White Collar Crime Comparative Guide

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1 Legal and enforcement framework

1.1 Which legislative and regulatory provisions govern white collar crime in your jurisdiction?

White-collar crime in Greece is governed by:

• the national legislative framework;
• EU regulations and directives on:
• • financial crime;
  • anti-money laundering;
  • public procurement;
  • fraud; and
  • the protection of the European Union's financial interests; and
• international treaties against:
• • corruption;
  • bribery; and
  • money laundering

The regulatory framework for white-collar crime in Greece is primarily established in:

• Chapters 9, 10, 12, 22 and 23 of the Second Book of the Criminal Code; and
• special criminal provisions found in various national laws, such as:
• • Law 146/1914 on unfair competition;
  • Law 3959/2011 on the protection of free competition;
  • Law 4548/2018 on the reform of the legal framework governing sociétés anonymes;
  • Law 3115/2003 on the authority for the assurance of the confidentiality of communications;
  • Law 3471/2006 on the protection of personal data and privacy in the field of electronic communications;
  • Law 3917/2011 on the retention of data generated or processed in connection with the provision of publicly available electronic communications services or public communication networks, and the use of surveillance systems involving audio or visual recording in public spaces, among other related provisions;
  • Legislative Decree 86/1967 on the imposition of sanctions against those delaying the payment and transfer of social security contributions;
  • Law 3560/2007 on the ratification and implementation of the Criminal Law Convention on Corruption and its Additional Protocol;
  • Law 2802/2000 on the ratification and implementation of the Convention on Combating Bribery of Officials of the European Communities or Officials of Member States of the European Union;
  • Law 4557/2018 on the prevention and suppression of money laundering and terrorism financing; and
  • Law 4037/2012 adapting Greek legislation to the provisions of Directive 2005/35/EC of the European Parliament and of the Council of 7 September 2005 on ship-source pollution and on the introduction of penalties, including criminal penalties for pollution offences, as amended by Directive 2009/123/EC of the European Parliament and of the Council of 21 October 2009, among other provisions.

1.2 Which bilateral and multilateral instruments of relevance to white collar crime have effect in your jurisdiction?

Greece maintains judicial cooperation with various states in criminal law matters. This cooperation is formalised through several bilateral agreements currently in force, addressing extradition and cross-border judicial assistance. Key agreements include:

• the Bilateral Agreement between the Hellenic Republic and the United States on Extradition (Law 3770/2009);
• the Bilateral Agreement between the Hellenic Republic and Russia on Extradition (Law 1242/1982);
• the Bilateral Agreement between the Hellenic Republic and Australia on Judicial Assistance in Criminal Matters (Law 3277/2004); and
• the Bilateral Agreement between the Hellenic Republic and the United States on Judicial Assistance in Criminal Matters (Law 3771/2009).

As a member of the European Union, Greece is also subject to European criminal law frameworks, including:

• Directive EU/2016/919 on the European arrest warrant, which streamlines the extradition process across EU member states; and
• EU Regulation 2017/1939, establishing the European Public Prosecutor's Office (EPPO), a centralised institution responsible for investigating and prosecuting crimes affecting the European Union's financial interests.

Moreover, Greece has enacted:

• Law 3663/2008 on the implementation of the European Judicial Cooperation Unit, joint investigation teams, recidivism and other provisions for the appointment of the national member, its deputy and assistant to:
• • propose investigations or prosecutions in Greece or other EU countries;
  • recommend coordination with other EU national authorities;
  • request the formation of joint investigation teams;
  • assist the Greek authorities with cross-border case coordination; and
  • execute judicial cooperation on behalf of Greece; and
• Law 4489/2017 on the European investigation order (EIO) in criminal matters, aligning national law with Directive 2014/41/EU. The EIO facilitates the mutual recognition and execution of investigative measures between EU member states in the context of criminal proceedings.

Greece maintains judicial cooperation with various states as a member of the European Union, which is formalised through several agreements currently in force, addressing extradition and cross-border judicial assistance, such as:

• the Agreement between the European Union and its Member States, of the one part, and Canada, of the other part on Judicial Assistance in Criminal Matters (Law 4981/2022);
• the Agreement between the European Union and its Member States, of the one part, and Japan, of the other part on Judicial Assistance in Criminal Matters (Law 4854/2021);
• the Agreement between the European Union and its Member States, of the one part, and Australia, of the other part on Judicial Assistance in Criminal Matters (Law 4852/2021); and
• the Agreement between the European Union and its Member States, of the one part, and New Zealand, of the other part on Judicial Assistance in Criminal Matters (Law 4851/2021).

In addition, the European Convention on Extradition applies within the Greek territory (Law 4165/1961), facilitating cooperation among European states. Through Law 3251/2004, Greece implemented the Framework Decision of 2002 on the European arrest warrant, which introduced a new process increasing the speed and ease of extradition throughout the European Union.

Furthermore, Greece has participated in Interpol since 1956, following the enactment of Law 3640/1956, ensuring communication between:

• its police and judicial and other authorities; and
• the Interpol General Secretariat as well as national central bureaus of member states.

The aim is to facilitate:

• crime prevention and prosecution;
• the exchange of information with international organisations and bilateral/multilateral police cooperation agreements;
• the registration, updating and deletion of arrest warrants;
• the execution of arrest warrants and Interpol red notices;
• the forwarding of data to Interpol databases on:
• • wanted vehicles;
  • missing persons;
  • stolen artefacts;
  • unidentified bodies;
  • crime methods;
  • serious threats; and
  • other relevant crime-related information; and
• the issue of corresponding notices.

1.3 Which bodies are responsible for enforcing the applicable laws and regulations? What powers do they have?

The Prosecutors' Offices at the Court of First Instance are the primary authorities responsible for initiating and conducting criminal prosecutions in most cases. They:

• oversee preliminary investigations;
• decide on charges; and
• supervise the course of criminal proceedings.

There are also specialised prosecutorial bodies dedicated to combating white-collar crime, including:

• the Economic Crime Prosecutor's Office, which is responsible for investigating and prosecuting:
• • complex financial and economic offences; and
  • corruption-related crimes; and
• the EPPO, which operates in Greece and focuses on cross-border financial crimes that affect the EU budget, such as:
• • fraud;
  • corruption; and
  • misuse of EU funds.

The Prosecutors' Offices at the Court of Appeal and the Supreme Court have supervisory authority over the work of the prosecutors at the Court of First Instance to ensure proper conduct in the handling of criminal investigations and prosecutions.

The Prosecutors' Offices at the Court of First Instance are responsible for processing the case until the conclusion of the main investigation, at which point they forward the case file to the public prosecutor at the Court of Appeal, who decides on referral to trial.

The Hellenic police also:

• enforce criminal law;
• investigate crimes;
• collect evidence; and
• execute warrants.

The Hellenic police operate specialised units dedicated to economic crimes, cybercrime and corruption, ensuring focused investigation and effective enforcement in these complex, high-impact areas. The Financial and Economic Crime Unit is particularly noteworthy, as it is tasked with investigating:

• tax evasion;
• money laundering; and
• other serious financial offences.

Judicial authorities are responsible for:

• adjudicating criminal cases;
• issuing warrants; and
• overseeing trials to ensure:
• • due process; and
  • the fair application of the law.

1.4 What is the general approach of the authorities in enforcing the applicable laws and regulations?

Greek prosecutorial authorities have an active role in enforcement efforts. They start by ordering a preliminary inquiry in order to gather evidence, which will determine whether prosecution is justified. After the conclusion of the preliminary inquiry, the public prosecutor will decide whether:

• to prosecute; or
• to dismiss the case:
• • on the grounds that there is no evidence indicating that a criminal offence has been committed; or
  • on legal grounds.

The decision to dismiss the case must be confirmed by the competent prosecutor at the Court of Appeal. If the public prosecutor decides to start prosecution for a misdemeanour offence, they will refer the case to trial before the Misdemeanour Court issuing a writ of summons. This document:

• is served on the defendant; and
• must state:
• • the accusation;
  • the trial date;
  • the court that the defendant must appear before;
  • the witnesses to be examined at the court hearing; and
  • the evidence to be introduced by the public prosecutor.

Foreign defendants also receive a translation of the summons in a language that they understand. In the case of serious crimes, the prosecutor may not refer a felony case for trial directly after the preliminary inquiry but must order a main investigation. The investigation is carried out by the investigating judge and aims to collect all evidence necessary for the Judicial Council, which will issue its decision after having heard the prosecutor on referral to trial.

