Financial Crime 2026 Comparisons

There is no formal legal definition of economic crime; it broadly encompasses punishable acts with a financial dimension that go beyond ordinary property offences, as they are committed within, by, or against businesses and affect the economic system and development. The protected legal interest extends from individual property to broader goods such as economic order, the financial system, and the capital market. It is distinct from mere compliance violations and is closely linked to corruption – fostered by lack of transparency, concentration of power, and impunity – as well as organised crime, where financial gain constitutes a core element and economic offences (eg, market manipulation or insider trading) may be committed within criminal organisations. The constituent elements of a punishable economic offence are an unlawful act imputable to a specific individual (a natural person), committed either in its completed form or at the stage of attempt. Such offences are typically classified as intentional crimes and offences of result.

Under Greek law, the presumption of innocence is a fundamental principle, with any reasonable doubt operating in favour of the accused. Consequently, the burden of proof in financial crime proceedings rests with the prosecuting authority acting on behalf of the state.

The Greek legal order adheres to the principle of the free assessment of evidence, whereby courts are not bound by formal rules of evidence but are required to form their judicial conviction on the basis of an impartial and reasoned evaluation of the evidentiary material adduced.

As a rule, all forms of evidence are admissible, subject to specific exclusions (notably legal professional privilege and the confidentiality of communications). The principal evidentiary means include indicia, autopsy, expert evidence, the accused’s confession, witness testimony, and documentary evidence.

Offences of conspiracy are not, as such, codified under Greek criminal law. Secondary liability, however, is recognised in the form of participation in a criminal offence, depending on the manner and degree of contribution.

Pursuant to the general provisions of the Greek Penal Code (Articles 45–49), punishable forms of participation include: joint perpetration of an offence (co-perpetrators), instigation of the decision to commit an offence (moral instigator, including the provocateur), and direct or simple assistance to the principal offender in the commission of an offence (direct accomplice and accessory).

Financial crimes are subject to the general rules on limitation periods. Accordingly, for serious offences (felonies), the limitation period is twenty years, where the offence is punishable by life imprisonment, and 15 years in all other cases (save for offences directed against the financial interests of the State). For less serious offences (misdemeanours), the limitation period is five years. These limitation periods may be suspended where criminal prosecution cannot be initiated or continued, for up to five and three years respectively. As a general rule, the limitation period commences at the time the offence is committed. In the case of continuing offences, where the perpetrator’s acts were aimed at achieving an overall result, the limitation period runs from the date of the last individual act constituting the ongoing criminal conduct. Civil claims for monetary compensation arising from tort, as provided under the Civil Code, must be brought within five years from the time the act was committed (irrespective of any criminal liability) and are, in any event, subject to a long-stop limitation period of 20 years.

Under the Greek Criminal Code, jurisdiction primarily extends to offences committed within Greek territory, including those committed by foreign nationals, as well as on Greek vessels and aircraft (Article 5). Greek criminal law may also apply extraterritorially, subject to the principle of double criminality, in cases where offences are committed abroad by Greek nationals (Article 6) or by foreign nationals against Greek citizens (Article 7). In addition, foreign criminal judgments may be recognised (Article 11). Accordingly, financial crime laws can apply to conduct occurring outside Greece, particularly where there is a link to Greek nationality or interests. Such jurisdiction is, however, limited by the principle of ne bis in idem, precluding prosecution where a final judgment has already been rendered in another jurisdiction.

Greece provides for international co-operation in financial crime matters through both EU mechanisms and international agreements. Within the European Union, co-operation is primarily effected through the European Arrest Warrant, which enables simplified and expedited surrender procedures between member states, as well as instruments of mutual legal assistance and information-sharing (such as the European Investigation Order). In addition, co-operation is reinforced through institutions such as the European Public Prosecutor’s Office (EPPO), competent for offences affecting the EU’s financial interests, and agencies addressing organised crime, such as Europol. Beyond the EU, Greece participates in extradition and mutual legal assistance through bilateral and multilateral conventions, including the European Convention on Extradition, as well as agreements with third states (eg, the United States and Australia).

Police co-operation and information exchange are further facilitated through international organisations such as Interpol.

Under Greek law, extradition is governed by the Constitution, the Code of Criminal Procedure, and applicable international instruments. As a rule, the Greek Constitution prohibits the extradition of Greek nationals to non-EU countries. However, surrender of Greek citizens is permitted within the EU under the EAW framework, which provides a streamlined, judicially driven surrender procedure based on mutual recognition, with limited grounds for refusal, as well as in limited cases provided by international agreements. Extradition may be refused in cases of ne bis in idem, political offences, risk of fundamental rights violations, lapse of limitation periods, or lack of double criminality.

According to the Code of Criminal Procedure Criminal proceedings are initiated by the Public Prosecutor of the First Instance Court after receiving a notitia criminis and also have an active role in enforcement efforts. Prosecutorial authority ordering the investigating officers to conduct a preliminary examination to gather evidence, which will determine whether to prosecute or to dismiss the case.

For serious economic, tax, or related offences, insofar as they are committed against the Greek state, legal entities governed by public law, the European Union, or a foreign state, or seriously harm the national economy, as well as for felonies committed by Ministers or Members of the European Parliament in the exercise of their duties, or involving legal entities governed by private law that have received grants or funding, jurisdiction for conducting investigations, preliminary examinations, and prosecutions lies with the Department of the Public Prosecutor for Financial Crime (Articles 33–36, CCP).

The Financial Crime Prosecutor, bearing responsibility for the supervision and direction of investigations, either personally or by issuing orders to general or special investigative officers (such as the Financial and Economic Crime Unit, the Directorate of Financial Crime Investigations, and the Directorate of Economic Police) collects the evidentiary material which, depending on the degree of indications that arise, may subsequently lead to the initiation of prosecution against the perpetrator.

At the same time, for offences against the financial interests of the European Union (eg, fraud against the EU, subsidy-related fraud, and tax evasion), jurisdiction lies with the European Public Prosecutor’s Office. Other administrative, customs, police, or tax authorities have the duty and obligation to assist these prosecutorial authorities in the performance of their duties.

