GREECE Law and Practice Contributed by: Ilias Anagnostopoulos and Alexandros Mezari, Anagnostopoulos
It should be noted that certain legal persons (eg, banks and other financial services institutions) and professionals are obliged to fulfil specific monitoring and reporting duties in relation to money laundering. They may be held liable if they fail to comply with these obligations (eg, if they intentionally fail to report suspicious transactions). Natural persons may also be held criminally liable for such failures. Administrative sanctions can also be imposed, such as fines. The Hellenic Anti-Money Laundering Authority col - lects evidence within the scope of its administrative powers, which is then forwarded to the Public Pros - ecutor’s Office. 3.14 ESG-Related Offences Environmental Criminal Law Greek environmental criminal law is based on the rele - vant European Directives. Article 28 of Law 1650/1986 criminalises: • an intentional environmental degradation through the exercise of an activity or business without a licence or approval, or in excess of the limits of the licence or approval; and • other forms of unlawful environmental pollution or degradation through act or omission. Environmental pollution or degradation are also pun - ishable if committed negligently. It should be noted that persons who have a leading position within a legal person may be criminally liable if they fail in their duties to prevent environmental crimes (Article 28 par. 5.1 and 5.2 of Law 1650/1986). Depending on the circumstances of each case, impris - onment of up to 20 years and a monetary penalty can be imposed for environmental crimes. Human Trafficking Human trafficking is a serious crime according to Arti - cle 323A of the Greek Penal Code, which criminalises, inter alia, the use or threat of violence, other coercive means or abuse of power to recruit, kidnap, transport, illegally detain, deliver or receive a third person for the purpose of exploiting such person. Article 323A cov -
ers all forms of “modern slavery” and similar acts of “exploitation” against adults or children. The maximum sentence for trafficking in human beings is life imprisonment and a monetary penalty,
depending on each case. Compliance Programmes
Environmental protection and human rights protection are part of modern compliance programmes (see also 3.3 Anti-Bribery Regulation ). 3.15 Artificial Intelligence and Automation Misuse The Greek Penal Code contains several provisions in relation to fraud, computer fraud, cybercrime offenc - es, etc (see 3.1 Criminal Company Law and Corpo- rate Fraud and 3.9 Cybercrimes, Computer Fraud and Protection of Company Secrets ) that may apply in cases of the misuse of AI or other modern technical tools to commit an offence. For example, in some cases, “deepfakes” are already being used to commit fraud, which is punishable under Article 386 of the Greek Penal Code. 3.16 Crypto-Assets and Digital Currency Crimes In 2025, a system of regulatory enforcement in rela - tion to crypto-assets was introduced through Law 5193/2025. The Greek legislation is based on the European legal framework (Regulation (EU) 2023/1114 on markets in crypto-assets). The Hellenic Capital Market Commission and the Bank of Greece have extensive administrative responsibili - ties in this sector, including supervisory powers and powers to impose corrective measures, to carry out investigations, to impose fines or other administrative sanctions, etc. Under Article 107 of Law 5193/2025, intentionally pro - viding professional crypto services without the licence required by Regulation (EU) 2023/1114 is recognised as a criminal offence, which is punishable by impris - onment of between one and five years. If the services are provided by legal entities, criminal sanctions shall
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