--- title: "Greece (GR) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/greece/ source_html: /jurisdictions/greece/index.html description: "Financial integrity intelligence for Greece (GR): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 0ac6a2f9430b4e30e2e44fa9f57d624135ca59c6857790f5122f6c443d4bc869 generator: "fe-fleet/md-twin@1.0" --- # Greece (GR) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Greece GR Domains covered 8 of 8 Sources 180 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Clean Tier: A Risk direction: Increasing Enablement vs enforcement: Mixed Greece operates under the EU AML/CFT acquis with the Hellenic AML Authority and Bank of Greece as key supervisors and the Hellenic FIU as the national financial intelligence unit. More FATF's 2019 MER found foundational effectiveness but flagged weak standalone money-laundering prosecution and inconsistent DNFBP supervision. Greece is not FATF grey-listed. Key deficiencies - Weak prosecution of money laundering as a standalone offence, per FATF 2019 MER - Inconsistent supervision of lawyers, tax advisors and other DNFBPs - Shipping-sector political resistance to stricter Russia sanctions enforcement - History of prosecutorial interference in high-profile corruption cases (Novartis case) Recent developments (18m) - Hellenic AML Authority's first-ever cryptocurrency asset freeze, tied to the February 2025 Bybit/Lazarus Group hack - EPPO investigation into a Greek EU agricultural-subsidy fraud scheme escalating to referral of sitting and former MPs and ministers (2025-2026) - Cabinet reshuffle in April 2026 as EU prosecutors sought parliamentary immunity waivers for 11 lawmakers - Continued Athens Court of Appeal/Supreme Court litigation over the Beny Steinmetz extradition case (2024-2025) - Sharp reduction in Greek-owned tankers hauling Russian crude amid intensified US/EU sanctions pressure (2024-2025) Law made at European Economic Area level that applies in Greece is covered once, on the [European Economic Area](/jurisdictions/eea/) page. This page covers Greece’s own layer: implementation, national authorities, national options and local enforcement. Brief ## Lead signal #### Lead Signal Greece tabled an omnibus bill in Parliament on 26 October 2026 that reinforces the Bank of Greece's supervisory and sanctioning toolkit over credit and claims servicers, with first-stage review by the Economic Affairs Committee beginning 29 October 2026. The bill's core thrust is architectural: it builds out the central bank's capacity to supervise and sanction the servicer sector, including a new mandatory annual claims-management-strategy filing obligation, rather than amending customer due diligence duties, reporting thresholds, or the remit of the national financial intelligence unit. The same bill carries a second, distinct chapter establishing a dedicated tax framework for crypto-asset transfers: a 10 percent capital-gains tax on individuals, with a EUR 500 annual exemption, tied into DAC8 and the OECD Crypto-Asset Reporting Framework. Both chapters are assessed as probable on the strength of contemporaneous Greek-language reporting on the bill's tabling. Read full brief #### Lead Signal Greece tabled an omnibus bill in Parliament on 26 October 2026 that reinforces the Bank of Greece's supervisory and sanctioning toolkit over credit and claims servicers, with first-stage review by the Economic Affairs Committee beginning 29 October 2026. The bill's core thrust is architectural: it builds out the central bank's capacity to supervise and sanction the servicer sector, including a new mandatory annual claims-management-strategy filing obligation, rather than amending customer due diligence duties, reporting thresholds, or the remit of the national financial intelligence unit. The same bill carries a second, distinct chapter establishing a dedicated tax framework for crypto-asset transfers: a 10 percent capital-gains tax on individuals, with a EUR 500 annual exemption, tied into DAC8 and the OECD Crypto-Asset Reporting Framework. Both chapters are assessed as probable on the strength of contemporaneous Greek-language reporting on the bill's tabling. The analytical significance lies in what the bill does not touch. It is a supervisory capacity build and a tax instrument, not an anti-money-laundering or counter-terrorist-financing perimeter change. The crypto-asset obliged-entity regime in Greece continues to run on the existing Markets in Crypto-Assets and EU Anti-Money Laundering Regulation framework, administered through the Bank of Greece and the Hellenic Capital Market Commission, and this bill leaves that perimeter where it was. #### Other Developments Tax transparency chapter advances without AML consequence. The crypto capital-gains provision gives Greek tax authorities a dedicated mechanism for taxing individual crypto-asset disposals and links that mechanism to cross-border reporting data flowing from DAC8 and CARF. This is best read as a fiscal-transparency measure that will generate new data trails on individual holdings rather than a new control obligation on crypto-asset service providers themselves. Servicer supervision build-out sits alongside, not inside, the AML/CTF regime. The bill's annual claims-management-strategy filing requirement increases the Bank of Greece's visibility into servicer conduct and gives it a sharper sanctioning toolkit, but the reporting reviewed identifies no accompanying change to customer due diligence duties, suspicious-transaction reporting thresholds, or the Hellenic Financial Intelligence Unit's receiving role. The two chapters of the bill are progressing together procedurally but are substantively separate: one is prudential-supervisory architecture, the other is a tax instrument. #### Cross-Monitor Connections The servicer-supervision chapter is the kind of enabler-jurisdiction architecture signal that connects to broader financial-sector oversight questions elsewhere in the fleet: a strengthening of a central bank's sanctioning toolkit over a non-bank credit intermediary sector is the structural type of development that recurs across jurisdictions managing legacy non-performing-loan servicing markets. The crypto tax chapter's reliance on DAC8 and CARF data flows is a reminder that fiscal-transparency instruments and anti-money-laundering instruments can move on parallel but distinct tracks within the same piece of legislation, a distinction worth holding onto when cross-referencing crypto-asset developments against other jurisdictions' digital-asset monitors. #### Outlook The omnibus bill was in Economic Affairs Committee review as of 29 October 2026; the exact article and provision numbers for both the servicer-supervision and crypto-tax chapters had not yet been retrieved from the Hellenic Parliament's own documentation or the Government Gazette at the time of this cycle's research. Until the bill clears committee and is published in the Gazette, its provisions should be treated as tabled rather than settled. Whether the crypto tax chapter's DAC8/CARF linkage produces any downstream adjustment to the AML/CTF obliged-entity perimeter for crypto-asset service providers is a question to watch as the bill moves through the legislative process, though nothing in the material reviewed this cycle suggests such an adjustment is currently contemplated. Earlier periodic briefs (6) 4 Nov 2026 · fim-2026-11-04 #### Lead Signal Greece tabled an omnibus bill in Parliament on 26 October 2026 that reinforces the Bank of Greece's supervisory and sanctioning toolkit over credit and claims servicers, with first-stage review by the Economic Affairs Committee beginning 29 October 2026. The bill's core thrust is architectural: it builds out the central bank's capacity to supervise and sanction the servicer sector, including a new mandatory annual claims-management-strategy filing obligation, rather than amending customer due diligence duties, reporting thresholds, or the remit of the national financial intelligence unit. The same bill carries a second, distinct chapter establishing a dedicated tax framework for crypto-asset transfers: a 10 percent capital-gains tax on individuals, with a EUR 500 annual exemption, tied into DAC8 and the OECD Crypto-Asset Reporting Framework. Both chapters are assessed as probable on the strength of contemporaneous Greek-language reporting on the bill's tabling. The analytical significance lies in what the bill does not touch. It is a supervisory capacity build and a tax instrument, not an anti-money-laundering or counter-terrorist-financing perimeter change. The crypto-asset obliged-entity regime in Greece continues to run on the existing Markets in Crypto-Assets and EU Anti-Money Laundering Regulation framework, administered through the Bank of Greece and the Hellenic Capital Market Commission, and this bill leaves that perimeter where it was. #### Other Developments Tax transparency chapter advances without AML consequence. The crypto capital-gains provision gives Greek tax authorities a dedicated mechanism for taxing individual crypto-asset disposals and links that mechanism to cross-border reporting data flowing from DAC8 and CARF. This is best read as a fiscal-transparency measure that will generate new data trails on individual holdings rather than a new control obligation on crypto-asset service providers themselves. Servicer supervision build-out sits alongside, not inside, the AML/CTF regime. The bill's annual claims-management-strategy filing requirement increases the Bank of Greece's visibility into servicer conduct and gives it a sharper sanctioning toolkit, but the reporting reviewed identifies no accompanying change to customer due diligence duties, suspicious-transaction reporting thresholds, or the Hellenic Financial Intelligence Unit's receiving role. The two chapters of the bill are progressing together procedurally but are substantively separate: one is prudential-supervisory architecture, the other is a tax instrument. #### Cross-Monitor Connections The servicer-supervision chapter is the kind of enabler-jurisdiction architecture signal that connects to broader financial-sector oversight questions elsewhere in the fleet: a strengthening of a central bank's sanctioning toolkit over a non-bank credit intermediary sector is the structural type of development that recurs across jurisdictions managing legacy non-performing-loan servicing markets. The crypto tax chapter's reliance on DAC8 and CARF data flows is a reminder that fiscal-transparency instruments and anti-money-laundering instruments can move on parallel but distinct tracks within the same piece of legislation, a distinction worth holding onto when cross-referencing crypto-asset developments against other jurisdictions' digital-asset monitors. #### Outlook The omnibus bill was in Economic Affairs Committee review as of 29 October 2026; the exact article and provision numbers for both the servicer-supervision and crypto-tax chapters had not yet been retrieved from the Hellenic Parliament's own documentation or the Government Gazette at the time of the research. Until the bill clears committee and is published in the Gazette, its provisions should be treated as tabled rather than settled. Whether the crypto tax chapter's DAC8/CARF linkage produces any downstream adjustment to the AML/CTF obliged-entity perimeter for crypto-asset service providers is a question to watch as the bill moves through the legislative process, though nothing in the material reviewed suggests such an adjustment is currently contemplated. 