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 as amended by Law 4734/08.10.2020 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 and 2018/843 of the European Parliament and of the Council.

Specific amendments to Law 4557/30.07.2018 regarding provisions which are related to the responsibilities of the Bank of Greece, have been made by laws 5042/10.04.2023, 5072/04.12.2023 and 5193/11.04.2025.

EU Directives and Regulations

  • Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849.
  • Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849.
  • 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, as amended mainly by the Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018.
  • 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) 2019/758 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

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

Guidelines

Final Report Guidelines restrictive measures

Regulatory Technical Standards

Guidelines

Final Report Guidelines restrictive measures

The Guidelines of the European Banking Authority specify the internal policies, procedures and controls financial institutions that are subject to regulation and supervision pursuant to Directive 2013/36/EU, Directive (EU) 2015/2366 and Directive 2009/110/EC should put in place in accordance with Article 74(1) of Directive 2013/36/EU, Article 11(4) of Directive (EU) 2015/2366 and Article 3(1) of Directive 2009/110/EC to ensure the effective implementation of Union and national restrictive measures.

Travel Rule Guidelines

The Guidelines of the European Banking Authority a) set out the factors that payment service providers, intermediary payment service providers, crypto-asset service providers, and intermediary crypto-asset service providers should consider when establishing procedures to detect and manage transfers of funds and crypto-assets lacking the required information on the payer/originator and/or the payee/beneficiary, and to ensure that these procedures are effective; b) specify what these providers should do to manage the risk of money laundering or terrorist financing where the required information on the payer, originator, payee or beneficiary is missing or incomplete, and c) specify technical aspects of the application of Regulation (EU) 2023/1113 to direct debits.

Guidelines on policies and procedures in relation to compliance management and the role and responsibilities of the AML/CFT Compliance Officer under Article 8 and Chapter VI of Directive (EU) 2015/849

The Guidelines of the European Banking Authority specify the role, tasks and responsibilities of the AML/CFT compliance officer, the management body and senior manager in charge of AML/CFT compliance.

Guidelines on the use of Remote Customer Onboarding Solutions

The Guidelines of the European Banking Authority set out the measures credit and financial institutions should take to ensure safe and effective remote customer onboarding practices in line with applicable anti-money laundering and countering the financing of terrorism (AML/CFT) legislation and the EU’s data protection framework.

Risk Factors Guidelines

Guidelines of the European Banking Authority under Articles 17 and 18(4) of Directive (EU) 2015/849 on 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 (“The ML/TF Risk Factors Guidelines”), repealing and replacing Guidelines JC/2017/37

Final Amending Guidelines on MLTF Risk Factors

Guidelines of the European Banking Authority amending Guidelines EBA/2021/02 on 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 (‘The ML/TF Risk Factors Guidelines’) under Articles 17 and 18(4) of Directive (EU) 2015/849

Guidelines on cooperation and information exchange for the purpose of Directive (EU) 2015/849 between competent authorities supervising credit and financial institutions - The AML/CFT Colleges Guidelines

The AML/CFT Colleges Guidelines of the European supervisory authorities set out the practical modalities of cooperation and information exchange between prudential and AML/CFT competent authorities for the purposes of AML/CFT supervision of credit and financial institutions both domestically and on a cross-border basis.

Guidelines on MLTF risk management and access to financial services

The Guidelines of the European Banking Authority complement the Guidelines on ML/TF risk factors and specify further the policies, procedures and controls credit and financial institutions should have in place to mitigate and effectively manage ML/TF risks, including measures with respect to the provision of a basic payment account.

EBA Final Report on GL on RBA AML CFT

Guidelines of the European Banking Authority 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 under Article 48(10) of Directive (EU) 2015/849 (amending the Joint Guidelines ESAs 2016 72). 

