{"id":106304,"date":"2025-06-04T13:01:53","date_gmt":"2025-06-04T13:01:53","guid":{"rendered":"https:\/\/my.legal500.com\/guides\/?post_type=comparative_guide&#038;p=106304"},"modified":"2025-08-14T08:49:21","modified_gmt":"2025-08-14T08:49:21","slug":"greece-bribery-corruption","status":"publish","type":"comparative_guide","link":"https:\/\/my.legal500.com\/guides\/chapter\/greece-bribery-corruption\/","title":{"rendered":"Greece: Bribery &amp; Corruption"},"content":{"rendered":"","protected":false},"template":"","class_list":["post-106304","comparative_guide","type-comparative_guide","status-publish","hentry","guides-bribery-corruption","jurisdictions-greece"],"acf":[],"appp":{"post_list":{"below_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Anagnostopoulos<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2019\/01\/Anagnostopoulos-logo.jpg\"\/><\/span><\/div>"},"post_detail":{"above_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Anagnostopoulos<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2019\/01\/Anagnostopoulos-logo.jpg\"\/><\/span><\/div>","below_title":"<span class=\"guide-intro\">This country specific Q&amp;A provides an overview of Bribery &amp; Corruption laws and regulations applicable in Greece<\/span><div class=\"guide-content\"><div class=\"filter\">\r\n\r\n\t\t\t\t<input type=\"text\" placeholder=\"Search questions and answers...\" class=\"filter-container__search-field\">\r\n\t\t\t<\/div>\r\n\r\n\t\t\t\r\n\r\n\r\n\t\t\t<ol class=\"custom-counter\">\r\n\r\n\t\t\t\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What is the legal framework (legislation\/regulations) governing bribery and corruption in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Following continuous amendments of relevant legislation and ratification of all major international instruments against corruption (see below under 19), the main core of anti-corruption legislation is included in the Greek Criminal Code (punishable acts of bribery and corruption) and the Greek Code of Criminal Procedure (operation and powers of special Prosecutor\u2019s Office against Financial and Economic Crime). Special provisions in Law 5090\/2024 are in force regarding criminal liability of corporate entities.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Which authorities have jurisdiction to investigate and prosecute bribery and corruption in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The core investigation authority is the Prosecutor\u2019 Office against Financial and Economic Crime and the Special Body of Investigators for acts of corruption. The Prosecutor\u2019s Office against Financial and Economic Crime consists of 4 Prosecutors with the Court of Appeal, Athens and at least 8 Prosecutors with the First Instance Court (of which 7 serve the Athens First Instance Court and 1 Thessaloniki First Instance Court). The Prosecutor\u2019s Office against Financial and Economic Crime may engage other agencies or Authorities to provide assistance in specific fields or investigations which require special knowledge, such as the FECU (Financial and Economic Crime Unit), the Financial Police (special department within the Police) and the Directorate for Investigation of Economic Crime (supervised by the Ministry of Finance). The Prosecutor\u2019s Office against Financial and Economic Crime is informed about any complaints or allegations of corruption offences by other enforcement agencies or any other sources. Once informed of such allegations the Prosecutors have the power to decide whether these allegations\/complaints fall within the scope of their function. They also have the power to resolve any doubts or disagreements on jurisdiction over an allegation. The Prosecutor\u2019s Office against Financial and Economic Crime is responsible to collect first evidence on possible acts of corruption and then orders an investigation by the Special Investigators Body. The decision to refer cases of corruption to trial is decided\u2013 following standard procedure \u2013 by a Judicial Council (Three Judges having sessions in camera).<\/p>\n<p>Starting from June 21<sup>st<\/sup>, 2021, Greece has joined fully the European Public Prosecutor\u2019s Office (EPPO) making necessary adjustments to it internal legislation. The EPPO is responsible for investigating and prosecuting and bringing to judgment crimes against the financial interests of the EU, including corruption and money laundering. The EPPO, according to the relevant legal provisions, is solely competent to investigate and prosecute crimes against the financial interests of the EU and is awarded (within the Greek jurisdiction) all powers given to the Prosecutor\u2019s Office against Financial and Economic Crime.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How is \u2018bribery\u2019 or \u2018corruption\u2019 (or any equivalent) defined?