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Greece tabled an omnibus bill in Parliament on 26 October 2026 that reaches into servicer supervision, consumer debt, and the tax treatment of crypto-assets in a single instrument, and the Economic Affairs Committee began its first-stage review on 29 October 2026. The architecture-relevant element is the reinforcement of the Bank of Greece's supervisory and sanctioning toolkit over credit and claims servicers, including a new requirement for each servicer to file an annual claims-management strategy report. Read as a structural matter rather than an enforcement incident, this is a build-out of supervisory capacity over an enabler-adjacent sector, not a direct anti-money-laundering instrument: no customer due diligence, reporting-threshold, or financial-intelligence-unit provision has been identified in the reporting reviewed to date, and the exact article establishing the reporting duty has not yet been retrieved from a primary source. The bill remains at the proposed, pre-enactment stage with the Ministry of National Economy and Finance reportedly targeting passage in the first week of November 2026. #### Other Developments A dedicated crypto capital-gains tax chapter sits inside the same omnibus bill, introducing a 10 percent tax on crypto-asset capital gains with the first 500 euros of annual gains exempted, and tying the regime to DAC8 and CARF cross-border reporting standards. This is a tax and transparency development rather than an anti-money-laundering or counter-terrorist-financing instrument in its own right; the underlying anti-money-laundering obligations for Greek crypto-asset service providers continue to run through the existing MiCA and AML Regulation obliged-entity perimeter, which this bill does not appear to alter. The pairing of a servicer-supervision chapter with a crypto-tax chapter in one instrument is itself a notable packaging choice, since it places two typically separate regulatory tracks — consumer-debt servicing oversight and digital-asset taxation — into the same legislative vehicle moving through committee at the same time. #### Cross-Monitor Connections The servicer-supervision chapter sits adjacent to work tracked elsewhere on commercial activity in the Greek payments and collections space, since any strengthening of Bank of Greece sanctioning power over servicers has implications for how those entities interact with payment rails and merchant-facing collection flows. The crypto-tax chapter, by tying taxation to DAC8 and CARF reporting, touches the broader European transparency architecture that beneficial-ownership and cross-border information-exchange trackers monitor, even though no beneficial-ownership-specific Greek development occurred. Both chapters remain at the bill stage, so the practical cross-monitor relevance is in architecture and sequencing rather than in any confirmed operational effect. #### Outlook The immediate marker to watch is whether the omnibus bill passes in the first week of November 2026 as the Ministry has indicated, and whether the enacted text retrieves a specific article reference for the servicer claims-management-strategy reporting duty that remains unspecified in current reporting. A second marker is whether the final text of the crypto capital-gains tax chapter preserves the 10 percent rate and 500 euro exemption as tabled, and whether any companion guidance clarifies how DAC8 and CARF reporting will interact with existing MiCA-based obliged-entity obligations for Greek crypto-asset service providers. Until enactment, both chapters are properly treated as proposed rather than in force. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal On 21 October 2026, under Operation Economic Outcast, the U.S. Department of the Treasury's Office of Foreign Assets Control designated the law firm Karnakis and Karnakis, operating out of Panama and Piraeus, five associated individuals, and the Piraeus-based shipping agent Roxette Maritime Shipping and Trading S.A., for facilitating Iran's shadow fleet through the registration of vessel-owning companies moving Iranian steel, petroleum and petrochemicals. A General Licence authorises wind-down transactions through 20 November 2026. The designation places a direct Greek corporate and maritime-services nexus at the centre of a United States sanctions-evasion enforcement action for the first time. #### Other Developments FinCEN has issued its first administrative subpoena to a Greek bank. Acting in close coordination with European partners including Greece, FinCEN disclosed its first administrative subpoena under the Bank Secrecy Act, 31 U.S.C. 5318(k), against an unnamed Greek bank over potential ties to Iran and its proxies, part of the same Operation Economic Outcast effort. That statute permits FinCEN to compel a foreign bank maintaining a correspondent account in the United States to produce records tied to that account or to any account at the foreign bank. The EU Council has adopted its largest-ever single package of Russia-related listings. On 12 October 2026 the Council of the European Union adopted restrictive measures against eight hundred twenty-six Russian companies and seven hundred forty-three individuals active in Russia's military-industrial complex, via Council Implementing Regulation (EU) 2026/2281, which applies directly to Greek obliged entities without any national transposition step. #### Cross-Monitor Connections The Piraeus nexus in the Karnakis and Roxette Maritime designations sits squarely within Greece's shipping and maritime-registration sector, a sector relevant to any monitor tracking state-level sanctions evasion through flag-of-convenience and vessel-ownership structures. The parallel FinCEN subpoena of a Greek bank signals correspondent-banking-level scrutiny that connects directly to payments-architecture monitoring of how Iran-linked flows move through European banking channels. The EU Council's Russia-listings expansion, meanwhile, is relevant to conflict-finance tracking given its direct bearing on Russia's military-industrial complex and its automatic application across Greek-based obliged entities. #### Outlook The wind-down period under the General Licence tied to the Karnakis and Roxette Maritime designations runs through 20 November 2026, and what happens at that date, whether further designations follow or the matter remains contained to the entities already named, will be the next concrete marker. Separately, confirmation of which Greek bank received the FinCEN subpoena, and whether that disclosure becomes public, would sharpen the picture of correspondent-banking exposure tied to Iran-nexus activity running through Greece. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Greece's domestic crypto-asset regulatory architecture moved from a zero-domestic-authorisation state to four authorised entities in a single register update this cycle, closing a roughly fifteen-month implementation gap under MiCA. On 24 September 2026, ESMA's MiCA register added BCASH, Xenios Blockchain Group and Capital Wallet, all authorised by the Hellenic Capital Market Commission between 30 June and 7 August 2026, alongside Piraeus Bank, authorised by the Bank of Greece. Binance had withdrawn its own Greek CASP application on 24 June 2026, before a formal HCMC decision was reached; a disputed allegation of ECB involvement in that withdrawal has not been independently corroborated. #### Other Developments Beneficial-ownership transposition gap. On 25 September 2026 the European Commission sent letters of formal notice to 18 EU Member States, including Greece, over incomplete transposition of AMLD6 beneficial-ownership register-access rules, whose transposition deadline was 10 July 2026. This is a structural, bloc-wide implementation lag rather than evidence of deliberate permissiveness: Greece sits among two-thirds of the EU membership named in the same notice, and its BORIS beneficial-ownership records remain otherwise searchable. Capital Wallet authorisation. Capital Wallet Greece announced on 27 July 2026 that it had secured MiCA CASP authorisation from the HCMC, among the first granted domestically, enabling EU-wide passported service from an Athens base. This is one of the dated commercial-entry events feeding the broader crypto-authorisation wave described above. #### Cross-Monitor Connections The MiCA CASP authorisation wave described above is directly relevant to the Crypto monitor's licensing and commercial-activity tracking for Greece, where the same four authorisations and the Binance withdrawal are tracked as domestic market-structure developments. The beneficial-ownership transposition gap connects to the Data Protection monitor's enforcement and governance tracking only insofar as registry-access rules intersect with data-protection obligations on BO registers, though no direct linkage has been sourced this cycle. #### Outlook Primary-source confirmation from the European Commission, ESMA or the HCMC directly would resolve the current reliance on secondary reporting for both the AMLD6 formal-notice step and the MiCA CASP register entries. Whether further domestic CASP authorisations follow this initial wave, and whether Greece closes its AMLD6 transposition gap ahead of the other 17 named Member States, are the clearest items to watch next. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Greece has produced two distinct, sourced developments this cycle rather than a single dominant signal. The first concerns the architecture of sanctions enforcement: Greece secured an exemption inside the European Union's 21st Russia sanctions package, agreed 23 July 2026, permitting continued shipment of Russian LNG to non-EU clients even as the broader package extended shadow-fleet and crypto-service restrictions. This is a member-state carve-out inside an otherwise bloc-wide instrument, and it is best read architecturally rather than as an isolated incident: it illustrates how negotiated divergence persists within a nominally uniform EU sanctions regime even as that regime tightens elsewhere. The underlying Council legal text has not itself been retrieved, so the finding rests on journalism reporting the outcome of the negotiation, capping assessment at probable rather than confirmed. The second development concerns market entry rather than enforcement. Greece's first four Markets in Crypto-Assets authorisations appeared on the European Securities and Markets Authority register on 24 September 2026, closing a gap of roughly fifteen months during which Greece had no domestically authorised crypto-asset service provider despite MiCA being in force across the bloc. The closure of a long-standing authorisation gap is itself a form of structural signal distinct from any single enforcement action, and it sits squarely in the crypto and financial-innovation domain this cycle. #### Other Developments Binance's withdrawal from the Greek authorisation process preceded the first domestic approvals by six days: the exchange withdrew its Greek MiCA application on 24 June 2026. A later allegation of European Central Bank involvement in that withdrawal has circulated but was not independently verified this cycle, and the finding is accordingly held at uncertain confidence pending corroboration beyond the single reporting source. Greece's standing AML/CTF architecture continues to operate under direct binding to the EU Anti-Money Laundering Regulation ahead of its 10 July 2027 full-application date. Greece's 2019 FATF mutual evaluation rated the jurisdiction Compliant on fifteen and Largely Compliant on twenty-two of the forty FATF Recommendations, with no current grey-list or increased-monitoring status. This is baseline-descriptive and unchanged this cycle, but is restated here because it frames the regulatory backdrop against which the sanctions and crypto developments above are read. A related honesty note: the transposition status of the sixth Anti-Money Laundering Directive for Greece specifically was not established this cycle, and that gap is recorded rather than filled with an assumed date. #### Cross-Monitor Connections The LNG sanctions carve-out has a direct bearing on conflict-finance and trade-finance monitoring more broadly: a jurisdiction-level exemption inside a sanctions package is precisely the kind of architectural divergence that enabler-jurisdiction and conflict-finance analysis elsewhere in the fleet would want to track for repeat patterns, even though those specific domains carried no new Greece-specific signal this cycle. The crypto-authorisation development connects to the crypto monitor's own licensing coverage: the same underlying fact of Greece's first domestic CASP authorisations is the subject of parallel, module-specific treatment there, with this brief's framing emphasising the integrity and typology-exposure reading of the same event rather than the licensing-mechanics reading. #### Outlook Two threads are worth watching into the next reporting window. First, whether the full Council legal text for the LNG exemption becomes available, which would allow the sanctions-architecture finding to move from probable toward confirmed and would clarify whether the carve-out is time-limited or open-ended. Second, whether additional Greek MiCA authorisations follow the initial four, which would indicate whether September 2026 marked a genuine regime activation or a narrow first tranche. Greece's AML/CTF regime, as scheduled, moves toward full AMLR application by 10 July 2027; no deviation from that trajectory was found this cycle. 