The initiation of an investigation into a financial offence may begin by any means or in any manner. Financial cases of greater significance for the public interest typically arise from intelligence and investigations conducted by regulatory authorities – ex officio – whereas less serious cases may be initiated by private criminal proceedings, where individuals submitting a criminal complaint to the prosecutor. The Head Prosecutor of the Financial Crime Department is informed of all complaints or information that come to the attention of the local Public Prosecutors’ Offices and enforcement services (see 2.1 Investigative and Enforcement Authorities) concerning offences within his jurisdiction. He evaluates and investigates this information, as well as any other relevant intelligence that comes to his knowledge by any means or method, prioritising those cases that seriously harm the interests of the Greek state and the European Union.

If the complaint, information, or report is not supported by law, or is manifestly unfounded in substance, or not amenable to judicial assessment, the Prosecutor may refrain from initiating prosecution and proceed to archive the case.

The Financial Crime Prosecutor is vested with extended powers, including the ability to order and carry out special investigative measures. Subject to the principle of proportionality, they may access any information or data necessary for the performance of their duties, without being bound by tax, banking, stock exchange, or other confidentiality rules. This access also extends to records held by public authorities processing personal data, in accordance with applicable traceability requirements. However, legal professional privilege is absolutely excluded from such access. Access to telecommunications data is permitted only under the specific conditions set by law, namely where it is necessary to establish the objective elements of a felony. Additionally, both the Financial Crime Prosecutor and the Independent Authority for Combating Money Laundering are vested with the power to order the freezing of assets. In particular, at the stage of the preliminary examination, they may, by means of a reasoned order, freeze bank accounts, the contents of safe deposit boxes, and assets in general (movable and immovable), for the purpose of safeguarding the interests of the state. The order does not need to specify any particular assets, is issued without prior hearing, and takes effect from the moment it is duly notified to the relevant authority or institution. The order may also be revoked or amended if new evidence arises, allowing the affected party or a third party to challenge it again on that basis.

Τhe Greek Code of Criminal Procedure does not expressly regulate the use of AI or other advanced digital technologies – such as predictive analytics, big data analysis, or blockchain tracing – authorities may nonetheless make use of such tools in practice. As a general principle, any evidence that has been lawfully obtained is admissible in criminal proceedings and may be relied upon by both investigative authorities and the parties. Within this framework, enforcement bodies and appointed experts are permitted to use modern technological tools in a supportive role, provided that their use is scientifically substantiated and does not infringe the procedural rights of those involved. In practice, Greek tax and anti-money laundering authorities already employ digital systems and analytical tools to detect and investigate offences such as tax evasion and money laundering. However, the use of technology is subject to legal constraints. General safeguards – such as data protection rules, fair trial guarantees, and the principle of proportionality – apply. More intrusive measures, particularly the interception of communications, are strictly regulated under Law 5002/2022: they require a reasoned judicial order, must relate to a limited list of serious felony offences, be supported by sufficient indications, and be justified by the absence of less intrusive means of obtaining the information. Such measures are authorised for a maximum period of two months and may be renewed, up to an overall maximum duration of ten months.

Internal investigations are not mandatory under Greek criminal law, but companies often use them to understand what has happened and to co-operate with the authorities. In this context, businesses may carry out internal audits by entrusting relevant data and information to independent financial auditors, in order to clarify the facts and ensure that responsibility is properly attributed.

Such internal reviews may also serve to assess and test the evidentiary findings of the authorities’ investigation or even operate as a means of rebuttal against the conclusions of official audit bodies (for example, the General Directorate of Financial Transaction Audits or other specialised financial and tax control units).

Their use is subject to legal limits. Data must be handled in accordance with Law 4624/2019 (implementing the GDPR). In employment law, employees generally have a duty to co-operate with their employer, including in internal investigations. However, this is balanced by fundamental criminal law protections, especially the right not to self-incriminate.

Companies are not obliged to share the results of internal investigations with the authorities. At the same time, authorities have strong investigative powers, such as questioning employees, carrying out searches, and seizing documents. However, they cannot, in principle, access material protected by legal professional privilege.

Voluntary disclosure or co-operation is not required by law, but it may be positively assessed either during the adjudication of the case or in determining the penalties imposed.

Under Greek criminal law, any offence committed in flagrante delicto – including financial crimes – may lead to arrest and immediate presentation before the authorities. In cases of non-flagrant offences, the Public Prosecutor orders a preliminary examination and, where sufficient indications arise, misdemeanours are referred for trial, while felonies lead to the initiation of a main investigation. A person accused of a felony is legally required to appear in person before the investigating judge to give a statement. Failure to do so may result in the issuance of an arrest warrant.

Both suspects and accused persons have the right to remain silent and the privilege against self-incrimination, as provided under the Code of Criminal Procedure (Article 104) and the European Convention on Human Rights (Article 6).

By contrast, witnesses are generally under a legal obligation to co-operate. They must appear when summoned, testify under oath and cannot refuse to testify or be represented by another person. Limited exceptions apply, notably in cases of professional privilege (eg, lawyers, doctors and clergy). If a duly summoned witness fails to appear without justification, a warrant for compulsory appearance may be issued and a financial penalty imposed. Continued refusal to appear or to testify without lawful grounds may lead to criminal liability for disobedience (Article 231, CCP). Furthermore, a witness who appears but refuses to testify or provides false testimony may be prosecuted for false testimony (Article 224, CCP).

Asset freezing constitutes one of the most commonly applied coercive investigative measures in the context of financial crime investigations. It is provided for both under the Code of Criminal Procedure and under special criminal legislation, as well as within the enhanced powers of the Financial Crime Prosecutor.

More specifically, in cases of tax evasion, corruption, and other financial offences, asset freezing may be imposed at the stage of the preliminary examination pursuant to Article 36(2), CCP, and at the investigation stage under Article 261, CCP. In relation to money laundering offences, freezing measures may also be ordered under Article 42(1) of Law 4557/2018 by the Anti-Money Laundering Authority, both during the preliminary examination and the investigation.

Given that this is a coercive procedural measure with significant impact on the suspect or accused, it must always comply with the principles of proportionality and sufficient evidentiary basis. Its imposition requires, in particular, a reasonable link between the person concerned and the alleged offence, clear identification of the affected person, and serious indications of guilt. The measure may extend to all types of assets, including bank accounts, the contents of safe deposit boxes, movable and immovable property, and generally any asset that may constitute proceeds or an instrument of the offence.

