International Fraud & Asset Tracing 2024 Comparisons

A distinction should be drawn between criminal and civil fraud claims, under the provisions of the Greek Criminal Code (GCC) and the Greek Civil Code (GCivC), respectively.

Criminal Law

Fraud

Article 386 GCC describes the basic type of fraud, which is committed by knowingly representing untrue facts as true or by unlawfully concealing or suppressing true facts, and, in this way, persuading another person to act or omit to act, thus causing pecuniary damage. The intent of the perpetrator to gain illicit financial benefit for themself or a third party is required.

The GCC also provides for fraud variants, including:

• computer fraud (Article 386A), which is committed by abusing electronic data; and
• subsidies fraud (Article 386B), whereby the perpetrator illegally obtains or misuses public funds.

Fraud exceeding EUR120,000 is considered a felony under Greek criminal law and entails imprisonment of a maximum of ten years and a monetary penalty.

It is noteworthy that special criminal provisions might apply to certain types of fraud (eg, tax fraud, customs fraud, securities fraud).

Corruption

Offences involving corrupt payments include:

• bribery, active and passive, in the public sector (Articles 235 and 236 GCC), namely the act of giving/receiving or promising/accepting, directly or through third parties/intermediaries, undue benefits or gain to/from a public official for committing or omitting an act in the exercise of one’s duties or against one’s duties; and
• bribery, active and passive, in the private sector (Article 396 GCC), which is an act of giving/receiving unlawful benefits or gain, directly or indirectly, in exchange for an action or omission contrary to one’s duties (as defined by law, contract, agreement, etc).

Special rules apply regarding the bribery of judges (Article 237 GCC) and the bribery of political officials (Articles 159 and 159A GCC).

Breach of fiduciary duties

Τhe perpetrator of this offence (Article 390 GCC) is someone entrusted with the administration of another (natural or legal) person’s property and who intentionally causes financial losses to it, by not respecting the applicable diligent management rules.

Penalties to be imposed vary, depending on the total of damages caused, while the breach of fiduciary duties in respect of state-owned property constitutes an aggravating factor, involving even stricter penalties (imprisonment of up to 15 years).

False statements and declarations

According to Article 176 of Law 4548/2018, the founder, member of the board of directors or director of a company who knowingly makes false or misleading positive statements to the public, either concerning the coverage or payment of capital or for the purposes of subscription to securities issued by the company, is punished with imprisonment and a fine ranging from EUR10,000 to EUR100,000.

Conspiracy

Preparatory acts related to the subsequent commission of a crime (including fraud) are, as a rule, not punishable under Greek criminal law. Exceptionally, such acts are punishable only when related to certain serious offences (eg, the circulation of counterfeit currency).

Civil Law

Contractual liability

Anyone who has been deceived into making a declaration of intent has the right to request the annulment of said legal act and may also seek restitution for further damages incurred (Article 147 et seq GCivC).

Tort claims

The injured party is entitled to compensation, including for material and moral damage caused by the wrongful act, provided that deceit (as a criminal act) has taken place against their interests protected by law (Articles 914 et seq GCivC).

Alternatively, provisions for unjust enrichment (Articles 904 et seq GCivC) may also apply.

In the event that an agent has received a bribe, the following causes of action apply.

Criminal Law

The agent would face accusations of passive bribery, following the submission of a pertinent criminal complaint (by the principal) or an ex officio prosecution. Criminal liability for breach of fiduciary duties is also not excluded, depending on the specifics of the case.

Civil Law

The injured party (ie, principal/company) may file an action in tort against the perpetrator (Article 914 in combination with Article 932 GCivC) for pecuniary and non-pecuniary damages.

Civil liability of the perpetrator may be also sought on the basis of their pre-existing contractual obligations towards the principal/company.

Criminal Liability

Instigation and complicity

Anyone who instigates another person to commit a certain crime is punished as if they had directly perpetrated that offence (Article 46 GCC). Moreover, whoever assists the perpetrator, before or during the commission of a crime, is punishable with a reduced penalty, except if the accomplice directly assists the perpetrator, by placing the object of the offence at their disposal. In the latter case, the court may impose on the accomplice the same penalty as that on the perpetrator (Article 47 GCC).

Commission of separate offences

The further receipt of fraudulently obtained assets (ie, following the completion of the fraud by the perpetrator) is likely to raise criminal liability of the involved party (recipient), as follows.