5 Sep 2026 · fim-2026-08-05 #### Lead Signal Greece's financial-integrity posture this cycle is defined by a convergence of AML-driven gatekeeping and structural non-transposition risk that together push the jurisdiction's risk trajectory toward tightening even as its underlying institutions show no sign of bad faith. On 24 June 2026, Binance withdrew its Greek Markets in Crypto-Assets application after the Hellenic Capital Market Commission signalled it would reject the filing over anti-money-laundering history and fit-and-proper concerns connected to Changpeng Zhao; the withdrawal cost Binance access to new EU services from 1 July 2026 and the exchange is now pursuing authorisation through France instead. Ten days earlier, on 4 June 2026, the European Commission issued a formal warning to Greece, alongside Luxembourg and Sweden, for incomplete transposition of the sixth Anti-Money Laundering Directive's offence-and-penalty provisions, opening a two-month response window. Read together, these are not contradictory signals: a national securities regulator applying rigorous AML scrutiny to a systemically significant crypto platform, sitting alongside a national legislature that has not yet finished transposing the EU's own AML-offence architecture, describes an enforcement posture that is stronger at the point of individual licensing decisions than at the level of completed statutory infrastructure. #### Other Developments EU 21st sanctions package escalates crypto and shadow-fleet exposure. The EU's 21st Russia sanctions package, adopted 23 July 2026, added 218 designations in the bloc's largest listing round in four years, extending crypto-asset service bans, effective 25 August 2026, across fourteen platforms spanning six jurisdictions, and tightening banking and tanker sanctions targeting Russia's war-economy financing. Greece's shipping-sector economic interests generated negotiation friction within the package: Athens pushed to freeze the Russian oil price cap at $44.10 per barrel, a position reflecting the exposure of Greece's large commercial tanker fleet to Russian crude trade rather than any resistance to the sanctions architecture itself. Shipping-fleet exposure creates a structural conflict-finance watch item. Greece's scale as a shipping nation gives its vessels structural capacity to be implicated, deliberately or not, in circumvention of the Russian oil price cap, a channel identified as financing Russia's war economy. This is assessed at low confidence and is framed as a structural capacity risk rather than an allegation of Greek bad faith; Greece's price-cap negotiating position is more plausibly read as protection of a legitimate strategic industry than as sanctions evasion by the state. HCMC scrutiny is read as gatekeeping rather than enabling. The AML and fit-and-proper scrutiny that led to Binance's withdrawal is assessed, at low confidence, as evidence that Greece's securities regulator prevented a potential passporting weak link from opening within the Markets in Crypto-Assets Regulation's EU-wide single-authorisation model, rather than Greece functioning as a permissive entry point for a scrutinised platform. Bank of Greece continues baseline AML/CFT supervision. Bank of Greece continues to supervise AML/CFT compliance for institutions under its remit, checking procedures and assessing their adequacy and effectiveness; no new RegTech or active-defence development was identified this cycle, and this baseline supervisory role sits as the institutional backdrop against which the transposition gap and the Binance decision both occurred. #### Cross-Monitor Connections The Binance Markets in Crypto-Assets withdrawal is a direct World Payments Monitor cross-reference: the Hellenic Capital Market Commission's rejection signal is a discrete crypto-asset-service-provider licensing event with EU single-market-access consequences that the World Payments Monitor tracks under commercial and product-authorisation lenses distinct from this monitor's AML-architecture reading of the same event. The EU 21st sanctions package's shadow-fleet and tanker-sanctions dimension connects to commodity-flow tracking given Greece's position in global tanker capacity and Russian crude transport. The sixth Anti-Money Laundering Directive transposition warning against Greece, Luxembourg and Sweden is a standing EU AML Package architecture item that recurs across financial-integrity jurisdiction files for all three named states, and should be read alongside the broader AML Regulation and Anti-Money Laundering Authority supervisory build-out rather than as an isolated Greek compliance failure. #### Outlook The immediate date to watch is the close of Greece's two-month response window to the European Commission's transposition warning, falling in early August 2026; a further Commission escalation step, or a demonstrated transposition fix, would materially change this jurisdiction's beneficial-ownership-and-transparency trajectory. On the crypto side, whether Binance secures French Markets in Crypto-Assets authorisation, and whether the Hellenic Capital Market Commission's rejection rationale is ever confirmed on the record rather than resting on secondary reporting, will determine whether Greece's gatekeeping posture is read as a template other national competent authorities adopt or as a one-off. The EU sanctions package's crypto-platform bans take effect 25 August 2026, and Greece's price-cap negotiating position is worth monitoring for whether it resurfaces in subsequent sanctions-package negotiation rounds. Board and MLRO stakeholders should treat the Binance episode as a live illustration of how AML-history and fit-and-proper scrutiny can now function as an EU-wide gatekeeping mechanism under the Markets in Crypto-Assets Regulation's passporting model, independent of any formal enforcement action against the platform itself. Domain intelligence (D1–D8) #### Sanctions Greece's sanctions-exposure picture tightened on two separate tracks within the same short window. On 21 October 2026, under Operation Economic Outcast, the U.S. Department of the Treasury's Office of Foreign Assets Control designated the law firm Karnakis and Karnakis, based in Panama and Piraeus, five associated individuals, and the Piraeus-based Roxette Maritime Shipping and Trading S.A. The designation addresses the registration of shadow-fleet vessel-owning companies used to move Iranian steel, petroleum and petrochemicals, placing a Greek maritime-services and legal nexus directly inside a United States sanctions-evasion architecture. A General Licence permits wind-down transactions through 20 November 2026, meaning entities with existing exposure to the designated parties have a defined window to unwind rather than an immediate cutoff. Continue reading Separately, on 12 October 2026, the Council of the European Union adopted its largest-ever single package of Russia-related sanctions listings, covering eight hundred twenty-six companies and seven hundred forty-three individuals active in Russia's military-industrial complex, through Council Implementing Regulation (EU) 2026/2281. As an EU member state, Greece is bound by this measure directly, without any national transposition step, meaning Greek obliged entities must apply the expanded listing immediately upon the Regulation's entry into force. The two measures proceed on different legal and political tracks, United States Iran-sanctions enforcement against shipping-sector enablers on one side, and the EU's autonomous Russia-sanctions architecture on the other, but both bear directly on Greek-domiciled or Greek-linked entities within the same reporting window, illustrating how Greece's position as a major shipping and maritime-services hub exposes it to parallel and independently-evolving sanctions regimes. #### Outlook The 20 November 2026 close of the Karnakis/Roxette Maritime wind-down period is the next concrete date to watch, as is whether OFAC extends its shadow-fleet designations further into Greece's shipping-registration sector. On the EU side, continued expansion of the Russia military-industrial-complex list remains an active and recurring pattern rather than a one-off event. Judgment: No GR-specific sanctions-evasion signal identified this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency As a European Union member state, Greece sits squarely inside the direct perimeter of the EU AML Package, and the structural backdrop against which this cycle beneficial-ownership signal should be read is the three-instrument architecture the Package establishes. The AML Regulation, Regulation (EU) 2024/1624, is directly applicable law and becomes binding across Greek obliged entities from 10 July 2027, harmonising customer due-diligence and beneficial-ownership requirements that were previously subject to national transposition variance. Alongside it, the sixth AML Directive, Directive (EU) 2024/1640, must be transposed into Greek domestic law by the same 10 July 2027 date, establishing financial-intelligence-unit powers and supervisory cooperation frameworks, though Greek transposition status has not been independently verified this cycle. The third instrument, the AMLA Regulation, Regulation (EU) 2024/1620, establishes the Anti-Money Laundering Authority and is expected to begin direct supervision of a first cohort of high-risk cross-border obliged entities from around 2027 to 2028, potentially including Greek banks or crypto firms that meet risk thresholds. Together these three instruments shift supervision from a purely national model, run through the Hellenic Anti-Money Laundering Authority and the Bank of Greece, toward a hybrid EU-level regime in which AMLA assumes direct or indirect oversight of the highest-risk obliged entities. This is durable structural context rather than a single-cycle development, and it is the backdrop against which the more immediate Greek signals below should be assessed. Continue reading Against that backdrop, the Golden Visa residency-by-investment channel remains an active beneficial-ownership opacity signal. Non-EU nationals may obtain Greek, and by extension EU, residency through real estate or bond investment from around EUR 250,000, with limited due diligence applied to source of wealth. FATF and OECD work on the misuse of citizenship and residency-by-investment programmes more broadly frames this as a structural, cross-jurisdictional channel, spanning Greece, Cyprus, Malta and Portugal, for obscuring beneficial ownership and laundering proceeds of fraud and corruption, rather than as a Greece-specific or single-incident concern. The other major beneficial-ownership-relevant development this cycle is the escalation of the OPEKEPE agricultural-subsidy fraud prosecution. Thirty-seven people were arrested on 23 October 2025 for defrauding the EU Common