Asset freezing may also affect third parties, but only in connection with the main suspect or accused, and not independently. Where imposed during the investigation stage, it requires the prior consent of the Public Prosecutor and the issuance of a specifically reasoned judicial decision.

As regards duration, when ordered by the Financial Crime Prosecutor at the preliminary stage, the measure may last up to nine months, with the possibility of extension for a further nine months. The same time limits apply when the measure is imposed by an investigating judge or by the Anti-Money Laundering Authority. In any event, if no final criminal judgment is issued within five years, the freezing is automatically lifted.

The affected person has the right to challenge the measure, either by filing an appeal before the competent authority or by requesting its revocation or modification before the authority that imposed it.

The main punishable forms of fraud are codified in Articles 386–389 of the Greek Penal Code and include:

• the basic form of fraud, which also encompasses fraud before the courts as well as fraud directed against legal entities of the public sector (Article 386, PC);
• computer fraud (Article 386A, PC);
• fraud relating to subsidies (Article 386B, PC);
• petty fraud (Article 387, PC); and
• fraudulent causing of damage (Article 389, PC).

Additionally, specific acts of fraud are regulated and penalised under special laws, such as accounting fraud (Laws 5104/2024, 4548/2018 and 4254/2014) and fraud against the European Union (Law 4689/2020).

Fraud is committed where a person knowingly presents false facts as true or unlawfully conceals or suppresses true facts and, by such conduct, induces another person to act, omit to act, or tolerate a situation, thereby causing damage to property, with the intention of obtaining an unlawful financial benefit for themselves or for a third party.

These offences are generally classified as misdemeanours. However, in aggravated circumstances, they may be elevated to felonies. This classification often depends on the extent of damage caused to the victim’s property and other qualitative or quantitative criteria set by law.

In its basic form, fraud is punishable by imprisonment of up to five years. Where the damage caused is significant, the offence is punishable by imprisonment of at least three months (up to five years) and a monetary penalty. If the pecuniary damage exceeds EUR120,000, the penalty is imprisonment of up to ten years and a monetary penalty.

Where the fraud is committed directly against the Greek state, legal entities governed by public law, or local government authorities, and the damage exceeds EUR120,000, the offence is punishable by imprisonment ranging from ten to 20 years, in addition to a monetary penalty.

Bribery and corruption offences in Greece are primarily regulated by the Penal Code and cover both the public and private sectors, as well as specific categories of persons such as judicial and political officials and foreign public officials.

Public Sector

Bribery in the public sector is divided into passive and active bribery by a public official (235–236, PC). A public official is defined as a person who has been lawfully entrusted, even on a temporary basis, with the performance of duties of the state, municipal or local authorities, or other legal entities governed by public law. Passive bribery occurs where a public official requests or receives an undue advantage in exchange for an act or omission related to their duties, while active bribery occurs where a third party offers or provides such an advantage. These offences are punishable by severe penalties, including imprisonment ranging from one to twenty years and monetary fines, depending on the circumstances. The same framework applies to the bribery of foreign public officials.

Judicial and Political Officials

A particularly strict regime applies to the bribery of judicial (237, PC) and political officials (159–159A, PC). Both active and passive bribery in this context are punishable by imprisonment ranging from five to 20 years, along with monetary penalties, reflecting the importance of safeguarding the integrity of the judiciary and public administration.

Private Sector

Bribery in the private sector arises where an employee or agent requests or receives an undue advantage, or where a third party offers such an advantage, in exchange for an act or omission in breach of professional duties (396, PC). These offences are subject to less severe penalties compared to the public sector, typically involving imprisonment from one to five years and monetary fines.

Influence Peddling

The improper exercise of influence over public officials constitutes a separate offence (237A, PC). The relevant conduct of trading in influence involves requesting or receiving any kind of benefit, or accepting the promise of such a benefit, in exchange for the exercise of improper influence. Such influence is directed at public officials or political and judicial office holders (within the meaning of Articles 159A, 235 and 237 of the Penal Code), which the perpetrator claims or confirms – whether truthfully or falsely – that they are able to exert, in order to induce those persons to perform or omit an act in the exercise of their duties. It is punishable by imprisonment of up to five years and a monetary penalty, depending on the seriousness of the case.

Failure to Prevent

Greek law does not recognise a standalone criminal offence of “failure to prevent” bribery. However, legal entities may incur administrative liability where such offences are committed for their benefit due to a lack of supervision of people in managerial positions. Additionally, under the newly introduced provisions of Law 5090/2024, Greek law now provides for the imposition of sanctions by criminal courts on legal entities for offences of bribery and trading in influence. Such sanctions apply where these offences are committed for the benefit of the legal entity by individuals holding a leading position or where the commission of the offence was made possible due to a failure of supervision over subordinate employees.

Money laundering in Greece is primarily governed by Law 4557/2018, which has undergone significant amendments, most recently through its codification and modification by Laws 5193/2025 and 5259/2025. The principal money laundering offences include:

• the knowing conversion or transfer of assets derived from criminal activity with the purpose of concealing or disguising their illicit origin or assisting the perpetrator in evading legal consequences;
• the concealment or disguise of the true nature, source, location, disposition, movement or ownership of such assets;
• the acquisition, possession or use of property with knowledge of its criminal origin; and
• the use of the financial system, including the placement or transfer of proceeds, in order to give them the appearance of legitimate origin.

Money laundering is generally regarded as a derivative offence, as it involves the concealment or disguise of the illicit origin of proceeds, rather than constituting the primary criminal conduct itself.

Pursuant to Article 4 of the same law, predicate offences encompass both specifically listed offences and, more broadly, any criminal offence punishable by a custodial sentence of at least three months from which financial benefit is derived. Indicative examples include participation in a criminal organisation, bribery and corruption offences, fraud and embezzlement, tax evasion and customs offences, forgery, as well as financial and market-related crimes such as market manipulation and insider trading. No prior conviction for the predicate offence is required to establish a money laundering offence.