• Acceptance and disposal of proceeds of crime (Article 394 GCC), which consists of the possession of objects (or the earned gains from such objects) that were acquired through criminal acts.
• (Anti-)money laundering legislation (Article 2 of Law 4557/2018), which prohibits the possession of property on condition that the recipient is aware that it was acquired through criminal acts. The notion of “criminal acts” includes certain offences (such as computer fraud and bribery), as well as any other crime, from which illicit financial proceeds originate.

Civil Liability

An action in tort may be directed against more than one defendant at the same time, provided that the damage to the claimant was caused by the joint acts of more persons (Article 926 GCivC). The same provision applies even if simultaneous or consecutive actions of more persons have taken place to the disadvantage of the claimant but it has not been determined which of these has actually caused the damage.

Criminal Law

According to Article 111 GCC, prosecution of criminal offences is time-barred, beginning from the day they occurred, as follows: 

• felonies punishable with life imprisonment have a statute of limitations of 20 years, with a possible extension of another five years during pending proceedings before a trial court;
• felonies punishable with up to 15 years of imprisonment have a statute of limitations of 15 years, with a possible extension of another five years during pending proceedings before a trial court; and
• misdemeanours have a statute of limitations of five years, with a possible extension of another three years, similar to above.

When it comes to certain financial crimes (eg, fraud, breach of fiduciary duties), the otherwise applicable statute of limitations (15 years) is extended to 20 years, on condition that the acts are directed against the property of the Greek State. Exceptional provisions as to the statute of limitations for certain criminal offences are also included in special criminal legislation.

Civil Law

As a rule, the right to file a civil action lapses after 20 years from the date that the pertinent claims were born and could be judicially pursued (Articles 249 and 252 GCivC).

However, if the wrongful civil act that gave rise to the respective claims constitutes, in parallel, a criminal offence, which is subject to a longer limitation period, preclusion of civil claims follows the latter statute of limitations (Article 937 GCivC).

For certain categories of civil claims, the applicable limitation period for their judicial pursuit is significantly shorter, namely five years, beginning from the date these were born (Article 250 GCivC).

A fraud victim may file an action in tort against the defendant with the competent civil court of first instance, seeking restitution for the loss or damage sustained (Article 914 et seq GCivC). Damages shall be awarded as compensation for the pecuniary harm caused by the defendant, possibly including loss of profits. It should be noted that moral damages could also be awarded in the form of compensation due to non-pecuniary harm as a result of the unlawful behaviour (please see also 1.2 Causes of Action After Receipt of a Bribe).

Under Greek insolvency proceedings, there are no established preferential rights of creditors who are victims of fraud.

Proceeds of Fraud

All assets deriving from the commission of fraud (predicate offence to money laundering), acquired directly or indirectly from the proceeds of such offence, or which constitute the means that were used or were going to be used in committing such offence, are subject to confiscation and forfeiture. Any legal act concerning confiscated property is prohibited and shall be considered as null and void (Articles 174–176 GCivC).

Proceeds of crime may be returned to the victims of fraud by a court decision; otherwise, they are considered property of the Greek State.

Civil Proceedings

There are no general preconditions for the claimant before taking judicial action in a fraud case. However, in practice it is rather common for an extrajudicial declaration to be sent to the opposing litigant, with a request for restitution of caused damages, prior to filing a lawsuit.

Criminal Proceedings

From a criminal law perspective, Article 405 GCC provides that no criminal sanctions are imposed if the perpetrator, of their own will, fully compensates the injured party, before being examined as a suspect or defendant, and without causing unlawful harm to a third party.

Effect of Interim Measures

The Greek Code of Civil Procedure (GCCivP) contains various provisions, allowing the plaintiff to apply – even before the commencement of ordinary proceedings – for an interim injunction or provisional order against the opposing party, in order to freeze movable or real estate assets (or rights in rem over such assets) as well as claims with respect to them (Articles 682 et seq, 707 et seq GCCivP).

The range of such injunctions is wide, so the competent court has the discretion to shape them in the most appropriate manner. The plaintiff needs to prove the urgent character of the requested measures, while injunctions that have been granted prior to the commencement of ordinary proceedings automatically cease to exist, unless an action is filed by the plaintiff within 30 days or within the timeframe instructed by the court.

