Anti-Corruption 2026

GREECE Law and Practice Contributed by: Ilias Anagnostopoulos and Alexandros Tsagkalidis, Anagnostopoulos

2.6 Lobbyists Lobbying activities are regulated by Law 4829/2021. The aim of this law is to ensure integrity and transpar - ency when exercising lobbying activities. To this end, a Transparency Registrar was established to which all natural and legal persons who exercise lobbying activities for a fee, through communications with insti - tutional bodies (ie, the bodies exercising a legislative or executive function, their members or employees, whether acting individually or collectively), must reg - ister by providing information about their identity and activities. On an annual basis, their representatives must file a declaration with the National Transparen - cy Agency, stating, amongst others, the policy area and type of decision that was influenced, the details of the person who exercised influence, as well as of their client, the time and manner in which the lobbying activity was carried out, the institutional body to which the lobbying activity was addressed, and, finally, the intended result. The general rules of limitation periods are set out in Articles 111–116 of the GCC. The limitation time for serious financial crimes against the state or state- owned entities is 20 years. Felonies punishable by imprisonment (five to 20 years) are time-barred after 15 years, and misdemeanours punishable by sentenc - es of up to five years are time-barred after five years. As a matter of principle, calculation of these times is made from the time of the act, unless there is a special legal rule that provides otherwise. 3. Scope of Application 3.1 Limitation Period Limitation times are suspended for five years (for fel - onies) or three years (for misdemeanours) while the case is pending before a court and until a final deci - sion is delivered or if there are legal grounds that do not allow the prosecution and/or its continuation. This five-year extension is not valid in cases where there is suspension of the proceedings by law, following cer - tain provisions of the Greek Code of Civil Procedure (GCCP). There are special provisions for cases relating either to the country’s international affairs (Article 29 of the GCCP) or cases that are very closely connected to other criminal cases already pending, and their out -

come is of major importance to the suspended crimi - nal case (Article 59 of the GCCP). 3.2 Geographical Reach of Applicable Legislation Article 8 of the GCC stipulates that Greek legislation is always applicable to offences committed abroad by public officials of the Greek state, or by officials of EU bodies and organisations seated in Greece. Accord - ing to the same provision, Greek legislation is always applicable where the crime committed abroad was directed against, or addressed to, a public official of the Greek state, or a Greek officer of an EU body or organisation, during or in relation to the exercise of their duties. Moreover, Articles 159 paragraph 4, 159A paragraph 4, 235 paragraph 5 and 236 paragraph 4 of the GCC, which have expanded the definition of “public official” to cover foreign public officials, stipulate that active and passive bribery of foreign public officials is pun - ishable when committed abroad, irrespective of dual criminality. 3.3 Corporate Liability Greek law provides that, in principal, only individuals may be held liable for a criminal act, thus being subject to classic punishments (eg, imprisonment). However, recent Law 5090/2024 introduced criminal liability of legal entities in relation to corruption offences, such as bribery. In such cases, criminal courts have the power to impose fines to legal entities ranging from EUR50,000 to EUR10 million, or to twice the pre-tax annual net profits of the legal entity (if such amount exceeds EUR10 million), if they find that the corruption offence was committed for the benefit or on behalf of the legal entity. Moreover, criminal courts have the power to impose definitive or temporary revocation or suspension of the licence of operations of the legal entity, or impose a ban on the exercise of its business activities. In such cases, the criminal liability of the legal entity does not bar prosecution of the individual who was the perpetrator of the offence. Liability of a successor entity could arise in cases where individuals managing the target entity are held criminally liable for acts of corruption and the target entity has benefited from these acts. Given the fact

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