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Under Greek Law passive and active bribery are both punishable. Bribery in the public sector (public officials) is an act of giving (or receiving) or promising (or accepting), directly or through third parties or intermediaries, unlawful benefits or gain to a public official for committing or omitting an act in the course of one\u2019s duties or against one\u2019s duties. The act of the public official maybe concluded or expected to be concluded in the future. Bribery in the private sector is an act of giving (or receiving) unlawful benefits or gain directly or indirectly as an exchange for an action or omission contrary to one\u2019s duties (as defined by law, contract, agreement etc.). It is noted that under Greek Law the promise of a benefit, gain etc. constitutes bribery (even before the gain or benefit has been awarded). Gains and benefits are not only cash\/cash equivalents but also intangible benefits (e.g. promotion or favourable transfer to a better position). The unlawfulness of such gains\/benefits is judged on an ad hoc basis. Generally, a benefit may be considered unlawful if it goes beyond the standards of proper social and\/or professional conduct. Although the legal provisions refer to \u201cbribery\u201d, they cover all sorts of gains and benefits and, actions or omissions that could be either illegal as such or legal but instigated in the context of a corrupt transaction.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Does the law distinguish between bribery of a public official and bribery of private persons? If so, how is 'public official' defined? Is a distinction made between a public official and a foreign public official? Are there different definitions for bribery of a public official and bribery of a private person?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There is a distinction between bribery of public officials and private persons. Both are punishable under Greek Law. A public official is a person entrusted permanently or temporarily with the exercise of duties directly related to the State or public law entities. The relevant provisions cover members of the judiciary (also arbitrators), members of international and transnational bodies, mayors and\/or members of local governments or local parliaments, members of international organizations, members of EU Bodies, individuals that exercise public service for a foreign country. It is noted that all provisions of Directive EU 2017\/1371 for the protection of EU\u2019s financial interests have been incorporated into Greek Law. Integration includes application of articles 235 (passive bribery) and 236 (active bribery) of the Greek Criminal Code to all EU officials irrespective of the seat of the organization or agency they work. As regards the Private Sector, the Greek Criminal Code provides for punishment of bribery (passive and active) of individuals who are involved in business activities (in any capacity) for actions or omissions contrary to someone\u2019s duties as defined by law, contract or the nature of one\u2019s position.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Who may be held liable for bribery?  Only individuals, or also corporate entities?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Liability as a general term may be refer to individuals and entities alike. Liability maybe criminal or civil liability. Criminal Liability: In principle, criminal liability applies to individuals. There are special provisions, however, for entities\u2019 liability within the context of criminal proceedings in relation to corruption offences (active bribery, bribery of judges, bribery of political persons, trading in influence). \u00a0The entity that has been involved in corruption acts and has benefited or gained from such acts may be the subject of criminal proceedings. The entity becomes party to the proceedings (pre-trial and trial) and may face penalties such as fines, suspension of operations, licensing termination etc., There are also provisions for liability of entities within the context of other proceedings, which take the form of fines and\/or administrative penalties. Civil Liability: Individuals and entities may be held liable in the course of civil proceedings. Individuals and entities may also be held liable in the course of independent proceedings conducted by other Regulatory Bodies (e.g. the Capital Market Commission, the Competition Commission, the Central Bank of Greece etc.)<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the civil consequences of bribery and corruption offences in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Civil consequences may arise either from provisions of the Greek Civil Code or the provisions included in the Civil Law Convention on Corruption in 2001 (Law No. 2957\/2001). Apart from seeking compensation, entities that have gained unlawful advantage or benefit through acts of bribery may face consequences such as annulment of agreements\/contracts and claims for related damages.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the criminal consequences of bribery and corruption offences in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Passive Bribery (applicable to individuals): The basic sanction for individuals in respect to passive bribery (the public officials) is imprisonment (maximum five years) and a fine. If the perpetrator is committing such acts by profession, the act is punishable with imprisonment up to 5 years (minimum sentence three years) and a fine. If the act is committed contrary to one\u2019s duties, there is provision for a prison sentence up to 10 years and a fine. If such acts (against the official&#8217;s duties) are committed by profession, the sentence is imprisonment up to 20 years (minimum sentence five years) and a fine. Active Bribery (applicable to individuals): The basic sanction is imprisonment (maximum five years). If the bribed official acted contrary to his or her duties the perpetration is the act is a felony punishable with imprisonment for up to 8 years (minimum sentence five years) and a fine. All assets and financial gains deriving from the punishable act are seized. Liability of entities: In the context of a criminal prosecutions