Greek courts order the unsuccessful litigant to pay costs of the proceedings, which, as a rule, are of nominal value and cover a small part of the actual costs incurred by the winning party.

Non-compliance by the Defendant

Consequences of a defendant’s non-compliance with aforementioned court orders could include the imposition of a fine of up to EUR100,000 as well as their personal detention (Article 947 GCCivP).

Moreover, a person who tries to conceal, transfer, destroy, etc, their property in order to prevent the enforcement of a judgment could be held criminally liable by virtue of Article 397 GCC. According to said article, a debtor who intentionally frustrates, in whole or in part, the satisfaction of their debt by damaging, destroying, transferring without value, concealing or appropriating without equivalent and marketable collateral any of their property, or who creates false debits of false contracts, shall be punishable by imprisonment of up to two years or by pecuniary penalty.

Asset-Freezing in Criminal Proceedings

Depending on the specifics of the case (eg, banking fraud), a fraud victim could accompany their criminal complaint before the competent prosecutor with a request for asset-freezing against the defendant, on the basis of money-laundering legislation (Article 42 of Law 4557/2018).

Besides publicly accessible information (Land Registry, General Commercial Registry, etc), criminal law mechanisms are generally deemed effective in tracing a defendant’s assets.

Civil Proceedings

Disclosure is not a recognised or established procedure for the exchange of information between litigants in Greek civil proceedings. The general principle established in the GCCivP is that the court acts only upon request of the litigants and reaches its ruling based on the factual allegations and evidence submitted by each party. Consequently, litigants bear the burden of proving their own allegations and cannot be forced to disclose evidence in relation to the opposing party’s claims or face sanctions for not acting in such a manner.

Criminal Proceedings

Unlike the civil procedure, prosecuting and investigative authorities are not solely bound by evidence adduced by the litigants. Once the competent prosecutor has pressed charges and made referral of the case for main investigation, the investigating judge has extensive powers to gather evidence (including requests for production of evidence/information) in accordance with the provisions of the Greek Code of Criminal Procedure (hereinafter GCCP), the Constitution and relevant legislation.

It should be noted, however, that even during this stage of investigation, the fundamental rights of the defendant (such as the right to be presumed innocent and the right to avoid self-incrimination) remain intact.

Preservation of Evidence

In urgent and serious cases (eg, corruption, large-scale fraud and money laundering), it is not unusual for enforcement agencies and the prosecutor to take immediate action to secure evidence, by issuing a warrant for search and seizure or by issuing freezing orders, even before any charges are filed or involved persons are called for questioning. Preservation of evidence may also be achieved through confiscation (Articles 260 et seq GCCP).

Moreover, Article 245 paragraph 2 GCCP provides that, upon suspected commission of a crime, and given that there is an imminent threat of loss of evidence, the competent investigative officers are entitled to perform all necessary acts in order to determine the offence and its perpetrator, even without prior notice to the prosecutor.

New legislation was recently passed in Greece regarding the management of assets that have been frozen or seized as proceeds of criminal acts (Law 5042/2023). Such legislation, which mainly derives from relevant EU Directives, is aimed at preserving and utilising proceeds of criminal offences for public purposes, including redress for victims.

Civil Proceedings

A litigant may file an application with the court for the presentation of a specific document by the opposing party or a third party (Article 450 et seq GCCivP). The party filing the application for the presentation of the document should expressly specify, in its application, the document for which disclosure is sought. An order granting or dismissing the application is issued by the competent court.

Criminal Proceedings

Please see 2.1 Disclosure of Defendants’ Assets.

Rules of Evidence

Lawfully obtained evidence may constitute means of proof and may be used as such before Greek courts in civil and criminal proceedings. The evaluation of evidence is made freely by the court, but the final ruling needs to be sufficiently reasoned.

Provisional orders may be issued ex parte, even without the service of a notice to the opposing litigant (Article 691A paragraph 2 GCCivP). Please see also 1.7 Prevention of Defendants Dissipating or Secreting Assets.

Fraud Victim as a Party to Criminal Proceedings

The victim of a criminal offence (including a fraud victim) is entitled to acquire plaintiff status in criminal proceedings by making a declaration in support of the charges against the accused. Such a declaration can be submitted as a written statement during the pretrial stages or before the criminal court, until the beginning of the examination of evidence (ie, usually before the calling of the first witness). Articles 63–68 in conjunction with Articles 82–88 GCCP comprise the relevant legal framework.

