GREECE Law and Practice Contributed by: Petros Machas, Dimitris Zanganas and Katerina Chrysi, Machas & Partners
EUR10 million, or up to twice the annual profits. It also provides for enhanced administrative sanctions, thereby reinforcing efforts to combat organised crime and the concealment of illicit activities through cor - porate structures. Institutionally, since the year of 2025, enforcement capacity has been further enhanced through the inte - gration of the Financial and Economic Crime Unit (SDOE) into the AADE framework and the estab - lishment of specialised regional units, including the Special Financial Control Units (MEOEL), Special Tax Audit Units (MEFEL) and Special Customs Control Units (METEL), tasked respectively with combating economic crime, large-scale tax evasion and smug - gling. These units, supported by advanced operation - al tools and co-ordinated through centralised opera - tional centres, are expected to carry out large-scale enforcement actions, with a target of at least 30,000 audits by 2026. 7.2 Recent Case Law and Latest Developments The legislative framework for combating economic crime in Greece has been significantly strengthened through recent reforms, with particular emphasis on the detection of organised and corporate crime, the deprivation of illicit proceeds, the establishment of new institutional structures and the transformation of audit mechanisms. The main legislative instruments governing this field include the following. • Law 5259/2025, which introduced full exemption from criminal prosecution for debts owed to the state (including tax authorities and social security bodies) for individuals subject to bankruptcy pro - ceedings. From the publication of the bankruptcy decision, all criminal prosecutions are suspended, while upon the successful completion of the bank - ruptcy process and discharge of debts, criminal liability is definitively extinguished, effectively removing the offence from the individual’s criminal record. • Law 5090/2024, which introduced a hybrid model of sanctions against legal entities, including the
imposition of fines and the suspension of business activities, marking an initial step towards address - ing criminality conducted through complex corpo - rate structures. • Law 5036/2023, which includes provisions on debt restructuring and the tackling of tax evasion, strengthening the tools of the Independent Author - ity for Public Revenue (AADE) for detecting unde - clared income. • Law 5026/2023, which harmonised Greek legisla - tion with the standards of the European Public Prosecutor’s Office (EPPO) for tackling offences affecting the financial interests of the European Union. At the same time, under Law 4557/2018, as updat - ed in 2025, specific persons (“obliged entities”) are required, as part of their compliance obligations, to report suspicious transactions to the Anti-Money Laundering Authority. These include banks, account - ants and tax advisors, lawyers (in certain transac - tions), notaries and statutory auditors. They are also subject to “Know Your Customer” (KYC) obligations, requiring the identification of the ultimate beneficial owner (UBO) of each company. Failure to report sus - picious transactions may result in significant admin - istrative fines and may even give rise to liability as an accomplice. Recent case law focuses on the more effective pros - ecution of tax evasion and non-payment of debts to the state, alongside a rationalisation of sanctions to ensure compliance with the fundamental principle of ne bis in idem. This has been expressly confirmed by the plenary of the Supreme Court ( Areios Pagos ), which held that, for the purposes of establishing crimi - nal liability for debts owed to the state, amounts cor - responding to debts that independently constitute tax offences should not be cumulatively taken into account. However, the application of this principle remains to be further clarified, particularly in light of the recent provisions of Law 5090/2024 concerning legal entities and the parallel imposition of administra - tive and criminal sanctions under various legislative frameworks for the same conduct.
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