Agricultural Policy subsidy system of over EUR 19.6 million through falsified land leases, inflated livestock numbers and fictitious invoices, laundering the proceeds into luxury goods and vehicles; the wider investigation involves at least EUR 23 million since 2018 across 324 identified subsidy recipients. This scheme illustrates how opaque corporate and personal beneficial-ownership arrangements at the domestic level, not only cross-border investment-migration structures, can channel EU public funds into laundered private wealth, and it demonstrates that Greek beneficial-ownership opacity is a live enforcement concern rather than a purely theoretical or historical one. Underlying supervisory capacity remains a documented structural gap. The FATF 2019 Mutual Evaluation Report found foundational AML and CFT effectiveness in Greece but flagged weak prosecution of money laundering as a standalone offence and inconsistent supervision of lawyers, tax advisors and other designated non-financial businesses and professions, with no fifth-round on-site date yet publicly scheduled. Real estate agents, notaries and investment intermediaries who process Golden Visa applications sit within the same DNFBP supervisory perimeter FATF found inconsistent, meaning the professional-facilitator gap and the residency-investment opacity channel are two faces of the same underlying structural weakness rather than separate risks. #### Outlook The Golden Visa channel and the DNFBP-supervision gap identified by FATF are structural, and the 2027 to 2028 EU AML Package implementation window is the primary lever available to close them, rather than any single Greek domestic reform. The OPEKEPE prosecution trajectory is a near-term watch point: its outcome will indicate whether Greek beneficial-ownership opacity concerns can be pursued to conviction against politically connected defendants, or whether the case stalls in a manner consistent with the documented pattern of prosecutorial interference in prior high-level corruption cases. Over the medium term, the extent to which AMLA direct supervision reaches Greek entities from 2027 to 2028, and whether Greek 6AMLD transposition is confirmed against the European Commission member-state transposition monitor, are the two concrete markers against which the beneficial-ownership assessed direction for Greece should be re-tested next cycle. Judgment: No new GR-specific BO development this cycle; the late-September 6AMLD-transposition infringement procedure (GR among 18 Member States) pre-dates this window and is carried forward. Uncertain #### Enabler Jurisdictions Greece tabled an omnibus bill in Parliament on 26 October 2026 that strengthens the Bank of Greece's supervisory and sanctioning toolkit over credit and claims servicers. First-stage review by the Economic Affairs Committee began 29 October 2026. The bill introduces a new mandatory annual claims-management-strategy filing obligation for servicers and expands the central bank's sanctioning capacity over the sector. This is assessed as probable on the strength of contemporaneous Greek-language press reporting on the bill's tabling. Continue reading Read through an enabler-jurisdiction lens, the development is architecture-adjacent rather than an enforcement event: it is a build-out of the state's supervisory toolkit over a sector (claims and credit servicers) that has historically sat at the edge of core banking regulation in several EU jurisdictions managing legacy non-performing-loan portfolios. The material reviewed this cycle identifies no accompanying change to customer due diligence duties, suspicious-transaction reporting thresholds, or the role of the Hellenic Financial Intelligence Unit as reporting recipient. That absence is itself worth noting: a bill that increases supervisory visibility and sanctioning power over a non-bank credit intermediary sector without touching the anti-money-laundering obligations that sector's obliged entities already carry under Law 4557/2018 represents a narrower, more targeted intervention than a full AML/CTF perimeter revision would be. The exact article and provision numbers of the servicer-supervision chapter have not yet been retrieved from the Hellenic Parliament's documentation or the Government Gazette, so the precise mechanics of the Bank of Greece's expanded sanctioning toolkit remain to be confirmed once the bill advances past committee stage. #### Outlook The bill remains in Economic Affairs Committee review. Its progression through to Gazette publication is the next point at which the servicer-supervision chapter's provisions will be fixed rather than tabled, and that is the point at which any consequential effect on the servicer sector's standing obligations, if any emerges, would become visible. Judgment: The tabled bill strengthens Bank of Greece supervisory capacity over servicers; this is a build-out of supervisory architecture, not a change to AML/CFT obligations. Probable #### Conflict Finance and Extractive-Industry Integrity Read through a conflict-finance lens rather than a sanctions-architecture lens, the Greek tanker-resale pipeline is most significant for what it directly sustains: Russian state war-economy revenue. Greek shipowners have sold aging tankers into shell-company chains that feed the Russian shadow fleet, collectively earning over USD 6.3 billion in the process, and the vessels these sales generate carry Russian crude above the price cap, converting Western commercial transactions into a direct revenue stream for a state conducting a war of aggression against Ukraine. This is the conflict-finance reading of the same evidentiary record examined under the sanctions-architecture domain: the financial flow, its source in Western vessel sales, its channel through shell-company intermediaries in the Marshall Islands, the United Arab Emirates and elsewhere, and its deployment into sustained Russian oil-export revenue during an active armed conflict, together satisfy the trace-source, trace-channel, trace-deployment structure the conflict-finance filter applies. Continue reading The second conflict-finance-relevant signal this cycle concerns extractive-industry integrity rather than armed-conflict revenue directly. Beny Steinmetz is the subject of contested cross-border extradition litigation tied to an opaque real-estate acquisition scheme; the Athens Court of Appeals ruled in January 2025 that he should be extradited to Romania for a five-year sentence over a fraudulent real-estate acquisition scheme exceeding USD 100 million, a ruling the Greek Supreme Court subsequently blocked. This illustrates Greek function as a contested venue for cross-border asset-recovery and extradition litigation involving opaque corporate structures tied to extractive-industry wealth, a distinct but adjacent integrity concern to armed-conflict financing: both involve the use of jurisdictional friction and opaque corporate vehicles to protect wealth derived from, or connected to, extractive-sector activity from cross-border legal accountability. Taken together, these two signals show Greece playing a dual role in this domain: an enabling role in the shadow-fleet financing chain that sustains an active armed conflict, and a contested-venue role in extractive-industry asset-recovery litigation that does not itself generate war-economy revenue but reflects the same underlying pattern of opaque corporate structures resisting cross-border legal accountability. Neither signal is resolved. The shadow-fleet financing chain continues to operate notwithstanding intensified EU, US and UK vessel-designation activity, and the Steinmetz extradition ruling remains blocked at the Greek Supreme Court rather than executed. The affected-firm-type footprint spans investment firms and cross-sector intermediaries handling high-net-worth and corporate structures connected to the Steinmetz matter, and banks, correspondent-banking relationships and trade-finance desks connected to the shadow-fleet resale chain, meaning conflict-finance and extractive-industry-integrity exposure in the Greek file is not confined to any single financial sub-sector. This domain also intersects with political-economy resistance documented separately in the enabler-jurisdiction domain, namely Greek reluctance alongside Cyprus and Malta to accept stricter shadow-fleet enforcement, since the same shipping-sector political weight that generates that resistance is the sector through which the shadow-fleet financing chain operates. #### Outlook The conflict-finance trajectory for Greece is assessed as worsening, since the underlying vessel-resale mechanism sustaining Russian war-economy revenue has not itself been disrupted even as designation volume rises. The extractive-industry asset-recovery question is better characterised as unresolved than as worsening or improving: the Steinmetz case remains in a state of judicial contestation rather than closure, and its ultimate resolution, either through executed extradition or continued blockage, will be a signal of how far Greek courts are prepared to go in cross-border asset-recovery matters involving extractive-sector wealth. Because the same shell-company-intermediary pattern recurs across both the shadow-fleet financing chain and the Steinmetz asset-recovery litigation, developments in the beneficial-ownership and enabler-jurisdiction domains examined elsewhere in this brief should be read as directly informing the conflict-finance and extractive-industry assessed trajectory in coming cycles. Judgment: No GR-relevant conflict-finance signal identified this cycle. Uncertain #### Crypto, Digital Assets, and Financial Innovation The same omnibus bill tabled in the Hellenic Parliament on 26 October 2026 carries a distinct chapter establishing Greece's first dedicated tax framework for crypto-asset transfers: a 10 percent capital-gains tax on individuals' crypto-asset disposals, with a EUR 500 annual exemption, tied into DAC8 and the OECD Crypto-Asset Reporting Framework for cross-border data exchange. This is assessed as probable on the strength of contemporaneous Greek-language press reporting on the bill's tabling. Committee review began 29 October 2026. Continue reading For Greece's own digital-asset regulatory perimeter, the relevant backdrop is the Markets in Crypto-Assets authorisation regime already administered by the Hellenic Capital Market Commission, which acts as the competent authority for the authorisation, admission to trading, and advertising of crypto-assets, and the Bank of Greece's complementary supervisory role under the national implementing legislation (Law 5193/2025). The new tax chapter sits alongside that perimeter rather than inside it: it is a fiscal-transparency instrument aimed at taxing individual holders' gains and linking that data to cross-border reporting flows, not an amendment to the customer due diligence, travel-rule, or authorisation obligations that crypto-asset service providers already carry under the Markets in Crypto-Assets and EU Anti-Money Laundering Regulation framework. Those obliged-entity duties remain governed by the existing perimeter, unchanged this cycle. The distinction matters for how the development should be read: a jurisdiction adding a capital-gains tax on crypto-asset transfers is building fiscal visibility into individual holdings, which is a different kind of control than strengthening anti-money-laundering obligations on the service providers that intermediate those transfers. Both can matter for financial-integrity purposes, but they are not interchangeable, and the reporting reviewed this cycle supports only the tax-transparency reading. #### Outlook The crypto-tax chapter's exact provisions await confirmation once the bill clears committee and reaches the Government Gazette. Whether the DAC8/CARF data linkage it establishes produces any downstream adjustment to the AML/CTF obliged-entity perimeter for Greek crypto-asset service providers is a question for the