During the pre-trial stage, the prosecuting and investigating authorities must respect the principles of confidentiality and legitimacy of the proceedings in accordance with their specific aspects – namely:

• the presumption of innocence (Article 6(2) of the European Convention on Human Rights), which is a fundamental principle of the Greek system according to which:
• • the burden of proof lies with the prosecution; and
  • the defendant is not obliged to disclose its evidence before trial; and
• in general, the rights of the suspect/defendant enshrined in:
• • the Code of Criminal Procedure;
  • the Constitution; and
  • the international agreements to which Greece is a signatory (ie, the European Convention of Human Rights, the Charter of Fundamental Rights of the European Union and the International Covenant on Civil and Political Rights).

The general approach of the Greek authorities in enforcing white-collar crime laws and regulations has been characterised by a gradual institutional modernisation. Greece has strengthened its institutional framework to combat serious crime – particularly economic and organised crime – by establishing two important mechanisms:

• the Directorate for Organised Crime (within the Hellenic police), which specialises in:
• • economic crimes;
  • corruption;
  • money laundering; and
  • international criminal activities; and
• the judicial police, who support the prosecutorial and judicial authorities.

2 Scope of application

2.1 Can both individuals and companies be prosecuted under the white collar crime laws? Under what circumstances are employees' actions attributable to the company?

As a general principle of Greek criminal law, criminal proceedings can only be initiated against natural persons. Article 7(1) of the Constitution defines a 'crime' as an act that constitutes a criminal offence by virtue of a statute prior to its perpetration. Legal entities as such are not considered capable of acting as such and of having a guilty mind in respect of such acts.

Nevertheless, the economic activity of businesses in Greece is closely linked to the commission of serious financial crimes that have broader consequences for society, such as:

• corruption offences;
• criminal acts relating to capital markets law; and
• competition law violations.

The gravity and extent of criminal behaviour committed within the context of business operations have drawn attention to the phenomenon of corporate crime. The concept of corporate criminality refers to:

• individual deviant behaviours that occur in connection with a business's operations; and
• the actions of associates or corporate executives that are attributed to the business itself, which is thereby treated as a 'corporate offender'.

In practice, in cases involving white-collar crime, only natural persons may be held criminally liable for financial offences. These typically include a company's legal representatives, managers and board members, who may be prosecuted either jointly or individually, depending on the scope and nature of their responsibilities in the company's management.

The liability of legal entities is not criminal, but there are provisions for sanctions in the form of:

• fines;
• administrative penalties; and
• other measures.

All these sanctions are provided for in Article 46 of Law 4557/2018. Sanctions mainly take the form of:

• administrative fines;
• the temporary or permanent cessation of activities;
• a prohibition on certain business activities; and
• a ban from public procurement.

2.2 Can foreign companies be prosecuted under the white collar crime laws?

Under Greek criminal law, legal persons cannot be held criminally liable; liability is limited to natural persons, such as legal representatives and members of the board of the relevant legal entity. However, there is a growing international and domestic trend advocating for the recognition of corporate criminal liability.

Many jurisdictions have amended their national criminal legislation to introduce such liability, reflecting the evolving global consensus. Influential international bodies have emphasised the need for reform in this area, highlighting the importance of holding legal persons accountable for criminal offences committed in the context of their business activities.

Notable references include:

• the G20 Leaders' Joint Statement (2019);
• the United Nations Convention against Corruption;
• the Organisation for Economic Co-operation and Development Convention on Combating Bribery of Foreign Public Officials; and
• Recommendation (88)18 of the Council of Europe, entitled "Liability of Legal Persons for Criminal Offences Committed in the Course of their Activities."

2.3 Can successor companies be prosecuted under the white collar crime laws?

The Criminal Code does not recognise the criminal liability of legal persons – liability is instead attributed to natural persons, such as the legal representatives and board members of a legal entity.

However, in cases that involve the general or specific succession of legal persons, if it is established that the business operations of a company are continuing through a successor entity, criminal liability may extend to individuals from both the predecessor and successor companies. This is particularly relevant in the case of repeat offences, given that only natural persons can be held criminally accountable under current Greek criminal law.

2.4 Do the white collar crime laws have extraterritorial reach?

Article 5 of the Criminal Code provides jurisdiction for crimes committed within the Greek territory, including offences committed by foreigners in Greece. Greek vessels and aircraft are also part of the Greek territory. If the double criminalisation principle is satisfied, jurisdiction also applies to:

• crimes committed by Greek citizens abroad (Article 6 of the Criminal Code); and
• offences committed abroad by foreigners against Greek nationals (Article 7 of the Criminal Code).

Greece recognises foreign criminal decisions and its jurisdiction applies to Greek nationals and other persons found guilty abroad (Article 11 of the Criminal Code).

In light of the above provisions, Greek criminal law – including laws relating to white-collar offences – may apply extraterritorially. These include cases where the offence was:

• committed outside the Greek territory;
• committed by a Greek national abroad; or
• committed against a Greek citizen abroad.

Such application is subject to the important procedural safeguard of double jeopardy – that is, Greek jurisdiction may not be exercised if the same offence has already been prosecuted with finality in another jurisdiction, as this would constitute a serious breach of this fundamental legal principle.

3 Offences

3.1 What types of white collar crimes are recognised in your jurisdiction and what do they involve?

In response to the need for criminal accountability in the business and economic sectors, Greek legislation – through either the Criminal Code or special criminal regulations – has codified and penalised a wide range of white-collar crimes.

The Criminal Code includes offences such as:

• forgery of documents (Article 216);
• passive bribery of civil servants in breach of duties (Article 235);
• active bribery of civil servants (Article 236);
• violation of secrecy (Article 370);
• violation of secrecy of telephone and oral communications (Article 370A);
• theft of professional secrets and data protection violations (Article 370B);
• unauthorized data access (Article 370C);
• embezzlement (Article 375);
• fraud (Article 386);
• fraud with computer (Article 386A); and
• breach of trust (Article 390).

In addition, specific white-collar crimes are addressed under special laws, including:

• money laundering (Law 4557/2018, as amended by Law 5042/2023);
• accounting fraud (Laws 5104/2024, 4548/2018 and 4254/2014);
• tax evasion (Law 5104/2024);
• EU fraud (Law 2803/2000);
• corruption involving officials of the European Communities or officials of EU member states (Law 2802/2000);
• the issue of bounced cheques (Law 5960/1933);
• breach of trade secrets (Law 146/1914);
• non-payment of social security contributions (Law 86/1967);
• market manipulation and capital market violations (Laws 4443/2016 and 4141/2013);
• customs offences (Law 2960/2001);
• anti-competitive practices (Law 3959/2011);
• non-payment of debts to the state (Law 1882/1990); and
• environmental offences (Laws 1650/1986, 4037/2012 and 4042/2012).

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.

3.2 How are predicate offences defined in your jurisdiction?

p>Money laundering is generally considered a secondary offence because it typically involves concealing or disguising the origins of illegally obtained money, rather than being the initial criminal act.

A 'predicate offence' does not mean just any offence, but only one of those listed in Article 4 of Law 4557/2018. These include:

• organised crime;
• bribery;
• crimes against:
• • human life;
  • physical integrity; and
  • personal freedom;
• counterfeiting of currency;
• theft;
• embezzlement;
• extortion;
• fraud;
• forgery;
• sexual offences against adults and minors;
• stock exchange offences;
• tax evasion;
• non-payment of debts to the state;
• piracy;
• IP infringements; and
• any offence:
• • resulting in illegal gains; and
  • punishable by imprisonment or incarceration for more than three months.

3.3 Do any restrictions or thresholds (eg, in terms of parties, asset type or transaction value) serve to limit the types of activities that constitute white collar crimes?

In general, the amount of illicit proceeds plays a significant role in determining whether an offence qualifies as a white-collar crime. Specifically, under Greek criminal law, the threshold for classifying an offence as a felony – rather than a misdemeanour – is illegal gains of €120,000.

3.4 What are the most common offences for which company directors and officers can be held personally liable?

Company directors, board members and managers may be found criminally liable for any unlawful act committed in the course of their duties.

However, in our experience, it is most often the case that legal representatives of companies are suspected or even accused of:

• active bribery of civil servants (Article 236 of the Criminal Code);
• embezzlement (Article 375 of the Criminal Code);
• breach of trust (Article 390 of the Criminal Code);
• accounting fraud (Laws 5104/2024, 4548/2018 and 4254/2014);
• tax evasion (Law 5104/2024);
• the issue of bounced cheques (Law 5960/1933);
• breach of trade secrets (Law 146/1914);
• non-payment of social security contributions (Law 86/1967);
• market manipulation and capital market violations (Laws 4443/2016 and 4141/2013);
• anti-competitive practices (Law 3959/2011);
• non-payment of debts to the state (Law 1882/1990); and
• environmental offences (Laws 1650/1986, 4037/2012 and 4042/2012)

4 Compliance

4.1 Is the implementation of a compliance programme a regulatory requirement in your jurisdiction? If so, what should this cover?