Moreover, after issuing its judgment on the charges brought, the criminal court has the power to order the return of seized assets to the victim of fraud or other related offences. 

The participation of the (fraud) victim in criminal proceedings aims at the conviction of the accused, with no possibility of the filing of private claims for compensation that arise from the same wrongful act. Nonetheless, the victim may pursue civil claims before civil courts. 

Parallel Criminal and Civil Proceedings

When a civil lawsuit is intertwined with criminal claims, which are to be adjudicated by the competent criminal court, it is usual practice (though not mandatory) for the ruling of the civil court to be postponed until a final criminal judgment has been issued.

Occasionally, it is possible for the judgment of a civil or criminal court to be issued without the conduct of a full trial. More specifically, the following applies.

Dispute Resolution

Article 293 GCCivP, under the title “Procedure and Results of Conciliation”, stipulates those litigants who may, at any stage of the trial, reach a settlement provided under the applicable laws. The settlement is made by means of a declaration before the court or the surrogated judge, or before a notary public, and terminates the proceedings. The minutes of the conciliation constitute an enforceable title (Article 904 paragraph 2 GCCivP).

Plea Bargaining

The newly enacted Articles 303 et seq GCCP (by virtue of Law 4620/2019) introduced the possibility of plea bargaining in criminal proceedings. According to the relevant provisions, the defendant may, during the pretrial stages or until the beginning of the evidence hearing before the competent first-instance court, submit a request for plea bargaining in relation to the charges filed. The prosecutor has no right to sua sponte initiate such plea bargaining. 

In exchange for the defendant’s confession and acceptance of criminal charges, the prosecutor may propose a reduced penalty, as prescribed by law, after considering the nature and specifics of the case. If a final agreement is reached between the defendant and the prosecutor, the competent criminal court ratifies said agreement in a summary hearing.

Default Judgments

In civil proceedings, the absence of any of the litigants (who is not represented by a lawyer) has the following consequences.

• In the absence of the plaintiff, the filed action is automatically rejected (Article 272 GCCivP).
• In the absence of the defendant, who has been properly summoned, the court considers that the claims of the plaintiff are true (Article 271 GCCivP). If the defendant appears and accepts the content of the plaintiff’s action, the court issues a judgment according to said acceptance (Article 298 GCicC).

In criminal proceedings, the court may proceed with the adjudication of the case even in the absence of the defendant (who is not represented by a lawyer), provided the latter has been legally summoned and there are no other circumstances that could justify the postponement of the trial (Article 340 GCCP).

Whether in civil or criminal proceedings, pleading fraud requires a solid factual basis, accompanied by adequate evidence. More specifically, the following applies.

Pleading Fraud in Civil Proceedings

Article 216 GCCivP stipulates that a lawsuit must contain, inter alia, a clear statement of the facts which, in accordance with the law, justify such action and its submission by the plaintiff against the defendant. In practice, civil courts place considerable emphasis on this provision and often reject civil actions that are not detailed and precise.

Concerning proprietary claims (such as fraud claims), the monetary value of the object in question must be also specified.

Pleading Fraud in Criminal Proceedings

The existence of adequate evidence is a crucial prerequisite for the initiation and progress of standard criminal procedure. In this context, the prosecutor may dismiss vague criminal complaints or allegations that do not have a concrete legal basis (Article 43 GCCP).

Similarly, the judicial council handling a criminal case following the conduct of a main investigation may choose to not make a referral of said case to trial, if criminal charges are not corroborated by adequate evidence (Article 308 GCCP).

It is not possible to file a civil action against unknown litigants. According to Articles 118 and 216 GCCivP, a civil action should at least contain:

• the names and addresses of the litigants;
• the court to which the action is addressed; and
• the particulars of the claim.

On the contrary, a criminal complaint can be submitted even against unknown perpetrators. Further progress of the proceedings shall be suspended until the alleged perpetrators are identified.       

Please see 2.1 Disclosure of Defendants’ Assets and 2.3 Obtaining Disclosure of Documents and Evidence From Third Parties.