next cycle; nothing in the material reviewed so far indicates such an adjustment is currently contemplated. Judgment: New crypto tax framework is a tax-transparency development, not an AML/CFT perimeter change. Probable #### Compliance Technology and Active Defence The single clearest active-defence development in the Greek jurisdiction file this cycle is the demonstrated capability of the Hellenic Anti-Money Laundering Authority to trace and freeze cryptocurrency proceeds using pre-procured blockchain-analytics tooling. The Authority used local technology partner Performance Technologies together with the Chainalysis Reactor platform, both procured in advance of the incident, to trace and freeze a tranche of the Bybit exchange theft proceeds attributed to the DPRK Lazarus Group. The significance of this development, read through the compliance-technology and active-defence lens, lies specifically in the timing of procurement: the tooling was in place before the incident occurred, meaning the resulting freeze reflects a forward-looking, technology-enabled investigative posture rather than an ad hoc response assembled reactively after the fact. Continue reading This distinction between proactive and reactive compliance posture is the central analytical point of this domain. A national AML authority that must acquire analytics capability only after an incident has already occurred is structurally behind the threat it is trying to address; a national AML authority that has already procured and integrated blockchain-analytics tooling before an incident occurs is positioned to act within the window in which stolen or laundered crypto assets remain traceable and, in principle, recoverable. The first-ever cryptocurrency asset freeze in Greece is a discrete but genuine RegTech and active-defence milestone precisely because it demonstrates that this proactive posture, rather than remaining aspirational, has now been operationalised at least once by a national authority. It is important to characterise the scale of this development honestly rather than overstate it. This is a single documented instance, not yet a demonstrated pattern of repeated blockchain-analytics-enabled enforcement, and the underlying Bybit theft itself originated far outside Greek jurisdiction, with the Greek nexus being one point along a much longer international laundering chain. The genuine significance of the development is narrower and more structural than the headline figures involved: it is that the institutional capability now exists and has been proven operational, which is a necessary precondition for any future, more systematic use of blockchain analytics by Greek authorities, rather than a claim that Greek crypto-asset supervision has now reached full maturity. This development also carries a cross-pillar significance rather than sitting neatly within a single AML, CTF or CPF category: it demonstrates active-defence capability applicable across all three pillars, since the same blockchain-analytics tooling that traced Bybit-hack proceeds could in principle be applied to CTF-relevant or CPF-relevant crypto flows in future matters. The affected-firm-type footprint of this capability spans both crypto-asset operators directly and the banks that may ultimately receive off-ramped proceeds, meaning the practical value of this tooling extends beyond the virtual-asset sector into the traditional banking channels crypto-laundering proceeds eventually re-enter. This honesty-over-coverage framing matters because compliance-technology narratives are prone to overstatement following a single high-profile success, and the FIM analytical register requires that a single instance be labelled as exactly that until a pattern is independently confirmed. #### Outlook The concrete marker to watch across coming cycles is repetition: whether the Hellenic Anti-Money Laundering Authority conducts further blockchain-analytics-enabled enforcement actions beyond the Bybit-linked freeze, which would confirm that the proactive compliance posture demonstrated this cycle has become an operating norm rather than a one-off capability demonstration. This domain also intersects directly with the digital-asset regulatory perimeter discussed elsewhere in this brief, since the same institutional capability that enabled this freeze will likely be tested further as Greek crypto-asset service providers complete MiCA authorization and come under a more structured supervisory regime, and potentially, from around 2027 to 2028, under AMLA direct supervision for the highest-risk cross-border entities. On present evidence, the compliance-technology trajectory for Greece is assessed as improving, though from a narrow evidentiary base of a single demonstrated action. Judgment: No new GR-specific RegTech/AI-transaction-monitoring supervisory development this cycle. Uncertain Judgment: GR's AML/CFT regime remains descriptively unchanged this cycle: Law 4557/2018 as amended, Bank of Greece and HCMC as supervisory authorities, Hellenic FIU as reporting recipient, bound directly by the AMLR as an EU Member State. Probable #### Commercial Activity Multiple dated commercial and regulatory-entry events occurred in Greece's crypto-services sector within this window, led by Capital Wallet's, BCASH's and Xenios's HCMC authorisations and Piraeus Bank's Bank-of-Greece authorisation. Capital Wallet Greece announced on 27 July 2026 that it had been granted a MiCA CASP authorisation by the HCMC, among the first such authorisations granted in Greece, a development that opened EU-wide expansion potential from a domestic base. BCASH and Xenios Blockchain Group received comparable HCMC authorisations within the same broad window (30 June-7 August 2026), and Piraeus Bank was separately authorised by the Bank of Greece; all four appeared together on ESMA's MiCA register on 24 September 2026. Continue reading These four authorisations, viewed as a single commercial-activity cluster, represent the practical commercial expression of Greece's domestic MiCA implementation closing its authorisation gap. Set against this wave, Binance's withdrawal of its own Greek CASP application on 24 June 2026, ahead of a formal HCMC decision, is the notable counter-signal: a major global exchange exiting the authorisation process in the same general period that four other entities, including a mainstream domestic bank, completed it. #### Outlook The near-term question is whether the current cluster of four authorisations is followed by additional domestic market entrants, and whether Binance re-engages with the Greek authorisation process. Continued tracking of commercial-entry events in this sector through year-end would clarify whether this cycle's cluster represents a one-off register update or the start of a sustained authorisation pipeline. Judgment: No commercial transactions among financial-integrity-infrastructure firms identified for GR this cycle. Uncertain Regulatory horizon Adopted 2027-07 · ±year ### AMLD6 transposition deadline / UBO access reform Fuller beneficial-ownership register access rights (Arts 11-13, 15) must be transposed; Greece's Law 5259/2025 currently grants only limited 'legitimate interest' access. [European Commission Source](https://kyckr.com/guides-and-reports/eu-ubo-register-access-for-obliged-entities) In Force Pending 2027-07 · ±multi_year ### AMLA phased supervisory roll-out Obliged entities must submit risk data to feed the selection methodology by 15 August 2026; direct AMLA supervision of up to 40 cross-border entities begins in 2028. [EU Anti-Money Laundering Authority (AMLA) Source](https://www.amla.europa.eu/faqs_en) In Force Pending 10 Jul 2027 · ±quarter ### AMLR / 6AMLD national transposition application date for Greece Directly-applicable EU AML Regulation supersedes elements of the current directive-transposition model; 6AMLD national transposition also due. [European Union / Hellenic Parliament Source](https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/greece) Consultation 2027-Q3 · ±year ### AMLD6 beneficial-ownership register-access national transposition (Greece) Access-rule standardisation for who may view Greek company/trust beneficial-ownership data, per AMLD6's tiered legitimate-interest model. [Greek legislature (transposing EU Directive (EU) 2024/1640) Source](https://www.comsuregroup.com/news/18-eu-states-miss-beneficial-ownership-access-deadline-aml-programmes-now-run-on-a-split-map/) In Force Pending 2027-Q3 · ±quarter ### AMLR / 6AMLD application date Directly-applicable uniform AML/CFT rulebook supersedes the current national-transposition model for obliged entities in Greece. [European Commission / AMLA Source](https://financialregulations.eu/blog/eu-aml-package-amla-amlr-guide) 5 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards Compliance ### A Greek omnibus bill tabled 26 October 2026 strengthens Bank of Greece supervisory and sanctioning powers over credit and claims servicers, without altering AML/CTF obligations. The bill adds a mandatory annual claims-management-strategy filing obligation and widens sanctioning capacity over servicers, but the material reviewed identifies no accompanying change to customer due diligence duties or reporting thresholds. Firms in the servicer sector should track committee progress for confirmation of final provisions. 1 evidence refs Board ### Greece tabled legislation reinforcing central-bank oversight of credit servicers and introducing a crypto-asset capital-gains tax, both still in committee review. The servicer-supervision chapter increases regulatory visibility and sanctioning exposure for firms in that sector; the crypto tax chapter is a fiscal measure with no identified AML/CTF consequence. Neither has reached final form. 2 evidence refs CTO ### Greece's tabled crypto-asset tax chapter does not alter the existing Markets in Crypto-Assets authorisation or AML obliged-entity perimeter for digital-asset platforms. The 10 percent capital-gains tax with DAC8/CARF reporting linkage is a fiscal-transparency measure affecting individual holders' tax data flows, not a change to the technical or compliance architecture crypto-asset service providers already operate under. 1 evidence refs Risk ### A Greek omnibus bill signals increased supervisory capacity over the credit-servicer sector alongside a new crypto-asset tax instrument, both procedurally linked but substantively separate. The servicer-supervision chapter represents a structural build-out of Bank of Greece sanctioning power, which is the kind of enabler-jurisdiction architecture signal worth tracking even absent an AML/CTF perimeter change. The crypto tax chapter is a parallel, distinct fiscal-transparency track. 2 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No GR-specific signal this cycle. T2 · EU AML Package / AMLA no_change No new GR transposition development this cycle; 6AMLD infringement procedure (18 Member States incl. GR) is a carry-forward. T3 · FATF Grey List no_change GR not FATF grey-listed; no movement this cycle. T4 · Beneficial-Ownership Register Status no_change No GR-specific BO development beyond carried-forward 6AMLD infringement status. T5 · Crypto & Digital-Asset Integrity stable GR omnibus bill introduces first dedicated crypto-asset capital-gains tax (10%, EUR 500 exemption) tied to DAC8/CARF; a tax/transparency development, AML perimeter unchanged. T6 · Sanctions Regime Divergence no_change No GR-specific listing-divergence development this cycle. Registers ### Enforcement actions - 1 Feb 2025 - 23 Oct 2025 - 1 Apr 2026 - 28 Jan 2025 - 4 Jun 2026 - - 1 Jan 2024 - - Greece's Hellenic AML Authority, working with local technology partner Performance Technologies and Chainalysis's Reactor platform, traced and froze crypto assets linked to the February 2025 $1.5 billion Bybit exchange hack attributed to North Korea's Lazarus Group. 