Greece has no specific regulatory requirement that mandates all companies to implement a compliance programme in a standardised manner. However, companies may be subject to various laws and regulations that indirectly necessitate the establishment of effective compliance measures.

With regard to anti-money laundering (AML) issues covered in Article 5 of Law 4557/2018, institutions and persons must implement relevant compliance programmes following the guidelines and regulations of the competent supervisory authorities. Compliance programmes should be designed to meet the minimum requirements set out in Greek law, which is aligned with EU directives and best practices.

A robust AML compliance programme typically:

• incorporates:
• • effective customer due diligence procedures;
  • thorough risk assessments;
  • ongoing employee training; and
  • adequate record-keeping and internal controls; and
• establishes:
• • mechanisms for the ongoing monitoring of transactions to detect unusual or suspicious patterns of activity; and
  • procedures for reporting such transactions.

Furthermore, companies listed on the Athens Stock Exchange are subject to compliance obligations under corporate governance laws (Law 4706/2020), including:

• internal control systems;
• a code of conduct;
• whistleblowing procedures; and
• risk management policies.

4.2 Does failure to implement an adequate compliance programme constitute a regulatory and/or criminal violation in your jurisdiction?

In Greece, failure to implement an adequate compliance programme does not generally constitute a criminal offence or regulatory violation across all sectors. However, in specific regulated sectors, especially those dealing with financial crime prevention, such failure can lead to significant regulatory and legal consequences.

The supervisory authorities – such as the Hellenic Capital Market Commission and the Bank of Greece – play a crucial role in overseeing financial institutions and other entities for compliance with AML regulations. Failure to implement an adequate AML compliance programme:

• can contribute to the facilitation of money laundering; and
• may lead to regulatory enforcement actions, including:
• • fines;
  • penalties; and
  • other administrative measures (eg, licence revocation).

Regulatory authorities may also require remedial actions and improvements to the AML programme.

All institutions and persons covered by Article 5 of Law 4557/2018 should implement AML compliance programmes, following the guidelines and regulations of the competent supervising authorities. Covered institutions, which are more vulnerable to money laundering activities (eg, banks, financial and insurance institutions), have more comprehensive and detailed AML compliance programmes. However, even natural persons such as lawyers and notaries must meet the standards set by the competent supervising authorities (eg, the Ministry of Justice, bar associations and notary associations).

4.3 What due diligence requirements apply in relation to customers, partners, suppliers etc?

Law 4557/2018 outlines a complex set of diligence rules for covered persons to follow, which apply to the following, among others:

• new and existing clients;
• high-risk individuals;
• politically exposed persons (PEPs);
• transactions in new financial products; and
• transactions executed without the client's physical presence.

Financial institutions, including banks, must conduct thorough customer due diligence when establishing a business relationship with a customer. This involves:

• identifying and verifying the identity of the customer;
• understanding the nature of the business relationship; and
• assessing the customer's risk profile.

Enhanced due diligence may be required for higher-risk customers (eg, PEPs or customers from high-risk jurisdictions). Entities should conduct due diligence on their partners, suppliers and other third parties to assess the risk of involvement in money laundering or other illicit activities. This may involve obtaining information on the third party's:

• ownership structure;
• business activities; and
• reputation.

Ongoing monitoring of customer transactions and business relationships is essential to identify any unusual or suspicious activities. If, during the due diligence process or ongoing monitoring, an entity identifies suspicious activities, it must report such transactions to the relevant authorities. Confirmation and verification of the identity of the customer and the beneficial owner must take place prior to the conclusion of the business relationship or execution of the transaction.

Such identity verification may be completed during the establishment of a business relationship, if necessary, so as not to interrupt the normal conduct of business where there is little risk of money laundering or terrorist financing. In such cases, the verification procedures are completed as soon as possible after the initial contact.

4.4 What books and records requirements apply in this context?

According to Article 30 of Law 4557/2018, as amended by Law 4734/2020, obligated persons must retain the following:

• documents and information required for compliance with the due diligence requirements defined in Article 13 – including, where available, information obtained through:
• • electronic identification means;
  • related trust services as defined in EU Regulation 910/2014; or
  • any other secure, remote or electronic identification process regulated, recognised, approved or accepted by the Hellenic Telecommunications and Post Commission;
• originals or copies of documents necessary for the identification of transactions;
• internal documents concerning approvals, findings or recommendations for cases related to the investigation of related offences or reported or unreported cases by the competent authority; and
• information from business, commercial and professional correspondence with clients, as may be identified by regulatory authorities.

Records of verification of client identity and other customer due diligence records must usually be retained for at least five years, always taking into account:

• the General Data Protection Regulation; and
• relevant Greek laws.

4.5 What other compliance best practices should a company implement to mitigate the risk of white collar crime?

Mitigating the risk of white-collar crime requires a comprehensive and proactive approach to compliance. The promotion of a culture of ethics and compliance throughout any organisation is essential. Leadership should set a tone of zero tolerance for white-collar crimes and unethical behaviour.

Key actions include the following:

• Regular risk assessments: Identify and evaluate:
• • vulnerabilities related to white-collar crime; and
  • financial irregularities within the organisation.
• Confidential and secure reporting mechanism: Establish safe channels for employees to report suspected misconduct, ensuring protection from retaliation. Certain entities in Greece (public and private, over 50 employees) must establish internal whistleblowing channels pursuant to Law 4990/2022.
• Thorough due diligence: Implement comprehensive background checks and assessments before hiring staff or entering into partnerships with third parties to minimise risk.
• Regular internal and external audits: Conduct periodic audits to detect and prevent:
• • fraud;
  • embezzlement; and
  • other financial crimes.
• Conflict of interest policies: Develop and enforce clear policies that identify and manage potential conflicts of interest among employees and management.

4.6 Must companies report financial irregularities or actual or potential violations?

Financial irregularities and actual or potential violations are typically subject to reporting requirements and companies are expected to comply with these regulations.

Reporting mechanisms may include filing reports with supervisory bodies such as:

• the Hellenic Capital Market Commission;
• the Bank of Greece; and
• the Hellenic Accounting and Auditing Standards Oversight Board.

A 'suspicious activity' is one which indicates that:

• a money laundering offence has been committed or attempted; or
• the transacting party may be involved in other criminal activity (predicate offences).

This assessment is made in view of:

• the characteristics of the transaction;
• the background of the client; and
• the history of the client's transactions.

Suspicious transactions must be reported immediately to the Financial Intelligence Unit (FIU). The Ministry of Finance has issued a series of circulars in respect of the application of anti-money laundering laws and regulations and bookkeeping obligations, setting out specific guidelines for auditors and accountants to report any transaction that gives rise to any suspicion that it is related to a criminal act to the FIU.

4.7 What factors will the authorities consider in assessing the adequacy of a compliance programme?

The main factors relate, among other things, to:

• the organisation's ability to conduct a thorough and effective risk assessment to identify and understand its money laundering and terrorist financing risks;
• the existence and effectiveness of:
• • written AML policies and procedures; and
  • clear guidelines on customer due diligence, enhanced due diligence and other AML-related processes;
• the adequacy of customer due diligence processes, including:
• • the verification of customer identities; and
  • the assessment of associated risks;
• the implementation of enhanced due diligence for high-risk customers, such as:
• • PEPs; and
  • customers from high-risk jurisdictions;
• the organisation's commitment to providing regular AML training to employees;
• the effectiveness of ongoing monitoring processes to detect and report suspicious activities;
• the maintenance of accurate and up-to-date records related to:
• • customer due diligence;
  • transactions; and
  • other AML compliance activities;
• the organisation's ability to promptly report suspicious transactions to the relevant authorities;
• internal communication channels for reporting and escalating AML-related concerns;
• regular and independent reviews or audits of the AML programme to identify weaknesses and areas for improvement; and
• the involvement and oversight of senior management in ensuring the effectiveness of the AML programme.

5 Investigations

5.1 How are investigations typically commenced in your jurisdiction?

Criminal proceedings are initiated by the public prosecutor at the Court of First Instance. The public prosecutor commences proceedings upon receiving information indicating that a criminal offence has been committed. This information typically originates from the individual filing a criminal complaint, who:

• provides details of the facts constituting the offence; and
• identifies the alleged perpetrators.

