GREECE Law and Practice Contributed by: Paris Tzoumas, Vivian Efthymiou and Dimitrios Mekakas, Zepos & Yannopoulos
included in the remuneration policy for all staff; the policy must be consistent with the objectives of the institution’s business and risk strategy, including ESG related objectives. The non-executive BoD members must adopt and periodically review the remuneration policy and are responsible for overseeing its implemen - tation. Credit institutions are also subject to reporting obligations toward the BoG. Greek credit institutions are subject to the Greek AML/CFT legislation, which is in line with the EU AML/CFT legislation. More specifically, the main legal basis is the Greek Law 4557/2018 on “prevention and combatting of money launder - ing and terrorist financing and other provisions”, as amended and in force (“the AML Law”). This implements the following in Greece: Directives 2015/849/EU (4th AML Directive), 2018/843/EU (5th AML Directive) and 2018/1673/EU and Deci - sion No 281/5/17.3.2009 of the BoG’s Banking and Credit Committee specifying the obliga - tions of credit, financial and payment institutions under the AML Law, as amended and in force (“the AML Decision”). The Greek legal framework is supplemented by other BoG acts as well as by laws and guidelines adopted at an EU level (such as EBA Guidelines on ML/TF risk factors and customer due diligence). More specifically, Greek credit institutions are required to adopt AML policy and procedures in accordance with the Greek AML/CFT legis - lation. These include model risk management practices, customer due diligence, reporting, 5. AML/KYC 5.1 AML and CFT Requirements
employee screening, record-keeping, internal control and compliance management, such as the appointment of an MLRO (and their deputy) on the basis of their integrity, status, academic background, experience in the relevant field and credit institution’s operations. One BoD member must also be designated as the member respon - sible for the credit institution’s compliance with the applicable AML/CFT framework. In addition, Greek credit institutions must carry out customer due diligence (CDD) measures when establishing a business relationship, when carrying out occasional transactions exceeding certain thresholds, when there is a suspicion of money laundering or terrorism financing, as well as when there are doubts about the identification data previously obtained. CDD also involves the ongoing monitoring of the business relationship. In the context of the CDD measures, the verifi - cation of the relevant data of natural persons may be carried out either on the basis of original documents issued by reliable and independent authorities, or, with the explicit and special con - sent of the natural person, through the trans - mission of such documents via the electronic platform “eGov-KYC” of the Single Digital Portal of Public Administration. In addition to the eGov- KYC platform, a new platform “eGov-Know Your Business” was set up. 6. Depositor Protection 6.1 Deposit Guarantee Scheme (DGS) The Hellenic Deposit and Investment Guarantee Fund (HDIGF or, in Greek, TEKE) is the operator of three distinct schemes: • the deposit guarantee scheme; • the investment compensation scheme; and
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