entities face fines \u00a0ranging from \u20ac50,000 to \u20ac10 million; if the entity\u2019s annual net profit before tax exceeds the 10 mn \u20ac cap, the fine may be double the net profit before tax; permanent suspension of business activities or temporary suspension of such for a time period of one month to two years; prohibition of specific business activities (e.g., establishing new branches) for a time period of one month to two years; permanent or temporary ban (one month to two years) from public tenders or state funding. The fine is always imposed. As regards the rest of the sanctions, the competent Authorities may impose all of them or some of them depending on the degree of liability of the entity, the value of the unlawful gain, the financial status of the entity, damages caused to third parties, prior violations, the actions of the entity following the violation, in particular the conduct of an internal investigation, which contributed to the detection of the infringement etc. The above sanctions are independent of any other sanctions that may be imposed against the entity from the competent regulatory authorities in other proceedings (e.g., administrative\/disciplinary proceedings).<\/p>\n<p>There are also provisions for punishment (with lesser penalties) of managers or directors of entities who did not exercise due diligence to prevent acts of corruption by employees or individuals under their authority in favour of the entity. The entity may also be liable with fines of up to 5 mn \u20ac (or equal to the entity\u2019s net profit before tax if it exceeds the 5 mn \u20ac cap)<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Does the law place any restrictions on hospitality, travel and\/or entertainment expenses? Are there specific regulations restricting such expenses for foreign public officials?  Are there specific monetary limits for such expenses?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A comprehensive list of restrictions applicable to all businesses and activities is not in place, so there aren\u2019t any general rules in respect of certain expenses or specific threshold rules for such expenses. There are, however, restrictions or prohibitions in certain industries governed by special regulations or restrictions by the Accounting Regulation. In the field of healthcare, for example, specific rules are applicable in relation to these expenses while in other fields (e.g., public works) these are totally prohibited. The Law does not provide for minimum (or maximum) monetary limits, which would trigger application of anti-corruption laws. It is quite usual, however, for businesses that are heavily regulated (e.g., pharmaceuticals), to adopt unified guidelines against corruption such as setting monetary limits for business expenses. Considering that current accounting standards for businesses must follow a strict legal framework on Bookkeeping and expenses registration, expenses of high value or out of the ordinary would probably be irregular transactions from a tax law point of view. It is noted that in many businesses there is real-time monitoring of invoices by the Tax Authorities through special software.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are political contributions regulated? If so, please provide details.<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Political contributions are governed by Law 3023\/2002 (as amended). There are provisions for transparency of contributions, proper registration, publishing complete financial statements, restrictions in receiving funding, disclosures etc. Violations of these provisions are punishable with fines, suspension of sponsorships and, for certain type of offences, imprisonment for the individuals.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are facilitation payments prohibited or regulated? If not, what is the general approach to such payments?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Facilitation payments are prohibited. They are considered illegal not only in respect to anti-corruption laws and regulations but also in respect to taxation laws and regulations. These types of payments may not be registered in the books and records of a company, since they are not recognised by law.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any defences available to the bribery and corruption offences in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Under Greek Law it is the prosecuting authorities that collect evidence and prove their case but there is no system of evidence testing. Depending on the phase of the procedure (preliminary inquiry, investigation, preindictment) the prosecuting authorities need to satisfy general standards to enable further process of a case-file (usually the existence of enough evidence to justify further investigation or recommendation to open a formal investigation or recommendation for trial referral). The defendant is entitled to challenge the prosecuting authorities\u2019 case even at the earliest stages (during the preliminary inquiry and the investigation) on all points, i.e. points of law and on the merits. In view of this, the defendant is entitled to request from the authorities carrying out specific investigating actions, file documents, request examination of specific witnesses, request expert opinions etc. The investigating procedure (preliminary and official) is always reviewed by a Council of Judges (three judges), which is competent to examine any procedural objections raised by the defendant.