Additionally, the public prosecutor may initiate criminal proceedings ex officio based on information received through other sources, such as:

• public authorities;
• media reports; or
• other means.

For certain misdemeanour offences filing a criminal complaint by the victim is a legal condition in order to initiate criminal proceedings.

The prosecutor provides guidance to enforcement agencies for conducting:

• investigations;
• searches;
• interrogations; and
• interviews.

Upon completion of investigative actions, the prosecutor:

• evaluates the findings; and
• determines the subsequent course of action.

Depending on the nature and procedural requirements of the case, the prosecutor may:

• submit written recommendations to the Judicial Council either advocating for or opposing indictment; or
• refer the individual directly to trial.

In complex or serious cases, multiple prosecutors may collaborate under the direction of the prosecutor for economic crime. Prosecution may be initiated based on a written complaint or information received from other sources, including regulatory authorities and enforcement agencies.

Investigative officials in Greece include members of the Hellenic police, which has specialised divisions – such as the Internal Affairs Division and the Financial Police Division – dedicated to combating business-related crimes. Additional law enforcement authorities with investigative powers over specific categories of business offences include:

• Customs; and
• the Coast Guard.

Investigations may also be conducted by bodies such as the following, within the scope of their respective competencies:

• the Financial and Economic Crime Unit of the Ministry of Finance; and
• regulatory bodies including:
• • the Hellenic Capital Markets Commission; and
  • the Hellenic Competition Commission.

The Hellenic Financial Intelligence Unit does not possess full investigative powers; however, it:

• is authorised to conduct on-site inspections; and
• cooperates closely with other authorities in fulfilling its mandate.

All law enforcement officials operate under the supervision of the public prosecutor, whose directives they are obliged to follow, including when conducting special investigative procedures. Where overlapping jurisdiction exists among investigative agencies, collaboration and information exchange are common practice to ensure the effective prosecution of business crimes.

5.2 What investigative powers do the authorities have?

In Greece, investigative authorities possess a range of powers to effectively investigate criminal offences, including white-collar crimes.

These powers include the following:

• Conducting searches and seizures: Authorities can search premises, vehicles and electronic devices and seize evidence related to the investigation, subject to judicial authorisation where required.
• Interrogations and interviews: Investigators can question:
• • suspects;
  • witnesses; and
  • experts.
• Suspects have rights safeguarded under the law, including the right to legal counsel.
• Surveillance and wiretapping: With prior judicial approval, authorities may conduct electronic surveillance, wiretapping and monitoring of communications when investigating serious offences.
• Forensic examination: Authorities can carry out forensic analyses, including:
• • financial audits;
  • cyber forensics; and
  • other technical examinations relevant to the case.
• Collaboration and information exchange: Investigative bodies cooperate with other national agencies and international counterparts, exchanging information and evidence as part of cross-border investigations.
• Detention and arrest: Investigators may request the arrest or detention of suspects:
• • under the supervision of the public prosecutor; and
  • in accordance with legal safeguards.
• Special investigative measures: In some cases, the authorities may employ undercover operations, controlled deliveries or other covert techniques authorised by the judiciary.

These powers are exercised under strict adherence to the principles of legality, proportionality and respect for fundamental rights, including those enshrined in:

• the Greek Constitution; and
• international human rights treaties.

The public prosecutor oversees and coordinates investigative actions to ensure compliance with the law.

5.3 Can the authorities demand that a company under investigation produce documents? When can the authorities search the premises and seize documents of a company under investigation

It is common practice for law enforcement authorities to request that legal entities provide relevant evidence and documentation to assist in the investigation of offences allegedly committed by natural persons associated with the company – such as board members or directors – in the course of their duties. Where deemed necessary, and in compliance with the principles of proportionality and legality, the competent authorities may:

• conduct searches on the company's premises; and
• seize any pertinent evidence.

Pursuant to Article 256 of the Code of Criminal Procedure, a court official must be present during such searches to ensure that the investigative actions are conducted lawfully. This provision also mandates that investigators exercise care to:

• avoid unnecessary exposure of confidential information; and
• minimise disruption to individuals present at the premises.

Furthermore, investigators must act cautiously to protect the reputation of persons not implicated in the offence under investigation. Finally, the occupant of the premises must be present throughout the investigation process.

5.4 Do the authorities typically cooperate with their foreign counterparts in conducting an investigation? If so, what is the process for doing so?

Yes. Mutual legal assistance may be granted for any investigative measure:

• provided that a bilateral or multilateral convention exists; or
• under the principle of reciprocity.

The sole limitation is that the requested measure must be permissible under Greek law with respect to the offence in question. Such measures may include:

• taking evidence or statements from individuals;
• effecting service of judicial documents;
• executing searches and seizures, as well as freezing property or evidence;
• examining objects and sites;
• providing:
• • information;
  • evidentiary materials; and
  • expert evaluations;
• supplying originals or certified copies of relevant documents and records, including government, banking, financial, corporate or business records;
• identifying or tracing property, instrumentalities or other items for evidentiary purposes;
• conducting controlled deliveries or covert investigations; and
• facilitating:
• • the voluntary appearance of individuals in the requesting state; or
  • the temporary transfer of persons held in custody.

In most cases, mutual legal assistance requests are transmitted through the Central Authority at the Ministry of Justice to the locally competent prosecutor at the Court of Appeal. From there, the requests are forwarded to the investigating officer within the respective jurisdiction, who will carry out the necessary investigatory acts. In urgent cases, requests may also be submitted via Interpol channels. Once the evidence has been collected, it is transmitted back through the competent prosecutor at the Court of Appeal to the Ministry of Justice and subsequently forwarded to the requesting authority.

5.5 What rights do companies and their directors and officers have during an investigation (eg, in relation to interviews/privacy and data protection)?

Any board member or legal representative of the company who is suspected or charged in a criminal case has certain rights under:

• the Code of Criminal Procedure;
• the Constitution;
• the European Convention on Human Rights; and
• other international conventions.

Both suspects and defendants suspected of committing a potentially criminal offence have important rights. More specifically, they have the right to:

• be represented by a defence lawyer;
• receive free legal advice if they cannot afford to pay for this;
• consult with a lawyer;
• be given a deadline by which to provide written statements or an explanation;
• be notified of and receive copies of the case file; and
• receive translation or interpretation services if they do not speak Greek.

Finally, their personal data is subject to constitutional and transnational protection. However, in certain cases – and always in accordance with the principles of proportionality and legality – it is possible for law enforcement authorities to request and secure the removal of phone and computer privacy for the purposes of their investigation.

If the preliminary examination for a potentially criminal offence is carried out by the public prosecutor for financial crime, the latter, under their prosecution powers, may seek:

• access to tax, banking, stock exchange and any other private information not subject to the restrictions of the relevant legislation; and
• the freezing of:
• • bank accounts;
  • safe deposit boxes; and
  • any other assets.

For any of the above actions, the public prosecutor for financial crime must issue a specifically reasoned order and then serve it on the defendant, which in turn can lodge an appeal against it before the competent judicial council.

5.6 What rules govern attorney-client privilege in your jurisdiction and what are their implications in the context of white collar crime investigations?

Greek law makes sufficient provision for the protection of the confidentiality between lawyer and client at both:

• the preliminary investigation stage before and after the prosecution; and
• the trial proceedings.

According to Article 99(4) of the Code of Criminal Procedure, all communications between a suspect or defendant and their defence lawyer are confidential.

Furthermore, according to Article 212 of the code:

• lawyers cannot be examined by the court as witnesses if they provide testimony on matters subject to professional confidentiality; and
• if they are examined, the proceedings are considered null and void.

In fact, any disclosure of this kind of confidential information constitutes a criminal offence under Greek law (Article 371 of the Criminal Code). These provisions afford adequate protection to the defendant. Even if a court takes such business confidential information into account when sentencing a person, not only are there grounds to appeal the decision, but also the proceedings are declared null and void – a fact which constitutes separate grounds for appeal pursuant to Article 510(1A) of the Code of Criminal Procedure.

5.7 What factors will the authorities consider in assessing whether to bring charges?

When the public prosecutor becomes aware by any means of the possible commission of an offence, they are obliged to investigate whether criminal prosecution should be pursued against the alleged perpetrators. This investigation is conducted under the order of the competent prosecutor and takes the form of a preliminary examination. According to Article 43 of the Code of Criminal Procedure, a preliminary examination is mandatory in cases involving felonies or misdemeanours under the jurisdiction of a three-member misdemeanour court.

