and Credit Committee Decision No. 300/30/28.07.2010. Thereafter, Bank of Greece Governor's Act No. 2652/29.2.2012 amended Banking and Credit Committee Decisions no. 281/5/17.3.2009 and 285/6/9.7.2009, while Credit and Insurance Committee Decision no. 94/23/15.11.2013 further amended Decision no. 281/5/17.3.2009.

Important Notices

Important success of Greece in Anti-Money Laundering and Combating the Financing of Terrorism

Important success of Greece in Anti-Money Laundering and Combating the Financing of Terrorism

  • 3/9/2019-Publication of the Mutual Evaluation Report of Greece: Financial Action Task Force published the particularly positive Mutual Evaluation Report of the Anti-Money Laundering and Counter-Terrorist Financing Measures of Greece.
    Click here to see the FATF announcement.
    A Press-Release was also issued from the Ministry of Finance.
  • 21/6/2019-Press Release:

    The evaluation of the Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) System of Greece, based on the revised Recommendation of the Financial Action Task Force (FATF), i.e. the intergovernmental body setting the relevant global standards, was completed with great success in Orlando. On 20/6, the FATF, under the US Presidency, adopted the evaluation report of Greece, according which our country becomes subject to a “regular follow-up” process, a regime that applies to a limited number of assessed countries worldwide. Based on the report, which will be released in six weeks, Greece is ranked among the countries with a high level of compliance with international AML/CFT standards. 

    As regards the financial sector, the report states that the Bank of Greece identifies and assesses the Money Laundering/Terrorism Financing (ML/TF) risks of supervised sectors and individual companies and applies a risk-based approach to its supervision. Credit and financial institutions also have a good understanding of their ML/TF risks and obligations and apply mitigating measures commensurate with their risks. 

    The successful evaluation of Greece and its financial sector, based on the revised strict FATF standards, significantly enhances the reputation and credibility of the Greek banking system. Given that financial institutions worldwide are required to assess the country risk of their counterparties, based primarily on FATF’s evaluations, the successful evaluation of Greece is expected to have a positive impact on the correspondent banking activities of Greek banks, as well as on the cross- border transactions and activities of all Greek financial institutions. 

    The Bank of Greece, having played a significant role in this national effort that started 2.5 years ago with the Assessment of the National ML/TF Risk, congratulates the Ministry of Finance, which coordinated all of the national competent authorities involved, on the successful completion of this important project. 

Publication of the National Money Laundering/Terrorist Financing Risk Assessment Report

The first Greek National Money Laundering/Terrorist Financing Risk Assessment Report was published on the Ministry of Finance's website, further to its approval by the Strategy Committee for Combating Money Laundering, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction, in accordance with the provisions of article 8(7.a)(cc) of Law 4557/2018.

Supervised institutions are required to review carefully the said report and take it into account when conducting their ML/TF risk assessments in accordance with the provisions of article 35(1) and (2) of Law 4557/2018 and in the context of the provisions of paragraph 1.3(i)(e) and chapter 4 on risk-based approach of Banking and Credit Committee Decision no. 281/5/17.3.2009. Depending on the segment of activity, supervised institutions should focus on the report's individual chapters relating to threat assessment and especially the vulnerability assessment of the banking sector, and the sectors of life insurance and other financial institutions.

Vulnerability assessments of these sectors were drafted by working groups led by executives of the Bank of Greece Anti-Money Laundering Section with the participation of representatives of both the private and public sectors, and reflect the vulnerability of each financial sector, as established by the intrinsic ML/TF risk of goods and services, and by the evaluation of general audit mechanisms for preventing ML/TF. 

FATF Public statements on countries with strategic deficiencies and other monitored countries

  • FATF June 2019 Public Statement on countries with strategic AML/CFT deficiencies for which an FATF call for action applies
  • FATF June 2019 document on Improving Global AML/CFT Compliance: on-going process
  • February 2019 Public Statement identifying jurisdictions with strategic deficiencies in anti-money laundering / countering the financing of terrorism measures, for which specific counter-measures are required
  • FATF February 2019 document on compliance with anti-money laundering/countering the financing of terrorism standards in jurisdictions subject to FATF's special monitoring process
  • FATF October 2018 Public Statement identifying jurisdictions with strategic deficiencies in anti-money laundering / countering the financing of terrorism measures, for which specific counter-measures are required
  • FATF October 2018 document on compliance with anti-money laundering/countering the financing of terrorism standards in jurisdictions subject to FATF's special monitoring process
  • June 2018 Public Statement identifying jurisdictions with strategic deficiencies in anti-money laundering / countering the financing of terrorism measures, for which specific counter-measures are required
  • FATF June 2018 document on compliance with anti-money laundering/countering the financing of terrorism standards in jurisdictions subject to FATF's special monitoring process 
  • FATF February 2018 Public Statement identifying jurisdictions with strategic deficiencies in anti-money laundering / countering the financing of terrorism measures, for which specific counter-measures are required
  • FATF February 2018 document on compliance with anti-money laundering/countering the financing of terrorism standards in jurisdictions subject to FATF's special monitoring process
  • FATF November 2017 Statement on the Democratic People's Republic of Korea (DPRK).
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