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are compliance programs a mitigating factor to reduce\/eliminate liability for bribery and corruption offences in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The special provisions regarding entities\u2019 liability in bribery and corruption offences stipulate that if the entity discloses corruption acts following an internal investigation, this is taken under consideration in the process of determining the punishment. \u00a0This provision in addition to general provisions regarding mitigating factors, is sufficient basis to support defence arguments related to the compliance of the entity to its legal obligations through a compliance program and argue further on the degree of liability, which would result to sanctions on the lower side. The effectiveness and adequacy of a compliance program is evaluated in accordance with the company\u2019s operations, needs, size and the industry standards. Businesses under special regulation (eg financial or payment institutions) may have legal obligations to have in place a compliance program with certain features prescribed by law.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Has the government published any guidance advising how to comply with anti-bribery and corruption laws in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Several enforcement agencies and regulatory bodies have issued over the years guidelines in respect to anticorruption regulation, best practices, signs of irregularity of transactions etc. In addition to the guidelines issued by Regulatory Bodies (e.g. Bank of Greece, Hellenic FIU, Capital Market Commission), business associations in sensitive industries (e.g. healthcare) are proposing guidelines to their members, recommending best practices, evaluating market statistics, sharing experience from other jurisdictions etc.<\/p>\n<p>As regards the Public Sector and enforcement overview, the National Authority on Transparency is the competent Authority to develop action plans to combat corruption on a national level.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are mechanisms such as Deferred Prosecution Agreements (DPAs) or Non-Prosecution Agreements (NPAs) available for bribery and corruption offences in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There is a limited mechanism available for bribery and corruption offences applicable to individuals and entities. It is provided that the criminally liable party (defendant or involved entity) may request to enter negotiations with the Prosecutor only for the imposed sentence (primary or collateral). If the parties reach an agreement, the case is referred to a Court for the sentencing. The agreement is valid for the participating parties only. If there are more persons or entities involved in a case, the procedure continues for those not participating in the agreement.<\/p>\n<p>As regards NPAs, due to the general obligation of the Prosecutors to prosecute the offences, there is no provision for an Agreement. There is a provision (which resembles a NPA) regarding the suspension or non-prosecution of an individual if he\/she acts as a witness exposing corruption offences. This is a procedure initiated by the Prosecutor and validated by a Chamber of Judges.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Does the law in your jurisdiction provide protection to whistle-blowers? Do the authorities in your jurisdiction offer any incentives or rewards to whistle-blowers?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Protection of whistle-blowers is provided by law, in accordance with the DIRECTIVE (EU) 2019\/1937 for the protection of whistle-blowers.<\/p>\n<p>These provisions cover most aspects of whistle-blowers protection, starting from the time a person makes a complaint and thereafter. \u03a4here are provisions regarding protection of their personal, professional and employment status, protection against false prosecutions, defamatory practices, blacklisting, contract termination etc. There are also provisions for compensation for damages (before the civil courts) and penalties (imprisonment and fines) for those that violate the protective provisions of the Law. These provisions aim to support, protect, and compensate for damages of the whistleblower. Incentives, such as rewards, are not provided by law.<\/p>\n<p>From a criminal law perspective, the Greek Code of Criminal Procedure includes some provisions in respect to \u201cwitnesses of public interest\u201d. These provisions have been in place before changes in the legal framework of whistle-blowers protection and are applicable to individuals that offer substantial information on acts of corruption (of public officials). These individuals become \u201cwitnesses of public interest\u201d with an Order issued by the Financial and Economic Crime Prosecutors or the Deputy Prosecutor of the Supreme Court who supervises same Office. To achieve the status of a \u201cwitness of public interest\u201d one must not have any implication in the reported criminal acts and have no personal interest or benefit from his\/her testimony. As a \u201cwitness of public interest\u201d one can\u2019t be prosecuted for acts of defamation or violations of personal data law and regulations. In addition, there is protection against termination of one\u2019s working\/professional contract. If the Authorities believe that a \u201cwitness of public interest\u201d may be in danger, it is also provided that he\/she can achieve the status of an \u201canonymous witness\u201d following the procedure set out in the legislation governing organized crime.