Sanctions vary depending on the seriousness of the predicate offence and the circumstances of the case, whether the underlying offence constitutes a felony or a misdemeanour. Penalties include imprisonment as well as monetary fines.

Law 4557/2018 also imposes anti-money laundering (AML) compliance obligations on a range of obliged entities, including credit and financial institutions, insurance undertakings and certain professionals such as lawyers and notaries. These obligations include, inter alia, customer due diligence procedures, risk assessment mechanisms, ongoing staff training, record-keeping requirements, internal controls, and systems for monitoring transactions to detect and report suspicious activity. The Hellenic Anti-Money Laundering Authority is responsible for collecting and assessing relevant information within its administrative competence and forwarding cases to the Public Prosecutor.

Failure to comply with AML obligations may result in administrative and, under certain conditions, criminal liability. Sanctions include administrative fines, suspension or revocation of licences, exclusion from certain activities, and potential criminal liability of natural persons, particularly in cases of intentional failure to report suspicious transactions. Supervisory authorities, such as the Bank of Greece and the Hellenic Capital Market Commission, exercise broad oversight and enforcement powers. In addition, companies listed on the Athens Stock Exchange are subject to corporate governance obligations under Law 4706/2020, including the establishment of internal control systems, risk management policies and whistle-blowing mechanisms.

Although there is no general requirement for all companies to implement a standardised compliance programme, in regulated sectors the absence of an adequate AML framework may lead to significant regulatory consequences.

In Greece, the regulation of so-called stock exchange offences – namely market abuse offences – is structured through a framework of European and national rules aimed at ensuring the proper functioning of regulated markets and, more broadly, capital markets. This framework includes rules governing financial instruments and their markets (MiFID I, MiFID II, MiFIR), as implemented into Greek law through specific statutes (notably Laws 3606/2007 and 4514/2018), as well as rules on the prevention of market abuse (MAD, MAR), with corresponding national implementation (Laws 3340/2005 and 4443/2016). At the same time, these rules are distinct from, yet operate alongside, company law, accounting law and capital markets law, which regulate corporate and financial activity more generally.

More specifically, Law 4443/2016 provides for the criminalisation of insider trading offences (Articles 28–29), namely the use of inside information by persons in possession of such information in order to carry out transactions in financial instruments within the market, thereby infringing the principle of equal access of investors to information. It also criminalises the unlawful disclosure of inside information (Article 30), that is, the disclosure of specific, non-public information relating directly or indirectly to issuers or financial instruments which could affect their price, as well as market manipulation (Article 31), including practices such as the dissemination of false information or the execution of transactions that result in artificial price levels, thereby undermining the proper functioning of supply and demand mechanisms.

For the purposes of the law, a person in possession of inside information includes:

• any person who holds such information by virtue of:
1. being a member of the administrative, management or supervisory bodies of the issuer or a participant in an emissions allowance market;
2. holding a participation in the capital of the issuer or being a participant in such a market;
3. having access to the information through their employment, profession or duties; or
4. engaging in criminal activity through which the information is obtained; and
• any person who has acquired inside information under circumstances other than those described above, where that person knows that the information constitutes inside information.

The above offences are prosecuted ex officio by the competent Public who may initiate a preliminary examination, a pre-investigation, or a main investigation in order to establish the commission of the offences, without the need for a complaint or request by any authority. In practice, the Hellenic Capital Market Commission typically submits a criminal report to the public prosecutor notifying the commission of any market abuse offence, as well as any related offence subject to ex officio prosecution.

These offences are generally classified as misdemeanours and are punishable by imprisonment. However, in cases involving significant value or habitual or professional commission, they may be elevated to felonies. For example, in cases of insider trading, a custodial sentence of up to ten years may be imposed where:

• the total value of the unlawful transactions exceeds EUR2 million;
• the average daily value of the unlawful transactions exceeds EUR250,000;
• the financial benefit obtained, loss avoided or damage caused exceeds EUR400,000; or
• the offence is committed on a professional or habitual basis and the financial benefit obtained, loss avoided or damage caused exceeds EUR150,000.

A tax offence, within the meaning of Article 79 of Law 5104/2024, consists of intentional tax evasion, including, inter alia, the concealment of income, provided that the tax evaded per year exceeds EUR100,000. In cases of intentional VAT evasion (eg, non-payment of VAT or fraudulent receipt of a VAT refund), the threshold is reduced to EUR50,000.

Under this framework, which targets serious instances of tax evasion and clarifies the conditions for establishing criminal liability, evasion of income tax constitutes a misdemeanour punishable by imprisonment of at least two years or a monetary penalty where the evaded tax exceeds EUR100,000 per tax year, and a felony punishable by custodial sentence where it exceeds EUR150,000. No criminal liability arises where the evaded tax does not exceed EUR100,000 per year. Accordingly, tax violations are criminalised only where specific monetary thresholds are met, depending on the type of tax and the relevant fiscal year.

The issuance and acceptance of forged or fictitious tax records constitute tax offences under Article 79(4), with penalties ranging from imprisonment of at least one year where their total value exceeds EUR75,000, to custodial sentences of up to ten years where it exceeds EUR200,000.

False entries or omissions in accounting books are subject to administrative fines under the Code of Tax Procedure. In addition, criminal liability may arise under Law 4548/2018 and Law 4738/2020 for inaccurate or misleading financial statements, including for board members who approve them and auditors who knowingly certify them.

Criminal sanctions also apply under insolvency law for failures relating to the keeping or integrity of accounting records, non-submission of statutory declarations, or concealment or destruction of business records, even were committed negligently. Administrative fines may be imposed on both legal and natural persons, whereas criminal liability attaches only to natural persons, in particular managers, directors and members of the administration responsible for the relevant acts.

Business compliance with tax obligations and bookkeeping requirements is monitored both preventively and repressively by the Independent Authority for Public Revenue (AADE) and its specialised units. These include local tax offices (DOY – Public Financial Services), audit centres such as KE.ME.EP. (Audit Centre for Large Enterprises) and KE.FO.ME.P. (Audit Centre for High-Wealth Individuals), as well as dedicated control services responsible for targeted and on-site inspections. Additionally, customs authorities of the AADE oversee compliance in relation to indirect taxation and the movement of goods. In parallel, especially in larger corporations, voluntary internal audits and compliance mechanisms are implemented to ensure adherence to lawful accounting procedures and to prevent irregularities within the corporate hierarchical structure.