Civil Liability

A civil lawsuit against both the individual perpetrator and the legal entity (on behalf of which the defendant had acted) is in line with the relevant provisions on the jurisdiction of Greek courts (Articles 74 and 76 GCCivP in conjunction with Articles 334 and 922 GCivC). The sole adequate prerequisite for such an action is that the wrongful behaviour of the company’s director or officer occurred during the performance of their duties.

Criminal Liability

As a rule, only individuals can be held criminally liable under Greek law. In certain cases, corporate conduct may be sanctioned, especially in the context of anti-corruption, anti-money laundering and anti-cartel legislation, when it is linked with positive gains or advantages for the entity. The company is liable as an entity – notwithstanding the individual (criminal or administrative) liability of employees – when there is some type of profit, gain or advantage to the company. The severity of sanctions in such cases (in the form of administrative penalties and fines) usually depends on the type of profit or gain and on the annual turnover of the company.

Civil Law

According to established case law of Greek civil courts (including Judgment No 2/2013 of the Supreme Court of Greece, Areios Pagos, sitting in plenary session), the corporate veil of legal entities can be lifted, provided that the separate legal personality of a company (Article 70 GCivC) is essentially being abused, contrary to the pervading principle of good faith (Articles 281, 200 and 288 GCivC).

The above interpretation of the law applies (for example) in cases where a legal entity is being used as a vehicle for the facilitation of criminal or other wrongful acts, and consequently where the ultimate beneficial owners of the entity could face tort-based liability for wrongful actions.

Criminal Law

Regardless of whether the corporate veil of an entity would be lifted or not in civil proceedings, ultimate beneficial owners of a company could face criminal accusations, especially as instigators to an offence, in the event that the legal entity is involved in criminal activity.

Civil Claims

As a rule, claims on behalf of a société anonyme are judicially pursued by the board of directors and not by shareholders themselves (Article 77 of Law 4548/2018). If the board of directors does not proceed accordingly, a decision to bring claims against company directors may be made by the general assembly of shareholders.

In addition, Article 102 of Law 4548/2018 provides that members of the board of directors are liable towards the company for damages that have been caused due to an act or omission which constitutes a breach of their duties.

As a result, if fraudulent directors are, in parallel, members of the board of directors, the pertinent lawsuit may be filed as follows:

• following a request from majority shareholders to the board of directors, the filing of the above lawsuit (by the board of directors on behalf of the company) is mandatory (Article 104 paragraph 4 of Law 4548/2018);
• following a request from minority shareholders to the board of directors, if said request is rejected, minority shareholders may submit the same request before the competent court of first instance (Article 105 of Law 4548/2018); and
• following a decision of the general assembly of the company’s shareholders.

Criminal Claims

Fraudulent directors who harm the company’s and shareholders’ interests commit the crime of breach of fiduciary duties (please see also 1.1 General Characteristics of Fraud Claims). If caused damage exceeds EUR120,000, such offence shall be prosecuted ex officio. 

Jurisdiction and Judicial Assistance

Articles 1 et seq GCCivP and Articles 109 et seq GCCP determine the domestic jurisdiction of civil and criminal courts, respectively.

For cases with cross-border elements, there are two sets of applicable rules:

• in relation to EU member states and EU-based litigants, relevant EU Regulations apply (eg, EU Regulation 1393/2007, as amended by EU Regulation 1784/2020, regarding the service of documents); and
• in relation to third countries and non-EU-based litigants, judicial assistance is regulated by bilateral or multilateral international treaties (eg, the Hague Convention of 1965).

For practical reasons, European or international claimants who wish to acquire party status to Greek civil or criminal proceedings are advised to (also) appoint a lawyer based within the jurisdiction of the competent domestic court.

Extraterritorial Effect of Greek Criminal Laws

Apart from offences committed within national territory, Greek criminal law has an extraterritorial effect in the following cases:

• felonies or misdemeanours committed by nationals abroad, under the condition of dual criminality (Article 6 GCC – principle of active personality);
• felonies or misdemeanours committed abroad against nationals, state entities or other entities with their seat in Greece abroad, under the condition of dual criminality (Article 7 GCC – principle of passive personality); and
• certain offences prescribed in Article 8 GCC, regardless of the prerequisite of dual criminality according to the principle of universal jurisdiction (eg, terrorism, human trafficking, piracy, drug trafficking, etc).

Depending on the involved jurisdictions (eg, EU member states or third countries), different sets of rules may apply for such proceedings. Please see also 4.1 Joining Overseas Parties to Fraud Claims.