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Does the law in your jurisdiction enable individual wrongdoers to reach agreement with prosecutors to provide evidence\/information to assist an investigation or prosecution, in return for e.g. immunity or a reduced sentence?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Individuals involved in acts of bribery and corruption committed by public officials or members of the government are punished with a much lesser sentence, which may also be suspended (not served) provided that he\/she discloses crucial information regarding the misconduct of public officials or members of the government. This is applicable whether the individual is a public official or third party. The leniency proceedings are applicable once it is determined that the information provided is valid. If the information provided is determined to be false or misleading, the prosecution against the individual continues in accordance with the relevant provisions.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How common are government authority investigations into allegations of bribery? How effective are they in leading to prosecutions of individuals and corporates?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Under Greek Law the competent authorities for investigating allegations of bribery are under an obligation to initiate a preliminary inquiry as soon as they are informed on possible misconduct. This information may be a formal complaint, an anonymous tip or even information leaked to the Press. This is also the case for other criminal acts, so opening an investigation into allegations of bribery does not require exercising discretionary power by the authorities (whether to start an investigation or not) but normal progress of the procedure. Given that at least two Authorities are awarded power to investigate exclusively (Prosecutor\u2019s Office against Financial and Economic Crime) or primarily (the General Inspector of Public Administration) acts of corruption, it is evident that all relevant allegations are being investigated.<\/p>\n<p>Taking under consideration that inquiries into allegations for corruption offences trigger the initiation of other proceedings as well (targeted tax audits, money laundering investigations, regulatory compliance), findings from these proceedings can (and are) used to effectively prosecute corruption offences.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the recent and emerging trends in investigations and enforcement in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The competent Prosecuting Authorities (namely the Prosecutor\u2019s Office against Financial and Economic Crime) are very active in investigating cases of alleged bribery and have been targeting specific industries and sectors, such as the health industry, public works and financial institutions. In addition, the EU Public Prosecutor Office (EPPO) has initiated large-scale investigations, which include Greece, regarding funds distributed within the context of EU common agricultural policy and VAT returns of businesses related to intra-EU transactions.<\/p>\n<p>Above from the large-scale investigations and prosecutions there has also been a significant increase in investigating and prosecuting lower-level corruption offences, following formal complaints or information from other sources (e.g. tax authorities, suspicious transactions reports etc.) .<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a process of judicial review for challenging government authority action and decisions? If so, please describe the key features of this process and remedy.<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Depending on the type of procedure (criminal or administrative) and the phase of the investigation, inquiry etc. there are provisions with the Greek Code of Criminal Procedure as well as the Administrative Code of Procedure for judicial review of the authorities\u2019 decisions. As regards the criminal investigation of bribery acts, the whole investigation is reviewed at its conclusion by a Judicial Council (on points of law and procedural safeguards). Challenging decision and actions as they happen, however, may not be feasible, due to the fact that the Prosecutors against Financial and Economic Crimes (as well as the Special Investigators for corruption acts) are given extensive powers to seize, confiscate, gain access to privileged information etc. It is provided that all these actions may be challenged with the competent Judicial Council but review is done after these actions\/decisions have taken place.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Have there been any significant developments or reforms in this area in your jurisdiction over the past 12 months?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The most significant developments in the past months were a) the the inclusion of entities in criminal proceedings and b) the interoperability of data processing by various enforcement agencies (tax authorities, the Hellenic FIU, the Source of Funds Investigation Unit, the Financial Police etc.).<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any planned or potential developments or reforms of bribery and anti-corruption laws in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The core legal framework for corruption offences and related acts (money laundering, tax regulation) has been reformed repeatedly in the last years. The provisions for punishable acts, sanctions, fines and procedure have been amended many times. All provisions have been updated and amended to comply with EU laws and international standards.