In Greece, cartel and competition law offences are primarily governed by Law 3959/2011 on the protection of free competition, which is closely aligned with EU antitrust rules and provides for both administrative and criminal liability.

Anti-competitive conduct – such as participation in cartels (including price-fixing, market-sharing or output-restriction agreements) and the abuse of a dominant market position – may trigger significant administrative sanctions, most notably substantial fines imposed by the Hellenic Competition Commission. In parallel, pursuant to Article 44 of Law 3959/2011, intentional infringements of competition law may also constitute criminal offences, punishable by imprisonment and/or monetary penalties of up to EUR1 million. The Hellenic Competition Commission co-operates with the competent judicial authorities in the investigation and prosecution of such conduct.

In addition, Law 146/1914 on unfair competition establishes further offences relating to breaches of fair trading practices, including the dissemination of misleading or disparaging information about a competitor and the unlawful disclosure or exploitation of trade secrets.

From a broader regulatory perspective, Law 2251/1994 on consumer protection provides for administrative sanctions, primarily in the form of fines, for violations of consumer law. While these are generally regulatory in nature, criminal liability may arise where harmful products result in death or bodily injury, in which case the relevant provisions of the Greek Penal Code on offences against life and physical integrity may apply.

Overall, the Greek legal framework adopts a dual enforcement model, combining administrative enforcement by independent authorities with criminal sanctions in more serious or intentional cases.

In Greek law, intellectual property is primarily protected by Law 2121/1993. The protected legal interest is intellectual property in the broad sense of ownership over intangible goods, namely original works, as well as subject matter protected by related rights or rights of a special nature. Article 66 of this law establishes the framework of criminal sanctions for the infringement of intellectual property and related rights, providing that any person who, without authorisation and in violation of the law, reproduces, records, distributes, rents, publicly performs, transmits, or generally exploits works or copies thereof, as well as infringes the moral rights of the author, shall be punished by imprisonment of at least one year and a monetary fine. The same penalties apply to unlawful acts directed against the related rights of performers, producers, and broadcasting organisations. More severe penalties are provided in cases involving particularly significant damage or unlawful gain, as well as where the acts are committed professionally or on a commercial scale, in which case imprisonment of up to ten years and a substantial monetary fine may be imposed, along with administrative measures such as the revocation of the operating licence of the business concerned. Furthermore, unlawful access to audiovisual content is criminalised even when carried out for private use, as is the use or distribution of means intended to circumvent technological protection measures, while similar sanctions are provided for infringements relating to databases. Finally, in certain cases, the criminal liability may be extinguished through the payment of an administrative fine, without, however, eliminating the obligation to compensate the right holders.

In the Greek legal order, environmental pollution constitutes criminal, administrative, and civil wrongdoing, whereas so-called greenwashing does not amount to an autonomous criminal offence, but is primarily addressed under consumer protection law as a misleading commercial practice. Environmental pollution is chiefly governed by Law 1650/1986, as amended by Law 4042/2012 in alignment with EU environmental criminal law, providing for criminal sanctions (including imprisonment as well as monetary fines), administrative measures (such as fines and the suspension or revocation of operating licences), and civil liability for the restoration of environmental damage or degradation. Indicative criminal offences include operating without the requisite licence, unlawful emissions or discharges into air, soil, or water, improper waste management, the operation of hazardous installations, and offences against protected wildlife. Legal entities incur administrative liability for offences committed for their benefit by persons in leading positions or due to lack of supervision, while natural persons are subject to criminal penalties. By contrast, greenwashing falls within the scope of Law 2251/1994 and EU rules on unfair commercial practices, attracting primarily administrative sanctions, cease-and-desist orders, and civil claims, and only exceptionally giving rise to criminal liability (eg, fraud). The supervision and enforcement of the relevant framework are exercised by competent administrative authorities, including the Ministry of Environment and Energy and environmental inspectorates in relation to pollution, as well as the General Secretariat for Consumer Protection and the Consumer Ombudsman in relation to greenwashing, while serious infringements may also give rise to criminal proceedings before the competent courts.

According to the Greek Code of Criminal Procedure, criminal proceedings are initiated by order of the Public Prosecutor once they receive any information indicating that a criminal offence has been committed.

For certain misdemeanours – typically financial offences below EUR120,000 committed against a private individual – the filing of a criminal complaint by the injured party is required (within three months from the time they became aware of both the offence and the perpetrator) in order to initiate criminal proceedings.

Following a report or complaint, the Public Prosecutor orders a preliminary examination in order to collect evidence, gather documents and witness statements and obtain explanations from the suspect(s). In cases of flagrante delicto or other urgent circumstances, evidence may be collected by the police without prior prosecutorial order.

Pursuant to Article 43 of the Code of Criminal Procedure, the decision to initiate criminal prosecution lies with the Public Prosecutor. If the evidence collected is insufficient, or if the complaint is unfounded, not supported by law, or not amenable to judicial assessment, the case is dismissed and placed in the archive.

Prosecution and criminal penalties may be imposed only on natural persons and not on legal entities (in line with the Roman law principle societas delinquere non potest). Criminal liability is inherently linked to individual responsibility and is not recognised for legal persons or entities, whether or not they have legal personality, as this would raise significant doctrinal and constitutional issues.

However, very recently, following pressure from international organisations active in combating financial crime and corruption (such as the G20 High-Level Principles on the Liability of Legal Persons for Corruption – and the OECD Anti-Bribery Convention), Articles 134 and 135 of Law 5090/2024 were introduced into Greek criminal system.

These provisions concern management and service-related offences (in particular, bribery of public officials or judges, as well as active trading in influence) and, for the first time, provide for sanctions against legal persons within the context of criminal proceedings.

This development does not amount to the full recognition of criminal liability of legal entities. Nevertheless, it constitutes a significant innovation in Greek criminal law, which, until now, provided only for administrative sanctions against companies.