Typically, the prosecutor's order to initiate the preliminary examination is directed to the locally competent police departments and magistrates courts. The primary purpose of this examination is to determine whether there is sufficient evidence to proceed with criminal prosecution. Subject to the principle of legality, if the evidence is deemed sufficient, the prosecutor must initiate criminal proceedings. Conversely, if the evidence is insufficient, the prosecutor is obliged not to proceed with prosecution but to maintain a record of the complaint.

While the decision to initiate prosecution is fundamentally governed by the principle of legality, a strict application of this principle in every case may produce unjust outcomes. Therefore, certain provisions of the Code of Criminal Procedure recognise the principle of prosecution where it is opportune. In such instances, refraining from prosecution may be preferable when the social benefit derived from prosecuting is outweighed by the social harm it may cause – for example, when non-prosecution acts as an incentive to uncover more serious crimes whose punishment serves the public interest.

The principle of prosecution where it is opportune does not permit arbitrary decisions to prosecute but rather requires decisions to be made in accordance with the principle of proportionality.

6 Enforcement

6.1 What is the structure of the criminal courts in your jurisdiction?

The Greek judicial system operates independently from the legislative and executive branches of government, in accordance with the principle of separation of powers enshrined in the Constitution. Criminal courts are categorised based on the nature of offences into misdemeanour courts and felony courts, which handle misdemeanours and felonies respectively, as classified in the initial documentation related to the criminal act under prosecution.

These courts are further divided hierarchically according to the nature and complexity of the cases they adjudicate, comprising:

• single-member and three-member misdemeanour courts;
• three-member courts of appeal;
• single-member and three-member felony courts;
• mixed jury courts; and
• mixed jury courts of appeal.

Certain offences committed by specific categories of persons whose status warrants a distinct legal procedure fall under the jurisdiction of special criminal courts established by dedicated criminal legislation. These include:

• the Military Court;
• the Naval Court;
• the Air Force Court; and
• the Juvenile Court.

At the apex of the judicial hierarchy stands the Supreme Court, which is the highest criminal court in Greece. It:

• holds the authority to supervise the proper application and interpretation of criminal law; and
• through its rulings, ensures the consistency and integrity of case law.

6.2 Are white collar crimes tried by jury in your jurisdiction?

In Greece, white-collar crimes are generally tried by professional judges rather than juries. The Greek judicial system primarily relies on professional judges to adjudicate criminal cases, including those involving white-collar offences.

Cases involving financial or administrative matters require highly specialised knowledge in technical and financial aspects and legal analysis of concepts, which take many years of research in the law to develop. Consequently, financial crimes constituting a felony have been excluded from the jurisdiction of mixed juries, as these cases are particularly complicated for jurors.

6.3 What is the statute of limitations for prosecuting white collar crime in your jurisdiction?

White-collar crimes in Greece are classified as either misdemeanours or felonies based on the applicable penalty. The statute of limitations for prosecuting white-collar crime felonies is 15 years from the date on which the offence was committed, while for white-collar crime misdemeanours it is five years, pursuant to Article 111 of the Criminal Code.

Furthermore, as provided by Article 113 of the Criminal Code, the limitation period is suspended during the pendency of judicial proceedings, for:

• five years in the case of felonies; and
• three years in the case of misdemeanours.

6.4 Can parties that voluntarily report white collar crime or cooperate with investigations benefit from leniency in your jurisdiction?

In Greece, parties that voluntarily report white-collar crimes or cooperate with investigations can benefit from leniency measures.

The general legal framework for leniency in Greece is established in Articles 84 and 85 of the Criminal Code. According to these provisions, the offender's sincere remorse and efforts to remedy or mitigate the consequences of the offence may be considered as mitigating circumstances, potentially leading to a reduced sentence. To benefit from such mitigation:

• the defendant must formally raise the mitigating circumstance through their legal counsel; and
• the claim must be presented during the final stage of the criminal proceedings – that is, at the sentencing phase following a guilty verdict.

Courts will carefully evaluate the sincerity and substance of the remorse and the actions taken by the defendant. Examples of conduct that typically support a mitigation claim include:

• active participation in the investigation, such as providing truthful statements or facilitating the discovery of evidence;
• provision of financial or material compensation of the victim;
• efforts to undo or minimise the harm caused by the offence; and
• voluntary surrender, confession or cooperation with authorities.

These actions are viewed positively and may significantly influence the court's decision on sentencing, particularly when they demonstrate:

• genuine accountability; and
• a willingness to repair the damage caused.

Mitigating factors are not automatically applied; rather, they:

• must be proven with evidence; and
• are subject to the court's discretion.

If accepted, they may result in reduced penalties, including the possibility of:

• a suspended sentence; or
• a lighter custodial term.

While there is no national leniency programme for white-collar crimes, several specific legal provisions offer leniency for voluntary disclosure and cooperation during the investigation.

In the case of corruption offences – such as passive and active bribery (Articles 236 and 237 of the Criminal Code) and breach of duty by public officials (Article 390 of the Criminal Code) – Article 263B of the Criminal Code provides for the following leniency measures:

• a reduced sentence pursuant to Article 44(2) of the Criminal Code, which allows for significantly mitigated punishment;
• suspension of execution of the sentence, even if the typical legal requirements for suspension under Article 99 of the Criminal Code are not met;
• temporary suspension of the trial by a court decision to verify the truth of the evidence; and
• the lifting of procedural measures (eg, detention).

Under Law 3959/2011, which aligns with EU competition law, the Hellenic Competition Commission operates a leniency programme. Entities or individuals that are the first to disclose cartel activities and provide significant evidence may receive:

• full immunity; or
• a reduction in fines or suspension of the prosecution.

Furthermore, Law 4990/2022, which transposes EU Directive 2019/1937 into Greek law, offers protection to individuals who report breaches of EU law, including those related to:

• financial services;
• public procurement; and
• anti-money laundering.

This law prohibits retaliation against whistleblowers and provides legal safeguards, such as confidentiality and immunity from liability, encouraging individuals to report violations without fear of adverse consequences.

6.5 Can the existence of a compliance programme constitute a defence to charges of white collar crime?

The mere existence of a compliance programme does not automatically provide a full legal defence against charges of white-collar crime. However, a well-designed and properly implemented compliance programme can support claims for leniency by demonstrating that the company and its management took reasonable steps to prevent wrongdoing.

6.6 What other defences are available to parties charged with white collar crime?

At the trial stage, the defendant benefits from the principle of in dubio pro reo – that is, any doubt regarding the defendant's guilt must be resolved in their favour. The standard of proof for delivering a verdict is proof before reasonable doubt and the decision need not be unanimous.

As for the means of proof, Greek criminal procedural law provides that any lawfully obtained evidence is, in principle, admissible before the court (Articles 177 and 178 of the Code of Criminal Procedure). The law does not assign fixed probative value to specific types of evidence; instead, all admissible evidence is subject to the court's free evaluation based on the principle of moral conviction.

Common forms of evidence include:

• circumstantial evidence (indices);
• inspection of persons, places or objects;
• expert reports;
• confessions;
• witness statements; and
• documents.

While a confession by the defendant is considered a strong indication of guilt, it:

• is assessed alongside all other evidence; and
• is ultimately subject to the court's discretion and overall judgement.

6.7 Can parties negotiate a pre-trial settlement through plea bargaining, settlement agreements or similar?

In recent years, in response to persistent delays in the administration of justice, the Greek legal system has begun incorporating elements inspired by Anglo-Saxon legal traditions, allowing for the quasi-out-of-court resolution of criminal cases. Notable among these developments are the institutions of criminal conciliation (Articles 301 and 302 of the Code of Criminal Procedure) and criminal negotiation (Article 303 of the Code of Criminal Procedure), which aim to expedite proceedings through structured agreements between the prosecution and the defendant.

Article 301 of the Code of Criminal Procedure allows for criminal conciliation (plea agreement) in specific felony cases before the formal end of the investigative stage. This process applies mainly to:

• non-violent financial/property offences; and
• offences under specific laws (eg, anti-money laundering, tax, smuggling, public procurement fraud).

In cases where criminal prosecution for a felony (as defined in article 301 of the Code of Criminal Procedure) has been initiated, the defendant may submit a request for criminal conciliation:

• after the formal completion of the preliminary investigation; and
• before the issuance of the indictment or a prosecutor's opinion for direct referral to trial.

This request is submitted to the prosecutor handling the case, which:

• triggers further investigation; and
• suspends the prosecutor's prior recommendation to the Judicial Council or Court of Appeal president.