<\/p>\n<p>Following a series of new rules and regulations in respect of corporate governance, compliance and internal controls as well as whistle-blowers\u2019 protection and introduction of more effective proceedings of financial and tax audits, there is no plan (in the foreseeable future) for more changes.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To which international anti-corruption conventions is your country party?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Greece has ratified all major international anti-corruption conventions and has passed legal provisions to conform with them: The UN Convention Against Corruption (Law 3666\/2008); the Council of Europe Criminal Law Convention on Corruption and Additional Protocol (Law 3560\/2007); the Council of Europe Civil Law Convention on Corruption (Law 2957\/2001); the EU Convention on the Protection of the European Communities\u2019 Financial Interests (Law 2803\/2000); the EU Convention Against Corruption Involving Officials of the European Communities or Officials of Member States of the European Union (Official Journal C195 of June 25 1997) (Law 2802\/2000); and the Organisation for Economic Cooperation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Law 2656\/1998). In addition to the above, Greece complies with the EU policies against corruption in specific industries (e.g. public works) stipulated by EU Regulations or EU Directives. As of 27\/5\/2020 Greece has made necessary adjustments to its internal legislation in order to comply with Directive EU 2017\/1371 (Law 4689\/2020) in respect to the protection of EU financial interests, VAT fraud and bribery of EU officials.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do you have a concept of legal privilege in your jurisdiction which applies to lawyer-led investigations? If so, please provide details on the extent of that protection. Does it cover internal investigations carried out by in-house counsel?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Greek Law recognises the legal privilege and, also, provides for its protection. Lifting the legal privilege by prosecuting authorities is not done through the general provisions for accessing information considered privileged (financial, tax etc) but following different, special procedures. Legal privilege applies to anything the lawyer has known or obtained because of his\/her profession. In view of this, information acquired in lawyer-led investigations are, in principle, covered by legal privilege. There is uncertainty though in respect to the procedures to be followed during lawyer-led investigations either independently or within the context of an internal audit. In case of a dispute whether some information is connected to legal privilege, there are provisions for its resolution. These procedures take effect after securing\/seizing such information, so it is always important to indicate in relevant correspondence and\/or documents that they contain attorney-client privilege. The attorney-client privilege covers all attorneys (in-house and outside counsel) but may not be applicable in certain circumstances expressly provided by law.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How much importance does your government place on tackling bribery and corruption? How do you think your jurisdiction\u2019s approach to anti-bribery and corruption compares on an international scale?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Combating corruption is dealt as a standard priority in the government\u2019s agenda. The Public Sector is audited and monitored by a central enforcement agency and there is an update of the rules regarding anti-money laundering policies. A new set of rules regarding whistle-blowers\u2019 protection have been adopted band there has been a large reform of corporate governance laws to comply with all anti-corruption laws and regulations. Finally, new provisions have been introduced to enable the prosecuting authorities to respond to corruption practices instigated by entities by expanding their liability to involve criminal proceedings as well. Overall, there is constant effort to detect and prosecute corruption acts and all enforcement agencies have been very active in getting involved to relevant inquiries and investigations.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Generally, how serious are corporate organisations in your country about preventing bribery and corruption?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The consensus is that there is need to have in place and adhere to rules of transparency to prevent and detect possible corruption practices. Most medium\/large-sized entities have adjusted to AML and anti-corruption regulation putting in place compliance programmes and training executives and employees. Tax legislation, which provides for stricter rules in bookkeeping, payments and money transfers, combined with changes in AML legislation, also provide useful tools to organisations in their effort to abolish corruption practices. It is noted that certain industries have been more active in promoting best practices guidelines and monitoring of the market, especially those heavily regulated (eg banking institutions). Following the latest regulations on whistle-blowers\u2019 protection and corporate governance, most medium to large organisations have adjusted their operation to meet the legal requirements and adjust to guidelines and best practices provided by the regulatory authorities or the industry.