Enforcement of Civil Judgments

Final judgments of first-instance courts that have been issued as provisionally enforceable may be immediately enforced. A certified copy of the enforcement order, which is provided by the presiding judge of the court that issued the relevant judgment, is required in order to initiate the enforcement procedure (Articles 904 and 918 GCCivP). Once the order is served, enforcement actions may take place after three working days have passed (Article 926 GCCivP).

Enforcement actions include garnishment (confiscation) of the defendant’s assets and real estate property and/or auction of said assets and property.

Enforcement of Criminal Judgments

The enforcement of criminal judgments lies with the competent prosecuting authorities of the court that issued said judgment. As a rule, only final criminal judgments are enforceable (Article 545 GCCP). However, if a defendant has been convicted for a felony or even a serious misdemeanour, the first-instance court may rule that its judgment be directly enforced, notwithstanding the submission of an appeal against it (Article 497 GCCP).

Criminal Proceedings

The right to silence and to not incriminate oneself is enshrined in Article 104 GCCP. In accordance with this provision, the exercise of said right by the suspect or accused of a criminal offence shall not be interpreted as evidence of guilt; the exercise of said right does not preclude further collection of evidence by the investigative authorities.

The right to silence and to not incriminate oneself is reflected in a number of other provisions of the GCCP as well (eg, Article 273, which refers to the interrogation of the defendant).

Civil Proceedings

Although the defendant cannot be obliged to adduce evidence or disclose information (please see also 2.1 Disclosure of Defendants’ Assets), the right to silence does not apply to civil proceedings. If the defendant does not attend the trial to rebut the plaintiff’s claims, the latter’s allegations will be accepted as true (Article 271 GCCivP).

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The process of “discovery” or “disclosure” is not established under Greek civil law, though certain categories of privileged information, communications and documents are especially recognised throughout criminal proceedings.

Attorney-Client Privilege

Attorney-client privilege is well established within the Greek legal system and covers a broad range of data (eg, electronic correspondence, written memos, oral communications, etc) that is treated as confidential. Attorney-client privilege can be invoked in all types of procedures, whether criminal, administrative or civil, without making a distinction between natural and legal persons as to the identification of the client.

Sources of this privilege are to be found in:

• the Lawyers’ Code (Law 4194/2013);
• the Criminal Code (GCC);
• the Code of Criminal Procedure (GCCP); and
• the Code of Civil Procedure (GCCivP).

Professional Privilege

Except for lawyers, disclosure of privileged information may be denied by certain professionals, such as doctors, clerics, pharmacists, etc (Article 212 GCCP).

Moreover, pursuant to Articles 263 and 264 GCCP, seizure of privileged documents in the possession of the above-mentioned professionals is prohibited.

Undermining Privileges

In exceptional cases, prosecuting authorities may have broad powers for the collection of evidence and information, thus not being bound by professional privilege (eg, a financial crime prosecutor). Nonetheless, attorney-client privilege remains intact, as explicitly prescribed by law (Article 36 GCCP).

The attorney-client privilege can be undermined, either upon the voluntary decision of the client or where an attorney is individually involved in the commission of criminal acts.

There are no such provisions under Greek law.

Article 3 of Legislative Decree No 1059/1971 on Bank Secrecy, as amended by Act 1858/1989, stipulates that release of information on bank accounts is allowed, if it is necessary for the purposes of the investigation or punishment of a serious crime.

In order to release such information, an order by the competent judicial council at the request of the investigating judge (who carries out the main investigation) or of the prosecutor (who carries out the preliminary investigation or the summary investigation) is necessary. The same power is conferred to the court at the trial stage.

In accordance with EU Directives 2019/2177 and 2018/843, the notion of “property” (as defined by Article 3 of Anti-Money Laundering Law 4557/2018) has been amended (by virtue of the recent Law 4734/2020) to include “virtual currencies”.

More specifically, the above term refers to the digital representation of a value that is not issued by a central bank or public authority nor has their guarantee, and that is not necessarily linked to legally circulating currency nor has the legal status of currency or money, yet is accepted by natural or legal entities as a means of transaction and may be transferred, stored or circulated electronically.

Consequently, freezing orders or equivalent actions are, in principle, applicable to said types of assets, though the pertinent field awaits further regulation.