Financial crime cases, particularly those involving serious offences against the public interest (such as offences against the Greek state or the European Union, or involving public officials), are in principle required to be handled expeditiously. To this end, in addition to the Financial Crime Prosecutor’s Office, a Special Investigating Judge (under Law 4022/2011) has been established for serious felonies of major public interest. This judge, assisted by other investigators, experts, public officials, and the Anti-Money Laundering Authority, is tasked with conducting the investigation with priority and without delay, inter alia, to avoid the risk of limitation periods expiring.

In practice, however, financial crime cases often take longer to complete than other types of offences. This is mainly due to the large volume of case files, the complexity of financial, technical, and legal issues involved, the frequent need for expert reports, and the examination of specialised witnesses.

As regards pre-trial detention, under the Code of Criminal Procedure it may be imposed during the pre-trial stage where there are serious indications of guilt, and only if less restrictive measures – such as electronic monitoring, reporting obligations, or travel bans – are considered insufficient. It is primarily imposed in felony cases, particularly where there is a risk of absconding or reoffending, assessed on the basis of specific criteria (eg, lack of a known residence, prior conduct, or preparatory acts indicating flight risk).

Pre-trial detention may also be ordered where the alleged offence carries severe penalties (including long-term or life imprisonment), has been committed repeatedly, within a criminal or terrorist organisation, or involves a large number of victims, and where there is a justified risk of further offending. The seriousness of the offence alone is not sufficient to justify detention.

In any case, pre-trial detention may not exceed 12 months for the same offence, and only in exceptional circumstances, particularly for the most serious felonies – may it be extended up to a maximum of 18 months, within which time the case must be brought to trial.

In financial crime cases of a felony nature, the severity of the potential penalties allows for the imposition of pre-trial detention. However, in “white-collar” cases, due to the profile of the defendants (typically established individuals, non-recidivists, with stable residence), investigative authorities more commonly impose restrictive conditions or bail as sufficient measures to secure their appearance before the judicial authorities.

Αppointment of a defence lawyer by the state, also known as Legal Aid, in criminal, civil, and administrative proceedings in Greece is governed by Law 3226/2004.

In criminal matters – particularly given the importance of personal liberty – legal aid operates as a key safeguard of the right to legal protection, a fair trial, and the presumption of innocence. It applies across all offences, depending on their classification (felonies or misdemeanours).

In felony cases, legal aid is provided automatically and without any means test. The state appoints a defence lawyer ex officio (unless the defendant expressly refuses), regardless of the defendant’s financial situation, and no contribution is required from the accused.

For less serious offences (misdemeanours), legal aid is subject to financial eligibility criteria. It is available to individuals with low income (Greek citizens, EU nationals, and third-country nationals lawfully residing in Greece), upon application, provided that the offence carries a potential custodial sentence (typically of at least six months or one year). The application is submitted to the court and must be supported by relevant documentation such as tax returns and income statements. Legal aid may also be granted in urgent “flagrante delicto” cases.

The defence lawyer is appointed randomly from a list maintained by the local Bar Association, and their fees are covered by a special fund of the Ministry of Justice.

The subject-matter and territorial jurisdiction of criminal courts under Greek criminal law is determined by the provisions of the Code of Criminal Procedure (Articles 109–115). The allocation of jurisdiction is defined by the classification of the act by the Penal Code as a felony or a misdemeanour, based on the factual circumstances contained in the referring decision or the prosecutor’s summons.

Thus, apart from the Mixed Jury Courts, which primarily adjudicate offences against life or sexual freedom, the remaining offences are allocated by law to the single-member and three-member misdemeanour courts and courts of felonies. The main financial offences, relating to property, assets, currency or means of payment – such as fraud, breach of trust, forgery, counterfeiting, bribery and money laundering – are adjudicated by three-member courts. Appeals against decisions are heard by higher courts as provided by law (eg, decisions of the three-member misdemeanour court are heard by the three-member court of appeal).

Territorial jurisdiction is determined by the place where the offence was committed. Among multiple competent courts or investigating authorities acting in parallel, preference is given to those of the place where the offence was committed. If that place is unknown, preference is given to those who first summoned or ordered the arrest or pre-trial detention of the accused.

These provisions are of mandatory law, and the suspect or accused cannot derogate from them, except where any objection of lack of jurisdiction is based on law, in which the case is referred to the appropriate court. Likewise, no choice between lower or higher courts is left to the accused, who may only, if they consider that the lower court has wrongly assessed the evidence, lodge an appeal and bring the case before a second-instance court, or, if that decision contains legal errors or insufficient reasoning, file a cassation before the Supreme Court (Areios Pagos).

Financial crimes are adjudicated exclusively by professional judges, as the law mandatorily assigns jurisdiction over such offences to judicial panels without the participation of juries. Cases involving financial or administrative matters require specialised technical and legal expertise developed through extensive legal training and practice. Accordingly, white collar crimes are excluded from the jurisdiction of mixed juries due to their complexity for non-professional jurors, and this allocation of jurisdiction is binding by law, precluding any objection by the suspect.

In the Greek legal order, criminal liability is, in principle, attributed only to natural persons and is centred on the responsibility of the company’s legal representatives. Accordingly, unlawful acts or omissions committed for the benefit of a legal entity by persons holding a leading position and powers of representation (eg, members of the board of directors), or resulting from a failure of supervision over subordinates, give rise to criminal liability of the natural persons involved. Within corporate groups, liability is attributed to the representatives of the directly involved entity, while prosecution may extend to individuals of parent or affiliated companies where knowledge or participation (eg, aiding and abetting or instigation) is established. For most offences, liability of legal persons remains primarily administrative and may be imposed independently of any criminal conviction. However, in cases of bribery and trading in influence, Law 5090/2024 (Section 4.1) introduces a hybrid liability model, allowing for the parallel prosecution and sanctioning of both natural and legal persons. Sanctions imposed on legal entities may also be enforced against successor entities, whether universal or special, up to the value of the transferred assets, while proceedings may be conducted autonomously, even where the perpetrator remains unidentified.