1 Feb 2025 - Greek authorities arrested 37 people in an EPPO-led crackdown on a network that used falsified land leases, inflated livestock numbers and fictitious invoices to defraud the EU's Common Agricultural Policy subsidy system of over EUR 19.6 million, laundering proceeds into luxury goods and vehicles. 1 Oct 2025 - EPPO requested that the Hellenic Parliament lift the immunity of 11 lawmakers as part of its investigation into the OPEKEPE farm-subsidy fraud scheme, alleging some officials enabled false claims through fabricated land leases and livestock declarations while in office. 1 Apr 2026 - The Athens Court of Appeals ruled that mining magnate Beny Steinmetz should be extradited to Romania to serve a five-year sentence for forming an organized criminal group that fraudulently acquired over $100 million of real estate in a scheme involving a disputed Romanian royal claimant. 28 Jan 2025 ### Sanctions changes - 18 Dec 2025 - 15 Dec 2025 - 10 Jan 2025 - 1 Jul 2025 - 23 Jul 2026 - 21 Oct 2026 - 12 Oct 2026 - The EU Council imposed restrictive measures on an additional 41 vessels forming part of Russia's shadow fleet, bringing the total of EU-designated vessels to almost 600, targeting tankers circumventing the oil price cap or transporting stolen Ukrainian grain and cultural goods. 18 Dec 2025 - The EU Council sanctioned nine shadow-fleet enablers, shipping companies based in the UAE, Vietnam and Russia, that own or manage tankers already listed by the EU or other countries for shadow-fleet involvement and irregular shipping practices. 15 Dec 2025 - OFAC sanctioned 155 tankers in January 2025, the most extensive single shadow-fleet enforcement action to date; nearly 80 of the tankers linked by investigative journalists to Western (including Greek) sellers were among those designated. 10 Jan 2025 - The EU lowered the Russian crude oil price cap from $60 to $47.6 per barrel in July 2025, tightening the compliance threshold that Greek-flagged and Greek-owned tankers carrying Russian oil must observe to retain access to Western insurance, finance and shipping services. 1 Jul 2025 ### Regulatory horizon (register) - AMLR / 6AMLD national transposition application date for Greece - AMLR / 6AMLD national transposition application date for Greece - AMLR / 6AMLD application date - AMLD6 beneficial-ownership register-access national transposition (Greece) - 6AMLD beneficial-ownership register access provisions (Arts 11,12,13,15) - AMLA phased supervisory roll-out - AMLD6 transposition deadline / UBO access reform - GR omnibus servicer-supervision / crypto-tax / capital-markets bill - AMLR direct application across Greece as EU member state - 6AMLD transposition deadline for Greece - AMLA direct supervision perimeter reaches Greek high-risk entities - MiCA transitional period closure for Greek CASPs ### Active schemes - [CRITICAL] Greek tanker sales feeding the Russian shadow fleet - [HIGH] Golden Visa residency-by-investment laundering channel - [HIGH] Lazarus Group Bybit-hack proceeds transiting Greek crypto rails Sources - [MLex](https://www.mlex.com/mlex/financial-crime/articles/2485617/greece-luxembourg-sweden-face-eu-action-over-money-laundering-rules) - [Trending Topics](https://www.trendingtopics.eu/binance-faces-eu-ban-greek-regulator-reportedly-set-to-reject-mica-license/) - [Yahoo Finance (BeInCrypto)](https://finance.yahoo.com/markets/crypto/articles/binance-withdraws-mica-license-application-173752458.html) - [Zyphe](https://www.zyphe.com/resources/news/binance-mica-licence-eu-lockout-july-2026) - [Bank of Greece](https://www.bankofgreece.gr/en/main-tasks/supervision/prevention-of-money-laundering) - [Cryptonomist](https://en.cryptonomist.ch/2026/07/22/eu-sanctions-russia-crypto/) - [Chainalysis](https://www.chainalysis.com/blog/eu-21st-russia-sanctions-package-crypto-patforms-july-2026/) - [OffLine Post](https://www.offlinepost.gr/2026/08/03/dirty-money-clean-hands-inside-greeces-fight-against-money-laundering/) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Greece.html) - [https://www.bankofgreece.gr/en/main-tasks/supervision/prevention-of-money-laundering](https://www.bankofgreece.gr/en/main-tasks/supervision/prevention-of-money-laundering) - [https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/greece](https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/greece) - [https://www.fatf-gafi.org/en/countries/detail/Greece.html](https://www.fatf-gafi.org/en/countries/detail/Greece.html) - [https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [https://www.gamingcommission.gov.gr/index.php/en/](https://www.gamingcommission.gov.gr/index.php/en/) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofgreece.html) - [Euronews](https://www.euronews.com/my-europe/2026/07/23/eu-agrees-new-sanctions-against-russia-as-greece-secures-lng-exemption) - [Cointelegraph](https://cointelegraph.com/news/greece-first-mica-entrants-hcmc-binance-lagarde) - [KnowYourCountry](https://www.knowyourcountry.com/country-reports/greece/) - [FinancialRegulations.eu](https://financialregulations.eu/blog/eu-aml-package-amla-amlr-guide) - [https://www.fatf-gafi.org/en/calendars/assessments.html](https://www.fatf-gafi.org/en/calendars/assessments.html) - [https://www.comsuregroup.com/news/18-eu-states-miss-beneficial-ownership-access-deadline-aml-programmes-now-run-on-a-split-map/](https://www.comsuregroup.com/news/18-eu-states-miss-beneficial-ownership-access-deadline-aml-programmes-now-run-on-a-split-map/) - [https://en.cryptonomist.ch/2026/09/30/greek-mica-casp-entries/](https://en.cryptonomist.ch/2026/09/30/greek-mica-casp-entries/) - [https://bitcoinethereumnews.com/crypto/greek-mica-casp-entries-mark-new-crypto-regulatory-phase/](https://bitcoinethereumnews.com/crypto/greek-mica-casp-entries-mark-new-crypto-regulatory-phase/) - [https://euperspectives.eu/2026/07/eu-russia-sanctions-21-package-greece-compromise-lng-shipping/](https://euperspectives.eu/2026/07/eu-russia-sanctions-21-package-greece-compromise-lng-shipping/) - [https://home.treasury.gov/news/press-releases/sb0664](https://home.treasury.gov/news/press-releases/sb0664) - [https://www.fincen.gov/news/news-releases/operation-economic-outcast-targets-irans-shadow-fleet-networks](https://www.fincen.gov/news/news-releases/operation-economic-outcast-targets-irans-shadow-fleet-networks) - [https://www.sanctionscanner.com/aml-guide/anti-money-laundering-aml-in-greece-76](https://www.sanctionscanner.com/aml-guide/anti-money-laundering-aml-in-greece-76) - [Eversheds Sutherland](https://ezine.eversheds-sutherland.com/global-sanctions-guide/greece) - [Skadden](https://www.skadden.com/insights/publications/2024/09/eu-updates-sanctions-best-practices) - [Hellenic Anti-Money Laundering Authority](https://www.aml-authority.gov.gr/en/) - [NameScan](https://namescan.io/coverages/greece) - [Lawzana](https://lawzana.com/articles/greece/greek-register-of-beneficial-owners-compliance-guide-906) - [EY Global Tax News](https://globaltaxnews.ey.com/news/2019-6360-greece-enacts-provisions-for-registration-of-ultimate-beneficial-owners) - [Souriadakis Tsibris / Thomson Reuters](https://souriadakistsibris.gr/wp-content/uploads/2022/02/COUNTRY-UPDATE-Greece-AML.pdf) - [ELTE](https://elte.org.gr/wp-content/uploads/2021/03/N_4557_2018_English_Version.pdf) - [Independent Authority for Public Revenue](https://www.aade.gr/sites/default/files/2021-08/MER-Greece-2019.pdf) - [Scorechain](https://www.scorechain.com/blog/casp-greece) - [Bank of Greece](https://www.bankofgreece.gr/en/main-tasks/supervision/regulation-eu-2023_1114-on-markets-in-crypto-assets) - [Hellenic Capital Market Commission](http://www.hcmc.gr/aweb/files/Cryptos/files/Eng/Submitting_an_application_for%20_CASP_teliko_en.pdf) - [Crypto License Europe](https://crypto-license-europe.com/blog/mica-travel-rule-crypto/) - [Bank of Greece](https://www.bankofgreece.gr/RelatedDocuments/EXECUTIVE_COMMITTEE_ACT_172.pdf) - [HCMC](http://www.hcmc.gr/aweb/files/laundering/files/NEW%20AML-CFT%20Law%204557-2018_EN.pdf) - [European Commission](https://finance.ec.europa.eu/document/download/42e0d9f6-c2cc-4fe3-a08c-fbf223feea23_en?filename=amld-article-48-competent-authorities-greece_en.pdf&prefLang=bg) - [Lexology](https://www.lexology.com/library/detail.aspx?g=ed179735-c1bb-46c4-aded-f5a5cf6fe234) - [Athens News](https://en.rua.gr/2026/10/29/they-wanted-to-ban-even-e10-in-cash-the-greek-authorities-backed-down/) - [HCMC](http://www.hcmc.gr/en_US/web/portal/duties) - [Mondaq](https://www.mondaq.com/charges-mortgages-indemnities/66128/securities-finance-in-greece) - [ESMA](https://www.esma.europa.eu/sites/default/files/library/esma70-145-1020_-_list_of_thresholds_increased_pursuant_to_mar_article_199.pdf) - [Global Investigations Review](https://globalinvestigationsreview.com/review/the-european-middle-eastern-and-african-investigations-review-archived/2025/article/greece-fight-against-corruption-and-bribery-continues-key-amendments-fill-legislative-gaps) - [Global Law Experts](https://globallawexperts.com/what-is-the-register-of-beneficial-owners-in-greece/) - [NAVEX Global](https://www.navex.com/en-us/solutions/regulations/eu-whistleblower-directive/greece/) - [Kalaw](https://kalaw.gr/law-4990-2022-whistleblowing/) - [Sanction Scanner](https://www.sanctionscanner.com/aml-guide/anti-money-laundering-aml-in-greece-76) - [Greek Reporter](https://greekreporter.com/2026/05/27/greece-digital-platform-tax-evasion/) - [Cryptonomist](https://en.cryptonomist.ch/2026/09/30/greek-mica-casp-entries/) - [A&O Shearman](https://www.aoshearman.com/en/insights/amlctf-playbook-eu-edition-2-the-eu-antimoney-laundering-authority) - [AMLA](https://www.amla.europa.eu/faqs_en) - [Kyckr](https://kyckr.com/guides-and-reports/eu-ubo-register-access-for-obliged-entities) - [FATF](https://www.fatf-gafi.org/en/calendars/assessments.html) - [ComplyBridge](https://complybridge.xyz/regulators/bank-of-greece) - [HCMC](http://www.hcmc.gr/aweb/files/Annual_Reports/files/ANNUAL_REPORT_2024_EN.pdf) - [To Vima](https://www.tovima.com/finance/greek-gov-crackdown-on-unlicensed-investment-advisors/) - [Athens News (en.rua.gr)](https://en.rua.gr/2026/10/29/they-wanted-to-ban-even-e10-in-cash-the-greek-authorities-backed-down/) - [Capital.gr](https://www.capital.gr/politiki/4025980/katatethike-to-nomosxedio-gia-servicers-kai-prostasia-ofeileton-allages-se-idiotiko-xreos-crypto-kai-xrimatopistotiki-agora/) - [Ethnos.gr](https://www.ethnos.gr/Economy/article/425756/boylhkatatethhketonomosxediogiasynepeisofeiletesservicerskaiforologhshcrypto) - [IFC Review / step.org](https://www.ifcreview.com/news/2026/october/eu-eu-member-states-told-to-comply-with-6amld-beneficial-ownership-access-rules/) - [https://www.capital.gr/politiki/4025980/katatethike-to-nomosxedio-gia-servicers-kai-prostasia-ofeileton-allages-se-idiotiko-xreos-crypto-kai-xrimatopistotiki-agora/](https://www.capital.gr/politiki/4025980/katatethike-to-nomosxedio-gia-servicers-kai-prostasia-ofeileton-allages-se-idiotiko-xreos-crypto-kai-xrimatopistotiki-agora/) - [https://www.ethnos.gr/Economy/article/425756/boylhkatatethhketonomosxediogiasynepeisofeiletesservicerskaiforologhshcrypto](https://www.ethnos.gr/Economy/article/425756/boylhkatatethhketonomosxediogiasynepeisofeiletesservicerskaiforologhshcrypto) - [https://www.ifcreview.com/news/2026/october/eu-eu-member-states-told-to-comply-with-6amld-beneficial-ownership-access-rules/](https://www.ifcreview.com/news/2026/october/eu-eu-member-states-told-to-comply-with-6amld-beneficial-ownership-access-rules/) - 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[Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Universal-procedures.html) - [Greece's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-greece-2019.html) - [Mutual Evaluation of Greece](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofgreece.html) - [First-Ever Crypto Seizure in Greece](https://www.chainalysis.com/blog/greece-first-ever-crypto-seizure-bybit-hack-2025/) - [Research Reports Archive - Chainalysis](https://www.chainalysis.com/reports/) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Last Updated: 6/23/2026 FinCEN’s 314(a) Fact