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Anti-Money Laundering (AML) Requirements in Greece

As a starting point, this section provides general information on AML requirements in Greece. However, to provide more accurate and detailed information, it’s essential to clarify certain points.

Clarification Points

Transaction Thresholds

• You mentioned that customer due diligence measures apply to transactions amounting to €15,000 or more. However, you also mentioned that transactions exceeding €1,000 as defined in article 3, point 9 of Regulation (EU) 2015/847 are subject to these measures.
  • To provide more context, please clarify which regulation applies.

Cryptocurrency-Related Businesses and Activities

• You asked about the types of cryptocurrency-related businesses and activities that are subject to AML requirements. Based on this assumption, it includes exchanges, wallet providers, and other businesses involved in buying and selling cryptocurrencies.
  • Is this a correct interpretation?

Non-Fungible Tokens (NFTs)

• You asked if NFTs are considered a type of property for AML purposes. To confirm, you meant to ask if NFTs are subject to the same regulations as other types of digital assets.
  • Please clarify.

Compliance Programs

Designated Businesses and Financial Institutions

• You mentioned that certain financial institutions or designated businesses are required to maintain compliance programs. Could you provide more information on which types of institutions and businesses are subject to these requirements?
  • Which specific regulations apply?

Reporting Requirements

Large Currency Transactions

• You asked about recordkeeping or reporting large currency transactions. To clarify, what types of transactions are considered “large” and when reports must be filed?
  • Please provide more context.

Routine Reporting of Transactions

• You also asked about routine reporting of transactions other than large cash transactions. Based on this assumption, it includes transactions that may not meet the thresholds for suspicious activity but still require reporting.
  • Is this a correct interpretation?

Cross-Border Transactions

• You inquired about cross-border transactions reporting requirements. Could you clarify which types of institutions are subject to these requirements and what must be reported?
  • Please provide more information.

Customer Identification and Due Diligence

Financial Institutions and Other Businesses Subject to AML Regulations

• You asked about customer identification and due diligence requirements for financial institutions and other businesses subject to AML regulations. Based on this assumption, it includes verifying the identity of clients, beneficial owners, and understanding their economic background.
  • Is this a correct interpretation?

Shell Banks

Prohibited Accounts

• You asked if financial institution accounts for foreign shell banks are prohibited. Could you provide more information on what constitutes a shell bank and which types of institutions are subject to these prohibitions?
  • Please clarify.

Suspicious Activity Reporting Criteria

Identifying Indicative Transactions

• Finally, you asked about the criteria for reporting suspicious activity. Based on this assumption, it includes identifying transactions that may be indicative of money laundering or terrorist financing.
  • Is this a correct interpretation?

To provide more accurate and detailed information, please clarify any of these points or provide additional context so we can better assist with your questions.