In the Greek legal order, there is no general obligation requiring all companies to maintain standardised compliance programs for the prevention of financial crime; however, specific legislative frameworks indirectly mandate the adoption of such mechanisms. In particular, under the legislation on the prevention of money laundering (Law 4557/2018), obliged entities are required to implement adequate compliance programmes, including customer due diligence procedures, risk assessments, ongoing staff training, internal controls, record-keeping, and mechanisms for monitoring and reporting suspicious transactions. Furthermore, especially in the case of listed companies, Law 4706/2020 on corporate governance requires the establishment of internal control systems, risk management policies, codes of conduct, and whistle-blowing procedures, while Law 4990/2022 introduces mandatory internal reporting channels for certain entities.

Although the existence of an effective compliance programme does not constitute a standalone defence to criminal liability, it may operate as a mitigating factor for the accused, particularly where it is demonstrated that the individual contributed to the adoption of reasonable preventive measures by the company and co-operated with the authorities. In this context, sincere remorse, restitution of damage, and active contribution to the investigation, in accordance with Articles 84 and 85 of the Greek Penal Code (mitigating circumstances) may lead to a reduction of the penalty.

In the Greek legal order, financial crime offences are governed by the general provisions of the Penal Code concerning the exclusion of unlawfulness and culpability, such as lack of intent and factual or legal error. Furthermore, the defendant benefits from the fundamental principle of in dubio pro reo, according to which any doubt as to guilt must be resolved in their favour, while a conviction requires proof beyond reasonable doubt. Common defence arguments, particularly in financial crimes (eg, breach of trust, fraud), relate to the non-fulfilment of the objective elements of the offence and the absence of punishability due to failure to establish definite and actual damage or intent to obtain unlawful financial gain.

As regards evidence, the Greek procedural system follows the principle of free evaluation of evidence, accepting all lawfully obtained means of proof (such as witness testimony, documents, expert reports and confessions) without predetermined evidentiary value. In addition, mitigating circumstances are provided for, in particular sincere remorse, restitution of damage and co-operation with the authorities, in accordance with Articles 84 and 85 of the Penal Code, which may lead to a reduction of the sentence..

With regard to de minimis thresholds, in certain financial offences – particularly tax-related offences – criminal liability depends on the exceeding of specific monetary thresholds, whereas in lower-value cases only administrative sanctions are imposed. Moreover, for the classification of certain offences as felonies (eg, fraud or embezzlement against the Greek state), the damage must exceed the amount of EUR120,000. There is no general “safe harbour” regime; however, specific provisions provide for favourable treatment, especially in cases of voluntary disclosure or co-operation with the authorities. Greek law provides for consensual mechanisms for the resolution of criminal cases, such as criminal conciliation and plea bargaining (Articles 301–303 of the Code of Criminal Procedure), which, under certain conditions, allow for the acceleration of proceedings and the reduction of penalties following a confession and agreement with the prosecuting authority or compensation of the victim.

In cases involving bribery of public officials, political figures or members of the judiciary, as well as trading in influence and related offences, a person may be granted whistle-blower (public interest witness) status, provided that they are not involved in the offence and do not seek any personal benefit. This status is granted by financial crime prosecutors, with the approval of the Head Prosecutor, where the individual provides information that significantly contributes to the detection and prosecution of the offence.

The law provides protective measures for such whistle-blowers, including confidentiality and, in some cases, immunity from prosecution, in order to encourage reporting without fear of retaliation. Safeguards may include the use of pseudonyms in written statements or giving testimony remotely with voice distortion.

In addition, the law (Article 263A of the Penal Code) provides for lenient treatment of offenders or accomplices who assist the authorities by revealing the offence and identifying other participants, including reduced sentences and possible suspension of their execution.

Anonymous reports are also possible; however, their credibility is assessed by the competent authorities through investigation and the collection of supporting evidence.

In the Greek legal order, financial crime cases are primarily resolved through prosecution and the ordinary criminal procedure. However, in recent years, following the introduction of the new Penal Code in 2019, consensual resolution mechanisms inspired by Anglo-Saxon legal systems have been introduced with the aim of expediting the administration of justice. In particular, criminal conciliation (Articles 301–302 of the Code of Criminal Procedure) allows the defendant, under certain conditions and especially in non-violent financial offences (eg, forgery, embezzlement, tax offences), to reach an agreement with the victim prior to the completion of the investigative stage, leading to a reduced sentence imposed by the court.

In parallel, criminal negotiation (Article 303 of the Code of Criminal Procedure) may be initiated upon request of the defendant or at the initiative of the prosecutor at any stage prior to the commencement of the evidentiary proceedings before the trial court, in exchange for a confession and a reduced sentence. The relevant agreement is drawn up in writing and must be ratified by the court. If no agreement is reached, the criminal proceedings continue from the stage at which they were interrupted, and any written request by the defendant or invitation by the prosecutor is destroyed and cannot be used against the defendant.

Nevertheless, these alternative mechanisms have not been widely applied in practice and are more commonly used in cases involving narcotics or migrant smuggling. Accordingly, the Greek system combines traditional prosecution with alternative resolution mechanisms, which, however, remain of limited practical relevance in the field of financial crime.

In the Greek legal order, natural persons may be subject, either cumulatively or alternatively, to imprisonment and monetary penalties. Confiscation has also been expanded as a key measure to deprive offenders of unlawful proceeds. Moreover, in the case of foreign nationals, administrative deportation may be ordered under the applicable immigration framework as a supplementary measure.

In determining the appropriate sentence, courts apply Article 79 of the Penal Code, taking into account objective and subjective factors such as the damage caused, the nature of the offence, the degree of intent or negligence, and the offender’s personality and conduct. Mitigating circumstances under Article 84, including prior lawful conduct, sincere remorse and efforts to remedy the harm, may lead to reduced penalties.

As regards legal persons, sanctions remain primarily administrative in nature and consist mainly of monetary fines, temporary or permanent suspension or revocation of business activities, publication of the conviction, and temporary or permanent exclusion from public benefits, aid or subsidies, although in certain cases such sanctions may also be imposed by criminal courts. The imposition and assessment of such sanctions depend on factors such as the extent of damage and any recidivism of the legal entity. Under the more recent framework introduced by Article 134(3) of Law 5090/2024, the determination of sanctions against legal persons requires consideration of all relevant circumstances, including in particular the gravity and duration of the offence, the degree of responsibility of the entity, its financial standing, the amount of unlawful gain obtained or sought, the damage caused to third parties, any remedial actions taken after the offence (such as internal investigations contributing to its clarification), and any recurrence of offending behaviour.

