Greece

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1. Does Greece have a sanctions regime in place?

Yes. Greece, as a member of the UN and the EU, is bound to implement restrictive measures (sanctions), by virtue of the UN Charter (Arts. 25 and 41), the EU Treaties and L. 92/1967.

Greece, in the context of combating terrorist financing, implements UN Resolutions imposing sanctions into domestic law.

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 offense need to be set out specifically. National legislation is only required when a more solid ground for implementation is necessary. The recently issued L. 4557/2018, the new Anti-Money Laundering Law, entitled “Prevention and suppression of the legalisation of proceeds of crime and terrorist financing and other provisions” (Arts. 43 and 47 thereof) provides for the implementation procedure of the sanctions imposed by international organisations (Arts 58-59 of Directive 2015/849/EU). Moreover, EU Regulations have a direct effect in Greece and, therefore, all the EU sanctions (on the basis of UNSC Resolutions or autonomous EU Decisions and Regulations) are directly applicable.

2. Does Greece implement UN sanctions?

Yes.

3. Does Greece implement an autonomous sanctions regime?

No.

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

The Financial Sanctions Unit (FSU) of the Hellenic Anti-Money Laundering Authority disseminates the relevant Resolutions and Regulations and introduces any relevant lists to all obligated persons. The financial sanctions that can be imposed include: the freezing of assets (funds and economic resources) of individuals, groups or entities listed in the relevant EU Regulations and UNSC Resolutions, as well as the ones that are defined by the FSU itself; the blocking of financial assets or any other property owned by the persons and entities listed; the prohibition of making assets (funds, economic resources or any other asset that could be used as a source of profit) directly or indirectly available for the benefit of the abovementioned persons. The trade sanctions, for which the Directorate for Trade Regimes and Defense Instruments is the competent authority) include trade restrictions and especially arms embargos and the control of exports of dual-use items. Movement restrictions of certain individuals, such as restrictions on admission (travel bans) are also in place.

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

The Ministry of Foreign Affairs forwards the abovementioned Regulations and Resolutions as well as the amending or revision Resolutions thereof immediately after their issuance, to the Financial Sanctions Unit, which maintains a detailed list of sanctioned individuals and entities. The Unit is entitled to forward the relevant lists to public authorities that keep records and possibly have information for the identification of the said persons or their assets.

6. Are there any other lists related to sanctions?

No.

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

No. However, it is important to be noted that the Financial Sanctions Unit of the Hellenic Anti-Money Laundering Authority is able to authorise exceptions in relation to imposed sanctions (for reasons such as satisfaction of basic needs, expenses related to legal aid of the affected individuals etc).

8. 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.

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

Sanctions / Freezing of Assets Hellenic Anti-Money Laundering Authority Unit B- Financial Sanctions Unit (FSU)

T: (+30) 210 340922

E: terror@hellenic-fiu.gr W: www.hellenic-fiu.gr

Import / Export Restrictions Ministry of Development and Investments, General Directorate of International Economic and Commercial Policy, Directorate for Trade Regimes and Defense Instruments (TEDI) 1 Kornarou str., GR 10563 Athens Greece T: (+30) 2103286223, 2103286036, 2103286037 F: (+30) 210 328 6094

Ministry of Foreign Affairs

1 Vasilissis Sofias str., GR 106 71 Athens Greece

T: (+30) 210 3681000 F: (+30) 210 3681717 W: https://www.mfa.gr/en/index.html

Contributor law firm

Dr. Stefanos Charaktiniotis, Partner

Antonis Giannakodimos, Senior Associate

Dimitris Zepos

Zepos & Yannopoulos,

280 Kifissias Ave.

152 32 Halandri

Athens

Greece

http://www.zeya.com

T: (+30) 210 6967 082

s.charaktiniotis@zeya.com

T: (+30) 210 6967 099

a.giannakodimos@zeya.com

E: d.zepos@zeya.com

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