Greece

Global sanctions guide

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  1. Does Greece have a sanctions regime in place? 

Yes. Greece is a member of the UN and the EU. EU Regulations have direct effect in Greece and UN resolutions are incorporated into national law pursuant to Law 92/1967 and Law 4072/2012 (which relate to external trade).

In the most part, UN sanctions are implemented via presidential decrees or ministerial decisions and published in the Governmental Gazette. Occasionally, they are implemented by national legislation where UN quasi-legislative provisions need to be clarified and the elements of the criminal offence need to be set out specifically. National legislation is only required when a more solid ground for implementation is necessary. For example, Law 3251/2004 qualifies certain criminal offences as terrorist acts punishable by severe penalties. Respective sanctions are provided also in Law 3691/2008 on the prevention of money laundering activities and the financing of terrorism by Parliament in May 2017 regarding money laundering, which, among other provisions would ratify the Convention of Warsaw 2005 on “Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism”.

  1. Does Greece implement UN sanctions? 

Yes.

  1. Does Greece implement an autonomous sanctions regime? 

No.

  1. What is the nature of the sanctions regime in Greece? 

International financial sanctions are imposed by virtue of EU regulations (on the basis of UNSC resolutions or autonomous EU resolutions) which are directly effective. The Financial Sanctions Unit disseminates the relevant Resolutions and Regulations and introduces any relevant lists to all obligated persons.

  1. Does Greece maintain a list of sanctioned individuals and entities? 

No. Greece relies on the EU consolidated list.

  1. Are there any other lists related to sanctions? 

No.

  1. Does Greece have a licensing or authorization system in place? 

No. However, the General Directorate of Policy Planning and Administration of the Ministry of Economy and Finance is able to authorise exceptions in relation to export embargos.

  1. What are the consequences for a breach of sanctions in Greece? 

A violation of sanctions implemented by presidential decree carries a sentence of up to five years imprisonment, a monetary fine, or both.

A violation of measures relating to the export and import of trade that have been implemented into national legislation can result in administrative penalties, ranging from the exclusion from the market for up to one year to a monetary fine up to EUR100,000. For some cases, the law even provides for imprisonment of up to five years and monetary penalties.

  1. Who are the relevant regulators in Greece and what are their contact details?

Sanctions / Freezing of Assets

Hellenic Anti-Money Laundering, Counter-Terrorist Financing and Source of Funds Investigation Authority
more specifically, the Financial Sanctions Unit Against Terrorist Suspects (Unit B).

T: (+30) 210 340 1933
W: www.hellenic-fiu.gr


Import / Export Restrictions

Ministry of Development and Competitiveness, General Directorate of International Economic Policy, Directorate of Import-Export Regimes and Trade Instruments

Ermou and Kornarou
1 Athens 105 63
Greece

T: (+30) 210 328 6021, +30 328 6022, +30 328 6037
F: (+30) 210 328 6094
E: e3@mnec.gr, e3a@mnec.gr

Contributor law firm

Zepos & Yannopoulos, 280 Kifissias Ave. 152 32 Halandri, Greece

T: (+30) 210 696 7000
F: (+30) 210 69 94 640
d.zepos@zeya.com
www.zeya.com