If the defendant's request is made after the indictment or the prosecutor's opinion but before the defendant is officially summoned to court, the prosecutor will refer the request to the competent trial court on the same trial date.

If the summons has been served and the trial date is set more than four months ahead, the prosecutor can:

• withdraw the case from the scheduled date; and
• arrange a priority new trial date to present the defendant's request to the court.

The court's procedure applies specifically to misdemeanours (less serious crimes compared to felonies) falling under the following provisions:

• Articles 216(1) and (2) of the Criminal Code: These typically concern offences related to property crimes without violence (eg, theft under certain conditions).
• Article 242(1) of the Criminal Code: This generally deals with forgery offences.
• Specific laws listed: Laws 1599/1986, 2803/2000, 2960/2001, 4557/2018 and 5104/2024 cover various offences – often regulatory or financial crimes.
• Misdemeanours against property and assets without violence or threat: These crimes:
• • target property or financial interests; and
  • do not involve the use of physical violence or threats.

Article 303 of the Code of Criminal Procedure permits criminal negotiations to be initiated either before the formal conclusion of the investigation or preliminary inquiry or at the trial prior to commencement of the presentation of evidence – always upon the defendant's request. Under this procedure, the defendant's confession is exchanged for a reduced sentence. Notably, only the sentence is subject to negotiation; the charge itself remains non-negotiable. The defendant can request a plea negotiation in writing up to 10 days after receiving the summons or indictment, once at each stage of the process.

A written negotiation agreement is drawn up and signed by:

• the prosecutor;
• the defendant; and
• the defendant's lawyer.

This agreement must include:

• the defendant's confession to the crime;
• the agreed sentence; and
• the manner in which the sentence will be served.

Sentencing limits vary according to the severity of the offence:

• up to five years' imprisonment for felonies punishable by up to 10 years;
• up to nine years for felonies with longer sentences;
• up to 10 years for more serious felonies;
• up to two years for misdemeanours; and
• a minimum of three years for felonies punishable by temporary imprisonment.

The sentence is determined based on:

• the gravity of the offence;
• the circumstances of the act;
• the degree of fault; and
• the defendant's personality and financial situation.

Provisions for suspension or modification of the sentence apply accordingly. When the request is made immediately after prosecution during the pre-trial stage, the agreement may also include conditional release options after serving part of the sentence. Additionally, the agreement appoints a lawyer as the defendant's official representative and contact person in court.

6.8 What penalties can be imposed for white collar crime? How are these determined? Can non-exhaustive penalties be imposed for such violations (eg, exclusion from public procurement, exclusion from entitlement to public benefits or aid, disqualification from the practice of certain commercial activities, judicial winding up)?

The punishments for white-collar crimes vary depending on:

• the type of offence; and
• the severity of the offence, which is largely determined by the total value of the property involved.

Penalties are prescribed on a case-by-case basis and include:

• pecuniary sentences;
• imprisonment for misdemeanours; and
• imprisonment for felonies.

Prison sentences for misdemeanours, depending on the gravity of the offence, can range from 10 days up to five years (Article 53 of the Criminal Code). For felonies, provisional imprisonment ranges from five to 20 years (Article 52 of the Code of Criminal Procedure).

Additional penalties may be imposed by the court pursuant to Article 59 of the Code of Criminal Procedure. These can include:

• disqualification from holding public office;
• a prohibition on practising a profession;
• publication of the conviction; and
• confiscation of property.

6.9 What rights of appeal are available?

The defendant has the right to appeal an indicting decision of the Judicial Council when charged with a serious crime (felony), but only on specific procedural or legal grounds pursuant to Article 478 of the Code of Criminal Procedure. This appeal must be filed within 10 days of the date on which the decision is served on the defendant.

The grounds for an appeal against a decision issued by the Judicial Council are, according to Article 478 of the Code of Criminal Procedure:

• absolute invalidity; and
• incorrect interpretation or application of a fundamental criminal law.

Revocation of a judgment may be sought on the grounds of:

• absolute procedural invalidity during the trial process;
• incorrect interpretation or application of a fundamental provision of criminal law;
• violation of the principles of res judicata or lis pendens;
• lack of specific and adequate reasoning in the court's decision;
• unlawful dismissal of an appeal as inadmissible; and
• abuse of judicial power by the court.

The defendant also has the right to appeal against convicting decisions of all courts under the terms set by Article 489 of the Code of Criminal Procedure – for example, decisions of the Three-Member Misdemeanour Court may be appealed by the defendant if they have been sentenced to:

• imprisonment for a term exceeding eight months; or
• a pecuniary sentence higher than €8,000.

Decisions of the Single-Member or Three-Member Court of Appeal may be appealed by the defendant if they have been sentenced to imprisonment for a term exceeding:

• three years for a felony; or
• two years for a misdemeanour offence.

The defendant has the right to appeal by way of cassation against a conviction within 20 days of registration of the decision at the Official Registry of the Court (Articles 505 and 473(2) of the Code of Criminal Procedure) by serving their appeal on the prosecutor of the Supreme Court (Articles 473 of the Code of Criminal Procedure).

The Court of Cassation reviews only errors of law, as explicitly enumerated in Article 510 of the Code of Criminal Procedure, such as:

• infringement of procedural provisions on pain of nullity in the course of the trial;
• violation of the public character of the trial hearing; or
• lack of sufficient reasoning of the court's decision.

7 Alternatives to prosecution

7.1 What alternatives to criminal prosecution are available where the authorities find evidence of white collar crime?

Greek law provides several alternatives to full criminal prosecution in white-collar crime cases:

• criminal conciliation (Articles 301–302 of the Code of Criminal Procedure);
• criminal negotiation (Article 303 of the Code of Criminal Procedure); and
• administrative settlement in tax offences.

7.2 What procedures are involved in concluding an investigation in this way?

Criminal conciliation: This is initiated upon the defendant's request to the competent public prosecutor, either before or after completion of the main or preliminary investigation. In this process, the defendant's confession is exchanged for a reduced sentence, provided that the victim is fully compensated. The public prosecutor then summons the parties involved, together with their attorneys, and grants a 15-day deadline to prepare a conciliation statement. If the parties reach an agreement, they sign the statement and the competent public prosecutor sends it to the prosecutor of the Court of Appeal, who submits the case to the Single-Member Court of Appeal, which in turn issues a reduced sentence to the defendant.

Criminal negotiation: This is also initiated at the defendant's request, either:

• before the conclusion of the main or preliminary investigation; or
• at the hearing, prior to commencement of the presentation of evidence.

The public prosecutor is not obliged to initiate a negotiation procedure where the defendant submits a petition and in fact may decide not to proceed if, in their view, a negotiated sentence is not warranted in this case. Five days after the conclusion of the negotiation statement, the case is brought before the single-member misdemeanour court or the single-member court of felonies respectively. The court hearing the case will declare the defendant guilty on the basis of the confession made in the negotiation statement but may improve the legal classification of the offence to the benefit of the defendant.

Most importantly, the scope of the negotiation is limited solely to the sentence; the charges themselves cannot be altered. Thus, negotiations in Greece constitute sentence bargaining, not charge bargaining.

Administrative settlement: This is a widely utilised mechanism in the context of tax-related white-collar offences in Greece. In such cases, the initiation of criminal prosecution may be suspended upon the full repayment of assessed tax liabilities, in accordance with the applicable provisions of tax legislation.

Pursuant to Article 16 of Law 4714/2020, a committee has been established within the General Secretariat for Tax Policy and Public Property for the purpose of facilitating the extrajudicial resolution of pending tax disputes before:

• the Council of State; and
• the regular administrative courts.

The committee operates under the supervision of a general director, who is a former senior judicial officer.

Taxpayers involved in unresolved tax disputes took advantage of this mechanism and submitted an electronic application for extrajudicial settlement. Eligible cases include:

• those not yet adjudicated; and
• those in which new factual evidence, jurisprudential developments or final criminal court decisions have emerged.

Applications must be filed through legal counsel and may invoke specific legal grounds, such as:

• the statute of limitations;
• manifestly erroneous tax assessments;
• the retroactive application of more lenient tax sanctions; or
• grounds for reduction of surcharges and penalties.

The committee must complete its examination of submitted applications by 31 July 2025, with final settlement reports to be issued no later than 30 September 2025. While a case is pending before the committee, proceedings before the competent administrative courts are suspended, except in relation to interim judicial protection.

7.3 What factors will determine whether such alternatives to prosecution are to be offered to those who have been involved in white collar crime?

The success of conciliation or negotiation depends on whether the offence under investigation falls under the cases that allow for this procedure.

