GREECE Law and Practice Contributed by: Paris Tzoumas, Vivian Efthymiou and Dimitrios Mekakas, Zepos & Yannopoulos
CFT rules across EU member states. The 4th AML Directive will be repealed by the 6th AML Directive. The majority of new rules under the 6th AML Directive (as the measures will be transposed into Greek law) and under AMLR will apply as of 10 July 2027. • Law 4370/2016, as amended, transposed into Greek law, among others, Directive 2014/49/ EU (the “Directive on Deposit Guarantee Schemes”). • Law 2251/1994 on consumer protection, as amended and codified by Ministerial Decision 5338/2018, which is currently in force (the “Consumer Protection Law”). Depending on the type of services offered to cli - ents, credit institutions should also comply with other laws of the financial sector, including: • Regulation (EU) 600/2014 (the “MiFIR”), as amended, among others, by Regulation (EU) 2024/791 and Law 4514/2018, as amended, transposing Directive 2014/65/EU, as amend - ed (“MiFID II”) in Greece as regards the provi - sion of investment services; and • Law 4537/2018 transposing Directive 2015/2366/EU (“PSD2”) in Greece as regards the provision of payment services. Regula - tion (EU) 2024/886 as regards instant credit transfers in euros amends PSD2 and requires member states to adopt, publish and apply supplementing measures by 9 April 2025. In addition to the laws of the banking sector, Greek credit institutions should also comply with other laws, including Law 4548/2018 on sociétés anonymes , Law 4706/2020 on corporate gov - ernance of listed entities, as applicable, as well as Regulation (EU) 2016/679 (“General Data Pro - tection Regulation”) and Law 3471/2006.
The above laws are supplemented by acts issued by the Bank of Greece (BoG), including the BoG Governor’s Act 2501/2002, as amended and currently in force, on the information that credit institutions must provide to their custom - ers, the BoG Governor’s Act 2577/2006 on the organisational requirements and internal control functions of credit and financial institutions, the BoG Act 392/31.05.2021 on the revision of the Code of Conduct under Greek Law 4224/2013, the BoG Executive Committee Act 178/2020 as regards the outsourcing of activities, the BoG Executive Committee Act 229/10.05.2024 on the determination of the initial capital structure for the issuance of an incorporation and operation license, as well as guidelines issued by the Euro - pean Central Bank (ECB), the European Banking Authority (EBA) and other EU authorities. The BoG is the national competent authority supervising the banking sector and exercising prudential supervision over Greek credit institu - tions. However, within the Single Supervisory Mechanism (SSM), the ECB directly supervis - es the following significant credit institutions authorised in Greece: • Alpha Bank SA; • Eurobank SA; • National Bank of Greece SA; and • Piraeus Bank SA. Less significant credit institutions are supervised directly by the BoG, which is the competent authority for overseeing entities of the financial sector, including payment institutions, credit companies and credit servicing firms. The BoG is also the national resolution author - ity and, along with the Single Resolution Board (SRB), is established within the Single Resolu - tion Mechanism to exercise the resolution pow -
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