Financial Crime World

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Regulatory Requirements for Greek Credit Institutions

Greek credit institutions are subject to various regulatory requirements that cover aspects such as governance, remuneration, anti-money laundering (AML)/know-your-customer (KYC), and registration/oversight of senior management. Here’s a breakdown of these requirements.

Governance

  • The Board of Directors (BoD) must adopt a Code of Conduct and ensure that its members meet specific suitability requirements.
  • Senior managers, including key function holders, are subject to “fit and proper” assessment by the Bank of Greece/ European Central Bank (as applicable).
  • The BoD defines, oversees, and is accountable for the implementation of governance arrangements ensuring effective and prudent management of the credit institution.

Remuneration

  • Credit institutions must establish and apply remuneration policies that promote sound and effective risk management.
  • Staff whose professional activities have a material impact on the credit institution’s risk profile are subject to specific requirements, including a self-assessment by the credit institution each year.
  • Remuneration policies must set out the ratio between fixed and variable remuneration and be gender neutral.

AML/KYC

  • Greek credit institutions are subject to the AML/CFT legislation, which is in line with EU regulations.
  • Credit institutions must adopt AML policy and procedures, including customer due diligence, reporting, employee screening, record-keeping, internal control, and compliance management.
  • An MLRO (and deputy) must be appointed to oversee AML/KYC efforts.

Registration/Oversight of Senior Management

  • Members of the BoD and senior managers are proposed by the nomination committee and subject to “fit and proper” assessment.
  • The BoD defines, oversees, and is accountable for the implementation of governance arrangements ensuring effective and prudent management of the credit institution.

Conclusion

Overall, these regulatory requirements aim to ensure that Greek credit institutions operate in a safe and sound manner, with effective governance, remuneration practices, AML/KYC measures, and oversight of senior management.