Opinions

Opinion of the European Banking Authority on money laundering and terrorist financing risks affecting the EU’s financial sector

EBA Opinion and annexed report on de-risking

Opinion of the European Banking Authority on the risks of money laundering and terrorist financing affecting the European Union’s financial sector-3.3.2021

 

Opinion of the European Banking Authority on the interplay between the EU Anti-Money Laundering Directive and the EU Deposit Guarantee Schemes Directive-11.12.2020

Opinion of the European Banking Authority on how to take into account ML/TF risks in the Supervisory Review and Evaluation Process (SREP)

Opinion of the European Banking Authority on the future AML/CFT framework in the EU

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

Joint Opinion of the European Supervisory Authorities on the risks of money laundering and terrorist financing affecting the European Union’s financial sector- 4.10.2019

Opinion of the European Banking Authority on the nature of passport notifications regarding agents and distributors under Directive (EU) 2015/2366 (PSD2), Directive 2009/110/EC (EMD2) and Directive (EU) 2015/849 (AMLD)

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

Opinion of the European Banking Authority on money laundering and terrorist financing risks affecting the EU’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 /Executive Committee’s Acts and Credit and Insurance Committee/Banking and Credit Committee Decisions

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

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

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

Τhe Bank of Greece has issued Banking and Credit Committee Decision no. 281/17.03.2009, which 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. The relevant Decision has been amended by Executive Committee Act no 177/1/16.9.2020.

Finally, Bank of Greece by Executive Committee Act no. 172/1/29.05.2020 lays down the terms and conditions for remote electronic identification of natural persons establishing a business relationship with credit institutions and supervised financial institutions, in the context of the application of customer due diligence measures provided for in the legal and regulatory framework for the prevention of 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, Executive Committee Act no. 172/2/29.5.2020 and Executive Committee Act no. 188/1/26.4.2021 further amended Decision no. 281/5/17.3.2009.

Important Notices

Multilateral Agreement on the exchange of information between the ECB and AML/CFT competent authorities

The Bank of Greece has signed the Multilateral Agreement on the practical modalities for the exchange of information between the European Central Bank and national competent authorities responsible for supervising compliance with Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) framework, pursuant to article 57a(2) of Directive (EU) 2015/849. The Multilateral Agreement strengthens the cooperation between the above supervisory authorities and contributes to the more effective exercise of their supervisory tasks and to the strengthening of the European AML/CFT framework.

Multilateral Agreement on the exchange of information between the ECB and AML/CFT competent authorities

The Bank of Greece has signed the Multilateral Agreement on the practical modalities for the exchange of information between the European Central Bank and national competent authorities responsible for supervising compliance with Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) framework, pursuant to article 57a(2) of Directive (EU) 2015/849. The Multilateral Agreement strengthens the cooperation between the above supervisory authorities and contributes to the more effective exercise of their supervisory tasks and to the strengthening of the European AML/CFT framework.

The Bank of Greece publishes a regulatory framework for digital customer onboarding

• 03/06/2020- Press Release:
By Executive Committee Act 172/1/29.05.2020, the Bank of Greece laid down the terms and conditions for digital customer onboarding by banks and other supervised entities.
Digital customer onboarding possible via video conference or via dynamic selfie.

The new Act encourages the development of flexible and technologically innovative service delivery models in the financial sector, introduces a regulatory framework that is in line with those in place in most EU Member States, and ensures a level playing field for domestic institutions in a rapidly changing international environment. The Act becomes all the more important in the current circumstances of the COVID-19 pandemic and in view of the need to address its impact, as it creates service provision channels compatible with social distancing.
The Act contains a combination of organisational, technical and procedural measures that ensure a reliable identity verification of natural persons and are designed to prevent identity fraud. Two methods of digital onboarding are envisaged: (a) by video conference with a trained agent, which provides the greatest safeguard of security; and (b) an automated procedure via a dynamic selfie, subject to additional safeguard measures.
The identification documents for natural persons that are acceptable are those incorporating enhanced security features, most notably passports. Exceptionally and only as part of the video conference method, ID cards issued by the Hellenic Police, with data written in Latin characters, may be accepted subject to validity and authenticity check through the central portal of the public administration.
Rapid technological advances open up new opportunities for financial corporations, by enabling direct access to online services, faster transactions, lower costs and broader geographical reach. At the same time, however, they present AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) challenges. The new Act seeks to address these challenges by establishing modern rules for secure customer identification and for limiting remote access risks.

Money Laundering and Terrorist Financing Risks due to COVID-19

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 Announcements on High-Risk Jurisdictions subject to a Call for Action and Jurisdictions under Increased Monitoring

  • FATF October 2019 Public Statement on countries with strategic AML/CFT deficiencies for which an FATF call for action applies
  • FATF October 2019 document on Improving Global AML/CFT Compliance: on-going process
  • 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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