Sheet](https://www.fincen.gov/system/files/shared/314afactsheet.pdf) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Home](https://www.fatf-gafi.org/en/home.html) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Ships Keep Russia’s Shadow Fleet Afloat | OCCRP](https://www.occrp.org/en/investigation/european-ships-keep-russias-shadow-fleet-afloat) - [Russia's war of aggression against Ukraine: Council sanctions 41 vessels of the Russian shadow fleet - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/russia-s-war-of-aggression-against-ukraine-council-sanctions-41-vessels-of-the-russian-shadow-fleet/) - [Greek Shipowners Are Stampeding Out of the Russian Oil Trade - Bloomberg](https://www.bloomberg.com/news/articles/2024-02-05/greek-shipowners-are-stampeding-out-of-the-russian-oil-trade) - [Russia's war of aggression against Ukraine: Council sanctions 9 shadow fleet enablers - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/15/russia-s-war-of-aggression-against-ukraine-council-sanctions-9-shadow-fleet-enablers/) - [1 Red ALERT Shadow Fleet Sanctions Evasion and Avoidance Network](https://www.nationalcrimeagency.gov.uk/who-we-are/publications/753-red-alert-shadow-fleet-sanctions-evasion-and-avoidance-network/file) - [Updated Price Cap Coalition Advisory for the Maritime Oil ...](https://ofac.treasury.gov/media/933506/download?inline=) - [SANCTIONS ADVISORY - Guidance for Shipping and ...](https://ofac.treasury.gov/media/934236/download?inline=) - [Dark Fleet Seeking Russian Protection as US Seizes Oil Tankers - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-14/dark-fleet-seeking-russian-protection-as-us-seizes-oil-tankers) - [EU sanctions against Russia: questions and answers - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia-explained/) - [UK forces intercept Russian shadow fleet vessel for the first time in blow to Putin's war chest - GOV.UK](https://www.gov.uk/government/news/uk-forces-intercept-russian-shadow-fleet-vessel-for-the-first-time-in-blow-to-putins-war-chest) - [EU to Put Golden Visa Programs Under Scrutiny | OCCRP](https://www.occrp.org/en/news/eu-to-put-golden-visa-programs-under-scrutiny) - [Cypriot President Adamant: No Corruption in Golden Visa Scheme | OCCRP](https://www.occrp.org/en/news/cypriot-president-adamant-no-corruption-in-golden-visa-scheme) - [BlueLeaks: FBI Aware Large Investment Funds Enable Money Laundering | OCCRP](https://www.occrp.org/en/daily/12814-blueleaks-fbi-aware-large-investment-funds-enable-money-laundering) - [Golden Passports Make It Too Easy for Criminals, FATF Report Finds | OCCRP](https://www.occrp.org/en/news/golden-passports-make-it-too-easy-for-criminals-fatf-report-finds) - [Europe's Golden Doors: Lack of progress in stopping the criminal and corrupt accessing Europe via golden passports and visas | Global Witness](https://www.globalwitness.org/en/campaigns/corruption-and-money-laundering/europes-golden-doors/) - [EU Seeks `Golden Visa' Crackdown Amid Money-Laundering Fears - Bloomberg](https://www.bloomberg.com/news/articles/2019-01-23/eu-seeks-golden-visa-crackdown-after-money-laundering-scandals) - [Misuse of Citizenship and Residency by Investment Programmes](https://www.fatf-gafi.org/en/publications/Methodsandtrends/misuse-CBI-RBI-programmes.html) - [Football, Golden Visas Among “New” Money Laundering Risk Areas | OCCRP](https://www.occrp.org/en/news/football-golden-visas-among-new-money-laundering-risk-areas) - [Football, Golden Visas Among “New” Money Laundering Risk Areas](https://www.occrp.org/en/daily/10314-football-golden-visas-among-new-money-laundering-risks) - [Anti-money laundering and countering the financing of terrorism at EU level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en) - [Anti-money laundering directive V (AMLD V) - transposition status | European Commission](https://ec.europa.eu/info/publications/anti-money-laundering-directive-5-transposition-status_en) - [Transposition of directives - European Commission](https://ec.europa.eu/implementing-eu-law/transposition-directives/en) - [The European Commission calls on Greece to fully transpose the EAA - AccessibleEU](https://accessible-eu-centre.ec.europa.eu/content-corner/news/european-commission-calls-greece-fully-transpose-eaa-2025-03-19_en) - [Anti-money laundering and countering the financing of terrorism legislative package - Finance](https://finance.ec.europa.eu/publications/anti-money-laundering-and-countering-financing-terrorism-legislative-package_en) - [September 2019 Anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/media/fatf/documents/reports/mer4/MER-Greece-2019.pdf) - [Legislation and official policy documents - Eurydice network](https://eurydice.eacea.ec.europa.eu/eurypedia/greece/legislation-and-official-policy-documents) - [NIS2 Directive implementation in Greece | Shaping Europe’s digital future](https://digital-strategy.ec.europa.eu/en/policies/nis2-directive-greece) - [Country factsheet 2024: Greece - Migration and Home Affairs](https://home-affairs.ec.europa.eu/document/download/fa86c20b-e978-4083-b000-11f2bacf5202_en?filename=2024_EMN-ESTAT_EL_countryfactsheet.pdf) - [List of competent authorities under Article 48(1a) of AMLD](https://finance.ec.europa.eu/document/download/42e0d9f6-c2cc-4fe3-a08c-fbf223feea23_en?filename=amld-article-48-competent-authorities-greece_en.pdf&prefLang=bg) - [~· ~. . 0 I tf- 0 L(,. - PERMANENT MISSION OF GREECE TO THE UNITED NATION~ M L](https://www.un.org/en/ga/sixth/74/int_terrorism/greece_e.pdf) - [FinCEN Penalizes U.S. Bank National Association for Violations of Anti-Money Laundering Laws | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-penalizes-us-bank-national-association-violations-anti-money-laundering) - [Hellenic Bank | OCCRP](https://www.occrp.org/en/organizations/hellenic-bank) - [The Anti-Money Laundering Act of 2020 | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/anti-money-laundering-act-2020) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [Iran-related Designations; International Criminal Court-related Designations; Russia-related Designations Removals; Foreign Sanctions Evaders Determination Removal; Issuance of Iran-related and International Criminal Court-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251218) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Sanctions List Search Tool | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-search-tool) - [Sanctions Guidance for the Maritime Shipping Industry](https://ofac.treasury.gov/media/933556/download) - [OFAC Advisory to the Maritime Petroleum Shipping ...](https://ofac.treasury.gov/media/933191/download) - [Iran-related Designations; Publication of Updated Iran Shipping Advisory | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250416) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/More-on-high-risk-and-non-cooperative-jurisdictions.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - [Search page](https://www.fatf-gafi.org/en/search-page.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Greek Premier Reshuffles Government Amid EU Subsidy Scandal | OCCRP](https://www.occrp.org/en/news/greek-premier-reshuffles-government-amid-eu-subsidy-scandal) - [Greece: 37 Arrested in EU Farm Subsidy Scam Linked to Organized Crime | OCCRP](https://www.occrp.org/en/news/greece-37-arrested-in-eu-farm-subsidy-scam-linked-to-organized-crime) - [EU Probes €3M Fraud Scheme Tied to Greek Livestock Aid | OCCRP](https://www.occrp.org/en/news/eu-probes-eur3m-fraud-scheme-tied-to-greek-livestock-aid) - [Protecting EU institutions: OLAF investigations into EU funds misuse in Parliament feed into Paris verdict - European Anti-Fraud Office](https://anti-fraud.ec.europa.eu/media-corner/news/protecting-eu-institutions-olaf-investigations-eu-funds-misuse-parliament-feed-paris-verdict-2025-04-02_en) - [OLAF exposes fraud involving over €870 million - European Anti-Fraud Office](https://anti-fraud.ec.europa.eu/media-corner/news/olaf-exposes-fraud-involving-over-eu870-million-2025-06-16_en) - [Ex Prosecutor: Graft and Rule of Law Failures in Greece are an EU Problem](https://www.occrp.org/en/daily/16268-ex-prosecutor-graft-and-rule-of-law-failures-in-greece-are-an-eu-problem) - [Ex Prosecutor: Graft and Rule of Law Failures in Greece are an EU Problem | OCCRP](https://www.occrp.org/en/news/ex-prosecutor-graft-and-rule-of-law-failures-in-greece-are-an-eu-problem) - [Greek Premier Reshuffles Cabinet as Farm Aid Probe Intensifies - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-03/greek-premier-reshuffles-cabinet-as-farm-aid-probe-intensifies) - [Greek Scientist Accused of Embezzling EU Research Funds | OCCRP](https://www.occrp.org/en/news/greek-scientist-accused-of-embezzling-eu-research-funds) - [Greece’s Top Anti-Corruption Prosecutor Faces Removal | OCCRP](https://occrp.org/en/daily/13307-greece-s-top-anti-corruption-prosecutor-faces-removal) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [Frequently Asked Questions - Recently Updated | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/updated/2025-12-17) - [Russia-related Designations; Issuance of New and Amended Russia-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251022) - [817. What is the significance of OFAC's designations ...](https://ofac.treasury.gov/faqs/817) - [Beny Steinmetz Faces Extradition to Romania after Greek Ruling | OCCRP](https://www.occrp.org/en/news/beny-steinmetz-faces-extradition-to-romania-after-greek-ruling) - [Beny Steinmetz arrested in Greece Again | OCCRP](https://www.occrp.org/en/news/beny-steinmetz-arrested-in-greece-again) - [Greek Supreme Court Releases Israeli Billionaire Beny Steinmetz | OCCRP](https://www.occrp.org/en/news/greek-supreme-court-releases-israeli-billionaire-beny-steinmetz-blocking-extradition-order-to-romania) - [Beny Steinmetz Arrested in Greece | OCCRP](https://www.occrp.org/en/news/beny-steinmetz-arrested-in-greece) - [Swiss Court Upholds Bribery Conviction for Billionaire Beny Steinmetz | OCCRP](https://www.occrp.org/en/news/swiss-court-upholds-bribery-conviction-for-billionaire-beny-steinmetz) - [Cypriot Court Rules to Extradite Mining Magnate Beny Steinmetz to Romania | OCCRP](https://www.occrp.org/en/daily/18123-cypriot-court-rules-to-extradite-mining-magnate-beny-steinmetz-to-romania) - [Romania | OCCRP](https://www.occrp.org/en/regions/romania) - [EPPO Refers Ex-Ministers in Greek Farm Subsidy Fraud Case | OCCRP](https://www.occrp.org/en/news/eppo-refers-ex-ministers-in-greek-farm-subsidy-fraud-case) - [Beny Steinmetz: Scion of Diamond Royalty, Now At Bay Over Bribery Charges | OCCRP](https://www.occrp.org/en/project/the-steinmetz-scandals/beny-steinmetz-scion-of-diamond-royalty-now-at-bay-over-bribery-charges) - [Crypto-assets - Finance - European Commission](https://finance.ec.europa.eu/digital-finance/crypto-assets_en) - [Markets in Crypto-assets Regulation - Finance - European Commission](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/markets-crypto-assets-regulation_en) - [What the end of MiCA's transitional period means for crypto businesses](https://www.elliptic.co/blog/the-end-of-micas-transitional-period) - [What the First Quarter of MiCA Tells Us About CASP Authorizations | TRM Blog](https://www.trmlabs.com/resources/blog/what-the-first-quarter-of-mica-tells-us-about-casp-authorizations) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [MiCA's global reach: Why every crypto company needs a strategy](https://www.elliptic.co/blog/micas-global-reach-why-every-crypto-company-needs-a-strategy) - [What Is a VASP? Virtual Asset Service Provider - Chainalysis](https://www.chainalysis.com/glossary/virtual-asset-service-provider/) - [DAC8 - Taxation and Customs Union - European Commission](https://taxation-customs.ec.europa.eu/taxation/tax-transparency-cooperation/administrative-co-operation-and-mutual-assistance/directive-administrative-cooperation-dac/dac8_en) - [The MiCA Marathon: Are we reaching the finishing line? - Chainalysis](https://www.chainalysis.com/blog/the-mica-marathon/) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp) - [FATF (Financial Action Task Force) — Mutual Evaluation Report of Greece](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-greece-2019.html) - [European Commission (Directorate-General for Financial Stability, Financial Services and Capital Markets Union)](https://finance.ec.europa.eu/document/download/42e0d9f6-c2cc-4fe3-a08c-fbf223feea23_en?filename=amld-article-48-competent-authorities-greece_en.pdf) - [Council of the European Union](https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/russia-s-war-of-aggression-against-ukraine-council-sanctions-41-vessels-of-the-russian-shadow-fleet/) - [US Department of the Treasury, Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251022) - [OCCRP / Follow the Money](https://www.occrp.org/en/investigation/european-ships-keep-russias-shadow-fleet-afloat) - [Bloomberg](https://www.bloomberg.com/news/articles/2024-02-05/greek-shipowners-are-stampeding-out-of-the-russian-oil-trade) - [Chainalysis](https://www.chainalysis.com/blog/greece-first-ever-crypto-seizure-bybit-hack-2025/) - [OCCRP](https://www.occrp.org/en/news/greece-37-arrested-in-eu-farm-subsidy-scam-linked-to-organized-crime) Coverage gaps fim-int-2026-07-05-G001: Greece sixth AML Directive transpos… fim-int-2026-07-05-G001: Greece sixth AML Directive transposition vehicle and status against the European Commission member-state transposition monitor has not been independently established this cycle. [resolved] fim-int-2026-07-05-G002: FATF fifth-round mutual evaluation … fim-int-2026-07-05-G002: FATF fifth-round mutual evaluation on-site date for Greece has not been publicly scheduled or identified. [resolved] fim-int-2026-07-05-G003: No independent post-2019 FATF or IC… fim-int-2026-07-05-G003: No independent post-2019 FATF or ICIJ-style effectiveness assessment of the Greek beneficial-ownership register has been located. [resolved] fim-int-2026-07-05-G004: Precise USD valuation of the Bybit … fim-int-2026-07-05-G004: Precise USD valuation of the Bybit hack (reported between approximately 1.4 and 1.5 billion across sources) has not been reconciled to a single authoritative figure. [resolved] fim-int-2026-07-05-G005: A systemic, verified breakdown of i… fim-int-2026-07-05-G005: A systemic, verified breakdown of intermediary re-flagging jurisdictions in the Greek shadow-fleet resale chain (beyond Marshall Islands and UAE) has not been independently confirmed. [resolved] fim-int-2026-08-05-G001: No primary HCMC statement confirmin… fim-int-2026-08-05-G001: No primary HCMC statement confirming the rejection rationale for Binance's MiCA application was independently located this cycle. [resolved] fim-int-2026-08-05-G002: No independently located European C… fim-int-2026-08-05-G002: No independently located European Commission press release text for the 4 June 2026 AML infringement warning against Greece. [resolved] fim-int-2026-08-05-G003: No Greece-specific RegTech, AI-tran… fim-int-2026-08-05-G003: No Greece-specific RegTech, AI-transaction-monitoring, or perpetual-KYC development was located this cycle. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No Greece-specific 6AMLD/AMLR transposition draft text located this cycle; would upgrade the T2 tracker confidence. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 (beneficial ownership), D3 (enabler jurisdictions), D4 (conflict finance, not applicable in regime), and D6 (compliance technology) returned no Greece-linked material this cycle. [resolved] fim-int-2026-10-04-G001: D2, D3, D4, D6 were not actively re… fim-int-2026-10-04-G001: D2, D3, D4, D6 were not actively re-searched this cycle for Greece-specific developments; no material signal to report but genuine coverage gap exists. [resolved] fim-int-2026-10-04-G002: Tier D (KH/LA/MX/CO) watch jurisdic… fim-int-2026-10-04-G002: Tier D (KH/LA/MX/CO) watch jurisdictions were not re-searched this cycle. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): Full Council legal text for Greece's LNG sanctions carve-out has not been retrieved; current sourcing is T3 journalism only. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No T1 (Commission, ESMA, HCMC) primary source directly retrieved this cycle confirming the AMLD6 formal-notice step or the MiCA CASP register entries; both rest on T2/T3/T4 secondary reporting. [resolved] fim-int-2026-10-11-G002: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-10-11-G002: Tier D jurisdictions (KH, LA, MX, CO) were not actively searched this cycle; the pooled union budget was concentrated on the bound jurisdiction (GR). [resolved] fim-int-2026-10-25-G001: Greece's compliance status with the… fim-int-2026-10-25-G001: Greece's compliance status with the 6AMLD beneficial-ownership register-access transposition deadline (10 July 2026) could not be confirmed this cycle. [resolved] fim-int-2026-10-25-G002: No confirmation found of whether Gr… fim-int-2026-10-25-G002: No confirmation found of whether Greece is included in any AMLA direct-supervision selected-obliged-entity list. [resolved] fim-int-2026-11-02-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-02-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Sectoral sanctions (export/dual-use), nominee/bearer-share disclosure, financial-intelligence information-sharing gateways/production-order deadlines, periodic AML-audit/screening cycles, conflict-minerals/extractives transparency, and fraud/mule-account duties could not be pinned to a specific Greek provision within the research's search budget. [open] fim-int-2026-11-02-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-02-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): FATF has not yet assigned a confirmed onsite date for Greece's 5th-round mutual evaluation as of the research cutoff. [open] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): Exact article/provision number of the tabled omnibus bill's servicer-supervision and crypto-tax chapters not yet retrieved from hellenicparliament.gr or the Government Gazette. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1/D2/D4/D6 domains returned no GR-relevant dated signal this cycle; Tier-D watch (KH/LA/MX/CO) is structurally out of scope for a single-JID GR run. [open] fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D4'}): No GR-specific conflict-finance (D4) signal identified this cycle. [open] fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', 'value': 'D3'}): Exact article number of omnibus bill's claims-management-strategy reporting obligation not yet retrieved from a primary source. [open] FIM-GAP-001 (D1): Greece, alongside Cyprus and Malta, has ex… FIM-GAP-001 (D1): Greece, alongside Cyprus and Malta, has expressed concern over stricter EU sanctions enforcement measures against Russia's shadow fleet given its shipping industry's outsized economic weight, creating political resistance that slows upstream disruption of the tanker-resale pipeline feeding the shadow fleet. FIM-GAP-002 (D2): FATF's 2019 Mutual Evaluation Report found… FIM-GAP-002 (D2): FATF's 2019 Mutual Evaluation Report found that Greece needs to improve prosecution of money laundering as a standalone offence and found supervision of lawyers, tax advisors and other non-financial businesses inconsistent, including enforcement gaps in sanctioning entities that fail to implement required AML measures. FIM-GAP-003 (D3): Greece's former chief anti-corruption pros… FIM-GAP-003 (D3): Greece's former chief anti-corruption prosecutor was herself prosecuted after investigating the Novartis bribery scandal, with cases against politically connected officials implicated in the probe subsequently dropped despite evidence of large cash deposits; her office was also targeted for institutional restructuring. ## Evidence #### Confidence-tiered claims Greece secured an exemption inside the EU's 21st Russia sanctions package to continue shipping Russian LNG to non-EU clients. [[Source 1]](#sec-sources) Probable · 1 source Greece's first four MiCA CASP/ART-EMT entrants appeared on the ESMA register on 24 September 2026, closing a roughly 15-month gap in domestic MiCA authorisation. [[Source 1]](#sec-sources) Probable · 1 source Greece's AML/CTF regime operates under direct EEA/AMLR binding ahead of the 10 July 2027 AMLR full-application date; 2019 FATF MER rated Compliant on 15 and Largely Compliant on 22 of 40 Recommendations, no grey-list status. [[Source 1]](#sec-sources) Probable · 1 source Binance withdrew its Greek MiCA CASP application on 24 June 2026, six days before the HCMC's first Greek authorisation. [[Source 1]](#sec-sources) Uncertain · 1 source Transposition status of 6AMLD for Greece not established this cycle; direct AMLR binding is the confirmed standing picture. [[Source 1]](#sec-sources) Uncertain · 1 source Named among 18 EU Member States given formal notice over incomplete AMLD6 beneficial-ownership-access transposition (25 Sept 2026) [[Source 1]](#sec-sources) Probable · 1 source Four Greek entities (BCASH, Xenios Blockchain Group, Capital Wallet, Piraeus Bank) entered ESMA's MiCA register on 24 Sept 2026; Binance withdrew its Greek application on 24 June 2026 [[Source 1]](#sec-sources) Probable · 1 source OFAC designated the law firm Karnakis and Karnakis (Panama/Piraeus), five associated individuals, and Roxette Maritime Shipping and Trading S.A. (Piraeus) on 21 October 2026 under Operation Economic Outcast for facilitating Iran's shadow fleet [[Source 1]](#sec-sources) Probable · 1 source FinCEN issued its first administrative subpoena under BSA 31 U.S.C. 5318(k) against an unnamed Greek bank over potential ties to Iran and its proxies [[Source 1]](#sec-sources) Probable · 1 source EU Council adopted its largest-ever single Russia sanctions listings package on 12 October 2026 (826 entities, 743 individuals) via Implementing Regulation (EU) 2026/2281, directly applicable to Greek obliged entities [[Source 1]](#sec-sources) Probable · 1 source Greece is not on the FATF grey or black list; last FATF mutual evaluation was 2019 [[Source 1]](#sec-sources) Probable · 1 source Law 4557/2018 (transposing 4AMLD) is the foundation of Greece's AML system, as amended by Laws 4734/2020 and 4990/2022 [[Source 1]](#sec-sources) Probable · 1 source presidential decree / ministerial decision implementation [[Source 1]](#sec-sources) Probable · 1 source 50% aggregated ownership threshold [[Source 1]](#sec-sources) Probable · 1 source up to 5 years imprisonment [[Source 1]](#sec-sources) Probable · 1 source supervisory responsibility [[Source 1]](#sec-sources) Probable · 1 source three-unit structure under single President [[Source 1]](#sec-sources) Probable · 1 source 25% [[Source 1]](#sec-sources) Probable · 1 source 10000 [[Source 1]](#sec-sources) Probable · 1 source in_force [[Source 1]](#sec-sources) Probable · 1 source transposition_incomplete [[Source 1]](#sec-sources) Probable · 1 source not_scheduled [[Source 1]](#sec-sources) Uncertain · 1 source 1891050 [[Source 1]](#sec-sources) Probable · 1 source 4 [[Source 1]](#sec-sources) Probable · 1 source Omnibus bill tabled 26 Oct 2026, strengthening Bank of Greece supervisory/sanctioning toolkit over credit/claims servicers, including mandatory annual claims-management strategy filings. [[Source 1]](#sec-sources) Probable · 1 source 10% tax on crypto-asset capital gains, first EUR 500 annual gains exempt, tied to DAC8/CARF reporting [[Source 1]](#sec-sources) Probable · 1 source Omnibus bill strengthening Bank of Greece supervision/sanctions over credit and claims servicers, tabled 26 Oct 2026, Economic Affairs Committee first-stage review began 29 Oct 2026 [[Source 1]](#sec-sources) Probable · 1 source 10% tax on individuals' crypto-asset capital gains, EUR 500 annual exemption, tied to DAC8/CARF reporting [[Source 1]](#sec-sources) Probable · 1 source Law 4557/2018 (as amended by Laws 4734/2020 and 4990/2022), Bank of Greece and HCMC as supervisory authorities, Hellenic FIU as reporting recipient, bound directly by EU AMLR [[Source 1]](#sec-sources) Probable · 1 source