Greece's anti-money laundering regime has undergone a significant legislative upgrade, aligning national rules more closely with the EU's evolving AML directives. Companies that have not yet audited their internal procedures face mounting regulatory exposure. Supervisory authorities – the Αρχή Καταπολέμησης της Νομιμοποίησης Εσόδων από Εγκληματικές Δραστηριότητες (Hellenic Anti-Money Laundering Authority, AMLC) and the Bank of Greece – are intensifying inspections across both financial and non-financial sectors.
Greece's updated anti-money laundering legislation, effective from early 2025, broadens the scope of obliged entities and strengthens know-your-customer (KYC) and beneficial owner verification requirements. Companies operating in affected sectors must complete internal compliance reviews and register or update their beneficial owner disclosures within the deadlines prescribed by the new rules. Failure to act exposes businesses to administrative sanctions, suspension of banking relationships, and reputational harm.
This alert identifies the key regulatory change, the categories of business most affected, the operative deadlines, and the immediate steps international companies should take.
What changed and when it takes effect
Greece transposed the most recent EU AML directive package into its domestic AML legislation with amendments that came into force in the first quarter of 2025. The changes are not merely procedural. They represent a substantive expansion of compliance obligations across three dimensions.
First, the definition of obliged entities has been widened. Real estate intermediaries, crypto-asset service providers, and certain high-value goods dealers now sit firmly within the AML perimeter alongside traditional financial institutions. Second, the threshold for enhanced due diligence has been lowered. Transactions and business relationships that previously fell below the enhanced scrutiny threshold may now trigger mandatory deeper review. Third, beneficial owner registration requirements have been tightened. Both the scope of information to be filed and the verification standard applied by the national registry have been raised.
The updated rules also reinforce correspondent banking controls. Greek banks conducting cross-border relationships must now apply more rigorous AML screening at the correspondent banking level, which directly affects foreign companies maintaining accounts or credit facilities with Greek institutions.
For detailed guidance on how these changes interact with Greece's banking and finance regulatory environment, see our overview of banking and finance law in Greece.
Who is affected and the compliance threshold criteria
The revised AML legislation in Greece applies to a broad set of obliged entities. International companies should assess whether their Greek operations, subsidiaries, or financial relationships fall within any of the following categories.
- Credit institutions and payment service providers operating in Greece
- Real estate agents and property developers facilitating transactions above prescribed thresholds
- Accountants, auditors, tax advisers, and legal professionals handling client funds or transactions
- Crypto-asset service providers registered or operating in Greece
- High-value goods dealers where cash transactions exceed regulatory thresholds
Companies that are not themselves obliged entities may still be affected indirectly. Greek banks have intensified their own KYC procedures in response to the new rules. Foreign businesses seeking to open a Greek bank account, renew a credit facility, or maintain correspondent banking arrangements should expect significantly more detailed documentary requests. Incomplete or outdated beneficial owner information is among the most frequent grounds for account suspension or denial of new banking services.
Threshold criteria are also relevant for enhanced due diligence triggers. Business relationships or transactions involving jurisdictions identified on Greece's high-risk country list – which mirrors the EU list – automatically attract enhanced scrutiny regardless of transaction value. Companies with ownership structures involving such jurisdictions must prepare consolidated KYC documentation in advance.
For companies active in capital markets, the intersection of AML obligations and market integrity rules introduces additional compliance layers. Our analysis of capital markets regulation in Greece covers these intersecting requirements in further detail.
To receive an expert assessment of your company's AML exposure in Greece, contact us at info@ferrazwhitmore.com.
Immediate actions required before the compliance deadline
Companies affected by the updated AML rules in Greece should treat the first half of 2025 as the operative compliance window. Supervisory authorities have indicated that enforcement activity will intensify following an initial period of guidance. The following steps reflect current regulatory expectations.
1. Audit your beneficial owner records. Verify that the beneficial owner information held in Greece's national beneficial owner registry is current, accurate, and consistent with your corporate structure. Discrepancies between the registry entry and actual ownership – including indirect or layered holdings – must be corrected without delay. The AMLC has the authority to cross-check registry data against bank-held KYC files.
2. Update your KYC documentation package. If your company maintains a Greek bank account or credit facility, prepare a full KYC refresh. This includes identification documents for all beneficial owners, organisational charts, source-of-funds documentation, and evidence of business activity. Banks are now required to validate this information periodically, not merely at account opening.
3. Appoint or confirm a compliance officer. Obliged entities must designate a named individual responsible for AML compliance. This person must have sufficient seniority and direct access to senior management. If your Greek entity has not formally appointed such an officer under the revised rules, this should be the first structural step.
4. Review transaction monitoring procedures. Internal controls for detecting suspicious transactions must be calibrated to the new thresholds. Procedures that were adequate under the prior regime may no longer satisfy the updated standard. A documented internal review of transaction monitoring rules – and their alignment with current Greek AML legislation – provides a defensible compliance record.
5. Assess correspondent banking relationships. If your company operates through a Greek correspondent bank or maintains cross-border payment channels involving Greek institutions, verify that your due diligence documentation meets the enhanced correspondent banking standards now required. Gaps in this area are among the most common triggers for transaction delays or relationship termination.
A practical comparison of the Greek AML update with the equivalent reforms recently implemented in Portugal is available in our alert on AML updates in Portugal. This may assist companies managing compliance across both jurisdictions simultaneously.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our banking and finance practice covers AML compliance, KYC programme design, beneficial owner registration, and regulatory engagement with supervisory authorities in Greece and across the EU. We advise international entrepreneurs, institutional investors, and in-house legal teams who need results-oriented counsel across multiple legal systems. Engaging a lawyer in Greece with cross-border AML experience is essential when regulatory timelines are tight and supervisory scrutiny is increasing. As an international law firm operating across Europe, Ferraz & Whitmore helps companies build defensible compliance structures efficiently and without unnecessary delays. To discuss your AML compliance position in Greece, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.