Conciliation: This may be initiated for the following felonies:

• forgery (Articles 216(4) and (5) of the Criminal Code);
• false certification of an official document (Articles 242(3), (4) and (5) of the Criminal Code);
• non-violent or threatening offences against property or assets (ie, grand theft) (Article 374 of the Criminal Code);
• embezzlement of more than €120,000 (Articles 375(2) and (3) of the Criminal Code);
• fraud and computer fraud exceeding €120,000 (Articles 386(1)(b), 386A(1)(b) and 386(2) of the Criminal Code);
• fraud concerning grants exceeding €120,000 (Article 386B(1)(b) of the Criminal Code);
• breach of trust exceeding €120,000 (Articles 390(1)(b) and 390(2) of the Criminal Code);
• false solemn declaration whereby the perpetrator intended to obtain a financial benefit of more than €75,000 (Article 22(6)(b) of Law 1599/1986);
• fraud against EU funds (Article 4 of Law 2803/2000);
• smuggling/trafficking exceeding €150,000 (Article 157(1)(c) of Law 2960/2001);
• money laundering (Law 4557/2018); and
• tax evasion (Article 79 of Law 5104/2024).

Conciliation: This is also allowed for the following misdemeanours:

• forgery (Articles 216(1) and (2) of the Criminal Code);
• false certification (Article 242(1) of the Criminal Code);
• violation of the law on solemn declarations (Law 1599/1986);
• violation of the law on community fraud (Law 2803/2000);
• misdemeanour breaches of the Customs Code (Law 2960/2001);
• money laundering (Law 4557/2018);
• misdemeanour (minor) cases of tax evasion (Law 4173/2013); and
• non-violent misdemeanours committed against assets and property.

Negotiation: This is allowed for all criminal offences – both felonies and misdemeanours – which are prosecuted ex officio, subject to certain explicit exceptions.

More specifically, negotiation cannot be initiated on felonies that are:

• subject to a life sentence; or
• provided for in Article 187A of the Criminal Code (ie, terrorist acts).

Administrative settlement: This:

• is allowed in pending cases before the Council of State and the regular administrative courts; and
• must concern disputes arising from:
• • the imposition of taxes; or
  • fines issued under tax legislation.

7.4 How common are these alternatives to prosecution? What, if anything, could lead to an increase in their use?

Criminal conciliation and negotiation, though established within the Greek legal framework as alternative mechanisms to traditional criminal prosecution, have thus far seen limited practical application. They are predominantly confined to cases involving financial misconduct or property-related offences where full restitution is achievable. Their underutilisation is attributable to institutional hesitation, particularly among legal practitioners and prosecutorial authorities, to actively engage with or promote these procedures.

Recent legislative initiatives – notably Law 5090/2024 – have sought to address this inertia by:

• broadening the scope of eligible offences; and
• streamlining procedural requirements.

These reforms aim to enhance the functional utility of plea-bargaining mechanisms and incentivise their adoption, especially in complex economic and white-collar crime cases in which judicial efficiency and restitution are prioritised.

Notwithstanding recent legislative advancements, the practical implementation of criminal conciliation and negotiation remains in an embryonic stage. Their utilisation is gradually increasing; for these mechanisms to be fully integrated as standard instruments within the Greek criminal justice system, ongoing institutional adaptation and the development of consistent jurisprudential guidance are essential.

8 Private enforcement

8.1 Are private enforcement actions for white collar crims available in your jurisdiction? If so, where are they brought and what process do they follow?

Private enforcement mechanisms are available in Greece, mainly through civil litigation and, in some cases, private complaints. In the case of certain categories of offences – especially where prosecution is not initiated ex officio – individuals may initiate private criminal proceedings by submitting a criminal complaint to the prosecutor. However, for most serious white-collar crimes (eg, large-scale fraud, tax evasion), prosecution is typically public and initiated by the state.

Civil enforcement in Greece may involve the private pursuit of claims, such as a civil action initiated by a natural or legal person against another party seeking compensation for damages resulting from misconduct, including:

• fraud;
• embezzlement; or
• breach of trust.

Depending on the nature and monetary value of the dispute, first-instance civil cases are heard by either a single-member or multi-member court of first instance.

Following recent amendments to the Code of Civil Procedure, civil litigation is now predominantly conducted in writing. The claimant must file a lawsuit before the competent court, seeking full compensation for pecuniary and non-pecuniary (moral) damages. Both parties must submit their respective pleadings and evidence within 120 days of the date on which the lawsuit is filed. The claimant must substantiate the legal and factual basis of the claim, while the defendant is expected to raise any objections or defences.

Once the initial exchanges are complete, the claimant has the right to submit a rebuttal to address any new allegations raised by the defendant. The case file is then considered closed. In accordance with the new procedural framework:

• court hearings are largely formal; and
• oral arguments are typically not presented.

The court will subsequently examine the written submissions and evidence contained in the case file and issue a reasoned judgment. The decision may either:

• uphold the claim in whole or in part, thus awarding the claimant the corresponding amount of compensation; or
• dismiss the action based on procedural or substantive grounds.

In parallel, administrative enforcement is frequently used in relation to offences such as:

• tax evasion;
• subsidy fraud;
• money laundering;
• securities fraud;
• bribery; and
• competition law violations (eg, cartels).

These measures are imposed by competent regulatory authorities, depending on the nature and status of the entity involved. These may include:

• the Hellenic Capital Market Commission (for securities and market abuse cases);
• the Independent Authority for Public Revenue (for tax-related offences);
• the Ministry of Finance, including its specialised units;
• the Hellenic Competition Commission (for competition violations); and
• other supervisory bodies regulating specific sectors.

As a general principle, the agency responsible for overseeing the licensing, registration or regulatory compliance of a given entity is also empowered to impose administrative sanctions, such as:

• fines;
• licence suspensions or revocations; and
• publication of infringements.

These forms of enforcement:

• operate independently of, or in parallel with, criminal proceedings; and
• may result in significant financial and reputational consequences for the entity involved.

While not enforcement in the strict sense, internal corporate investigations may be conducted by private entities in response to suspected misconduct. The findings can lead to:

• disciplinary action;
• civil lawsuits; or
• voluntary disclosure to public authorities.

8.2 What types of relief may be sought and what types of relief are most commonly awarded? How is the relief to be awarded determined?

In the context of civil enforcement proceedings arising from white-collar crime in Greece, claimants may seek a variety of remedies depending on the nature and extent of the harm suffered. The most common types of relief include:

• pecuniary damages;
• moral damages; and
• in certain cases, restitution or injunctive relief.

Pecuniary damages encompass compensation for actual losses and loss of profits directly attributable to the defendant's unlawful conduct. Moral damages may also be awarded in cases where the claimant has suffered non-material harm, such as reputational damage, mental anguish or emotional distress – particularly in cases involving:

• fraud;
• breach of trust; or
• defamation.

Restitution may be granted where the unlawful act has resulted in unjust enrichment or the misappropriation of assets, with the court ordering the return of such assets or restoration of the status quo ante. Although less frequently invoked, injunctive relief is available in the form of interim measures to:

• preserve assets;
• prevent further harm; or
• secure the claim pending final adjudication.

The determination of the relief to be awarded is based on the evidentiary submissions of the parties, including:

• documentation of losses; and
• demonstration of a causal nexus between the act and the damage.

In moral damage claims, the amount awarded lies within the court's discretion, as no statutory guidelines prescribe fixed compensation levels.

Pursuant to recent amendments to the Code of Civil Procedure, civil proceedings in Greece are conducted primarily in writing. The claimant must file a lawsuit before the competent court and both parties must submit their pleadings and supporting arguments within specified timeframes. The court then assesses the case file and issues a judgment either:

• awarding full or partial relief; or
• dismissing the claim on procedural or substantive grounds.

8.3 Can the decision in a private enforcement action be appealed? If so, how?

The party which lost the case has a right to appeal. The party that won the first-instance trial may file for an appeal only if it has a legitimate interest. The appeal must be filed within 30 days of service of the contested decision on the other party (or 60 days if the respondent is a foreign resident or its residency is unknown).

The deadline for filing for an appeal, if the first-instance decision is not served, is two years, beginning from the date of its publication aiming to a timely and binding res judicata in order to speed up the administration of justice in its entirety.

The deadline for filing an appeal, as well as the right to appeal, assuming that is taking place legally and on time, prevents execution of the contested judgment, except where the first-instance judgment has been declared provisionally enforceable by the Court of First Instance.

To exercise the right to appeal, the appellant must pay a deposit.