In the Greek legal order, mechanisms exist for the recovery of the proceeds of crime primarily through confiscation as an ancillary penalty, as provided under Article 68 of the Greek Penal Code and Article 40 of Law 4557/2018 on money laundering. As a general rule, confiscation requires a prior conviction for a predicate offence, and the court assesses the extent of the unlawful benefit, ordering the confiscation either of the assets themselves or of their equivalent value, including any direct or indirect proceeds derived therefrom. The procedure takes place before the criminal court during the main proceedings, applying the criminal standard of proof, while third parties asserting rights over the confiscated assets may seek legal protection through the available remedies.

Enforcement of confiscation follows the rules governing the execution of criminal judgments, and in cases of non-compliance, coercive enforcement measures may be taken against the convicted person’s assets. In addition, precautionary measures, such as seizure or freezing of assets, may be imposed at the pre-trial stage and remain in force until a final decision is issued. Civil recovery or compensation claims may be pursued in parallel with criminal proceedings, without being mutually exclusive. Furthermore, any gains or profits generated from the investment of criminal proceeds are treated as derivative proceeds and are likewise subject to confiscation.

In the Greek legal order, mechanisms for financial compensation are primarily pursued through proceedings before the civil courts, while parallel remedies exist within the criminal process. Within the framework of alternative dispute resolution procedures, such as criminal conciliation and plea bargaining, the conclusion of an agreement may depend on the prior financial satisfaction of the injured party, while in certain property-related offences (eg, embezzlement, fraud, breach of trust and fraudulent conveyance), full restitution prior to final referral to trial may lead to exemption from punishment.

Victims may seek compensation before civil courts and, in parallel, participate in criminal proceedings as civil claimants in support of the prosecution from the pre-trial stage through trial.

Although confiscation operates as an ancillary penalty in favour of the state, it does not preclude the victim from asserting claims over misappropriated assets. Victims may invoke proprietary rights over such assets or their proceeds – including substituted assets and mixed funds – provided they can establish a link to the original property, by means of civil law actions such as proprietary claims or unjust enrichment. In addition, during criminal proceedings, victims may assert rights over seized or frozen assets and seek their exclusion from confiscation.

In Greece, current enforcement priorities in financial crime focus on enhancing transparency and combating fraud against the public sector, with particular emphasis on tackling money laundering through the competent national authority, as well as monitoring asset declarations and terrorist financing. In 2024, this authority imposed fines exceeding EUR98 million in cases involving confirmed tax evasion of EUR2.4 billion, while priority is also given to alignment with the requirements of the European Anti-Money Laundering Authority (AMLA).

Tax compliance and audit activities are primarily overseen by the Independent Authority for Public Revenue (AADE), focusing on combating tax evasion, modernising digital systems and enhancing enforcement through the use of digital tools and artificial intelligence.

At the legislative level, Law 5090/2024 introduced a hybrid liability regime for legal persons in corruption offences (such as bribery), empowering criminal courts to impose fines ranging from EUR50,000 to EUR10 million, or up to twice the annual profits. It also provides for enhanced administrative sanctions, thereby reinforcing efforts to combat organised crime and the concealment of illicit activities through corporate structures.

Institutionally, since the year of 2025, enforcement capacity has been further enhanced through the integration of the Financial and Economic Crime Unit (SDOE) into the AADE framework and the establishment of specialised regional units, including the Special Financial Control Units (MEOEL), Special Tax Audit Units (MEFEL) and Special Customs Control Units (METEL), tasked respectively with combating economic crime, large-scale tax evasion and smuggling. These units, supported by advanced operational tools and co-ordinated through centralised operational centres, are expected to carry out large-scale enforcement actions, with a target of at least 30,000 audits by 2026.

The legislative framework for combating economic crime in Greece has been significantly strengthened through recent reforms, with particular emphasis on the detection of organised and corporate crime, the deprivation of illicit proceeds, the establishment of new institutional structures and the transformation of audit mechanisms. The main legislative instruments governing this field include the following.

• Law 5259/2025, which introduced full exemption from criminal prosecution for debts owed to the state (including tax authorities and social security bodies) for individuals subject to bankruptcy proceedings. From the publication of the bankruptcy decision, all criminal prosecutions are suspended, while upon the successful completion of the bankruptcy process and discharge of debts, criminal liability is definitively extinguished, effectively removing the offence from the individual’s criminal record.
• Law 5090/2024, which introduced a hybrid model of sanctions against legal entities, including the imposition of fines and the suspension of business activities, marking an initial step towards addressing criminality conducted through complex corporate structures.
• Law 5036/2023, which includes provisions on debt restructuring and the tackling of tax evasion, strengthening the tools of the Independent Authority for Public Revenue (AADE) for detecting undeclared income.
• Law 5026/2023, which harmonised Greek legislation with the standards of the European Public Prosecutor’s Office (EPPO) for tackling offences affecting the financial interests of the European Union.

At the same time, under Law 4557/2018, as updated in 2025, specific persons (“obliged entities”) are required, as part of their compliance obligations, to report suspicious transactions to the Anti-Money Laundering Authority. These include banks, accountants and tax advisors, lawyers (in certain transactions), notaries and statutory auditors. They are also subject to “Know Your Customer” (KYC) obligations, requiring the identification of the ultimate beneficial owner (UBO) of each company. Failure to report suspicious transactions may result in significant administrative fines and may even give rise to liability as an accomplice.

Recent case law focuses on the more effective prosecution of tax evasion and non-payment of debts to the state, alongside a rationalisation of sanctions to ensure compliance with the fundamental principle of ne bis in idem. This has been expressly confirmed by the plenary of the Supreme Court (Areios Pagos), which held that, for the purposes of establishing criminal liability for debts owed to the state, amounts corresponding to debts that independently constitute tax offences should not be cumulatively taken into account. However, the application of this principle remains to be further clarified, particularly in light of the recent provisions of Law 5090/2024 concerning legal entities and the parallel imposition of administrative and criminal sanctions under various legislative frameworks for the same conduct.