Judgments of the single-member Court of First Instance are contested in the single-member Court of Appeals; while judgments of the single-member Court of Appeals are contested in the three-member Court of Appeals.

Judgments of the Court of the Peace, Court of First Instance and Court of Appeal are challenged before the Supreme Court through a cassation procedure. Cassation is an appeal which disputes a court judgment in substance due to legal defects. Cassation is permitted only on the grounds mentioned in the restrictive provisions of Article 559(1) of the Code of Civil Procedure.

If the appellant is a Greek resident, the deadline for a cassation is 30 days from the date of serving the contested judgment; while if it is a foreign resident, the deadline is 60 days. If the judgment is not served, the deadline is two years, beginning from the date of publication of the judgment which terminates the trial. However, with the exclusion of matrimonial cases, the deadline for cassation and the effect of the cassation do not inhibit execution of the relevant judgment.

9 Cyber issues

9.1 How do the white collar crime laws dovetail with cyber laws in your jurisdiction?

Greece ratified the Budapest Convention on Cybercrime through Law 4411/2016 and has enacted specific legislation criminalising:

• hacking;
• illegal interception;
• data interference; and
• computer-related forgery.

These laws set out the necessary technical and procedural mechanisms to investigate offences that intersect with white-collar crimes perpetrated via digital means.

Pursuant to the harmonisation of national legislation, specific conduct has been criminalised in accordance with relevant international standards. The newly enacted Criminal Code incorporates numerous provisions addressing the issue of cybercrime, including but not limited to:

• unlawful access to a computer system;
• deployment of malicious software;
• dissemination of unsolicited electronic communications (spam);
• denial-of-service attacks and obstruction of information system operations;
• interception of personal data in the context of electronic phishing (Article 292B);
• obstruction of telecommunications (Article 293);
• infringement of privacy and confidentiality of communications (Article 370);
• violations of the confidentiality of telephone communications and oral conversations;
• unauthorised access to information systems (hacking);
• breaches of state, scientific, professional or business secrets in both the public and private sectors;
• unlawful access to telecommunications systems (Articles 370A, 370B, 370C and 370D); and
• computer-related fraud (Article 386A).

Furthermore, several legislative enactments contain complementary provisions related to cybercrime offences. These include:

• Law 4177/2013, which criminalises the fraudulent manipulation or alteration of software embedded in measuring instruments;
• Law 4002/2011, which penalises the organisation or operation of gambling activities without the requisite licences or certifications; and
• Law 4443/2016, which addresses the dissemination via mass media and the Internet of false or misleading information concerning the supply, demand or pricing of financial instruments.

This legislative framework:

• ensures comprehensive coverage of cybercrime conduct; and
• facilitates the effective prosecution and adjudication of offences that intersect with the digital and white-collar crime domains.

9.2 What specific considerations, concerns and best practices should companies be aware of with regard to white collar crime prevention in the cyber sphere?

In the context of the increasing risks associated with financial cybercrime, it is essential for businesses operating in Greece to adopt and maintain comprehensive internal control mechanisms and advanced information security systems.

Specifically, the implementation of a sound and effective internal control system, consistent with international best practices and the regulatory framework applicable in Greece (including relevant guidelines issued by the Hellenic Capital Market Commission and the Hellenic Data Protection Authority), should aim to:

• identify in advance any vulnerabilities or operational gaps in the company's electronic infrastructure; and
• timely inform the management so that appropriate preventive and corrective measures may be adopted to safeguard the legal entity, its management bodies (eg, the board of directors) and its legal representatives from exposure to cybercrime-related liabilities.

From a technical compliance perspective, every legal entity is advised to:

• install and regularly update anti-spyware, antivirus and firewall software;
• implement access control systems and secure authentication mechanisms;
• comply with data protection obligations as set forth in Law 4624/2019, which incorporates the General Data Protection Regulation (2016/679); and
• conduct regular IT audits and risk assessments, especially when processing sensitive financial or personal data.

These measures are essential for both regulatory compliance and the mitigation of civil, administrative and criminal liability associated with cyber incidents, particularly in cases involving white-collar offences such as fraud, embezzlement or unauthorised access to information systems, as criminalised under Articles 292B, 386A and related provisions of the Criminal Code.

10 Trends and predictions

10.1 How would you describe the current white collar crime enforcement landscape and prevailing trends in your jurisdiction? Are any new developments anticipated in the next 12 months, including any proposed legislative reforms?

In recent years, Greece has significantly strengthened its white-collar crime enforcement framework through legislative reforms and institutional modernisation. Law 5090/2024 introduced a hybrid model of corporate criminal liability, enabling the prosecution of legal entities involved in bribery, with penalties ranging from substantial fines to exclusion from public procurement. Anti-money laundering provisions have been reinforced, particularly through amendments to Law 4557/2018, aligning Greek law with evolving EU standards.

Institutionally, enforcement capacity has been bolstered with the establishment of the Directorate for Combating Organised Crime, tasked with investigating serious financial offences. The European Public Prosecutor's Office has also played an increasingly active role in prosecuting fraud affecting EU interests.

In terms of future developments, the operationalisation of the EU Anti-Money Laundering Authority is expected to further influence Greece's regulatory landscape. Additionally, there is a growing trend towards the integration of AI for the detection of financial misconduct and the promotion of internal corporate investigations in accordance with Law 4706/2020 on corporate governance.

While these developments mark a significant evolution, the practical implementation of enforcement remains a work in progress, with emphasis on proactive compliance and institutional cooperation.

10.2 What high-profile white collar crime cases have arisen in your jurisdiction in recent times?

• The Siemens scandal centred on allegations that multinational corporation Siemens engaged in systematic bribery of Greek government officials to secure lucrative public contracts. These contracts spanned various sectors, including:
• • communication systems;
  • medical equipment; and
  • military hardware.
• Investigations revealed that Siemens paid substantial kickbacks to influence contract awards, undermining fair competition and public trust. The scandal sparked widespread public outrage, leading to extensive legal proceedings against company executives and public officials implicated in the corruption scheme. The case highlighted:
• • the challenges of combating corporate corruption; and
  • the need for stronger regulatory oversight in Greece.
• The Proton Bank scandal involved the principal shareholder and his associates, who exploited their positions within the bank to authorise loans totalling approximately €701 million to companies directly or indirectly controlled by the principal shareholder. These loans were issued without adequate collateral or guarantees and carried an exceptionally high credit risk, resulting in significant harm to the bank. The defendants allegedly concealed from regulatory authorities and shareholders that the loans were extended to interconnected entities, thereby masking the existence of a single consolidated credit risk. Consequently, regulators and shareholders were misled into believing that the lending activities complied with applicable banking regulations, while they breached fundamental rules concerning credit risk concentration.
• The arms scandal concerned allegations of corruption involving political and government officials in connection with contracts for the supply of military equipment. According to the prosecutorial report, assets amounting to CHF 16.2 million were concealed as proceeds of passive corruption involving a former government minister. Furthermore, the investigation revealed that bribes totalling CHF 2.9 million were paid in relation to contracts for submarines, characterised as illegal fees.
• The Hellenic Society for the Protection of Intellectual Property (AEPI) scandal, which emerged in 2017, involved serious financial misconduct by the management of Greece's main copyright collection society. An audit ordered by the Ministry of Culture revealed that between 2011 and 2014, over €42 million in royalties were not distributed to rights holders. The findings also included:
• • unauthorised loans to board members;
  • excessive salaries; and
  • other irregularities.
• In 2018, criminal charges for embezzlement and breach of trust exceeding €30 million were brought against the president and other board members. The AEPI's operating licence was revoked and a state-managed entity (the Special Service of Emergency Rights Management) was established to replace it. The trial began in October 2024 and is ongoing. The case has had significant repercussions on copyright governance, leading to broader reforms in Greece's collective rights management sector.

11 Tips and traps

11.1 What are your top tips for the smooth implementation of a robust compliance programme and what potential sticking points would you highlight?

To ensure the successful implementation of a robust compliance programme, organisations must actively cultivate a strong compliance culture rather than treating compliance as a mere procedural formality. Critical elements of such a culture include:

• leadership commitment at all levels;
• comprehensive risk management frameworks;
• clear, well-documented policies and procedures;
• regular and mandatory employee training;
• protection mechanisms for whistleblowers; and
• continuous monitoring and auditing activities.

Additionally, compliance programmes should be subject to regular review and updates to remain effective. Common challenges to effective implementation include:

• limited resources;
• insufficient enforcement;
• cultural resistance within the organisation;
• complexities arising from global operations; and
• evolving technological demands.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.