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the biggest challenges businesses face when investigating bribery and corruption issues?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>When an investigation on bribery or corruption is done internally, an entity faces many dilemmas in many respects, i.e. monitoring, reporting, exposing and resolving issues internally or with the authorities. No business has the powers of an investigating authority; thus, it is bound by rules concerning privileges, private data protection, labour law restrictions etc. On the other hand, a business will need to consider how to handle information on bribery or corruption, the impact of reporting such information to the authorities and possible sanctions (criminal or civil) in the context of regulatory, investigating, prosecuting procedures.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the biggest challenges enforcement agencies\/regulators face when investigating and prosecuting cases of bribery and corruption in your jurisdiction? How have they sought to tackle these challenges?  What do you consider will be their areas of focus\/priority in the next 18 months?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Compliance with international agreements and incorporation of related provisions in Greek Law made available a sufficient toolbox to enforcement agencies to enable effective action against bribery and corruption. On the other hand, it is quite usual to have more than one procedures running in parallel eg criminal investigations running in parallel with tax audits and regulatory inquiries. In the context of different and \u2013 sometimes \u2013 incompatible procedures running at the same time, there have been occasions of contradicting enforcement decisions. Amended and new provisions regarding entity liability aim to set a specific framework applicable to entities that violate anti-corruption legislation by one competent authority and avoid multiple enforcement agencies\u2019 decisions for the same violation.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How have authorities in your jurisdiction sought to address the challenges presented by the significant increase of electronic data in either investigations or prosecutions into bribery and corruption offences?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Detection, recovery and use of electronic data is ruled by different provisions depending on the nature of the information. Electronic data regarding transactions are monitored within AML regulations and\/or tax regulations. This type of data is usually easy to retrieve and use following specific legal provisions (as a rule enforcement agencies investigating corruption offences are not bound by banking and tax privilege).<\/p>\n<p>When there is need to retrieve and process information from the cloud or local servers, there are provisions for seizing, copying or retrieving data from any means of storage (local restrictions or rules may apply in cross-border cases). Entities and individuals may also be legally forced to produce data, information or disclose the identity of the data holder, depending on the type of proceedings.<\/p>\n<p>Generally speaking, there are provisions that enable authorities to retrieve and use electronic data either locally stored or cloud stored and also monitor online traffic and streaming (where applicable). Since the volume of files and information digitally stored has increased significantly over the years, it will be important to have adequate resources to process this information.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What do you consider will be the most significant bribery and corruption-related challenges posed to businesses in your jurisdiction over the next 18 months?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Given that there is an ever-increasing demand for transparency in business operations and transactions, businesses will need to set-up effective compliance programs and internal procedures in accordance with the regulatory framework.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How would you improve the legal framework and process for preventing, investigating and prosecuting cases of bribery and corruption?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There is a multitude of legal provisions in respect to procedures and enforcement agencies, which have the power to investigate acts of corruption. Apart of criminal investigations, parallel proceedings may be initiated by Regulatory Bodies or the Tax Authorities. All these proceedings may result to different types of sanctions to individuals or entities, which can\u2019t be resolved, settled or terminated as a whole. The introduction of a new set of rules regarding entity liability aims to tackle some of these obstacles and it remains to be seen if it will work in real circumstances. The issue of regulatory sanctions though against individuals and entities remains unresolved, considering that Greek regulatory authorities tend to lean towards the maximum of the sanctions provided by law, which may result in severe punishment of an individual in both proceedings (criminal and regulatory).<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\r\n<div class=\"word-count-hidden\" style=\"display:none;\">Estimated word count: <span class=\"word-count\">5137<\/span><\/div>\r\n\r\n\t\t\t<\/ol>\r\n\r\n<script type=\"text\/javascript\" src=\"\/wp-content\/themes\/twentyseventeen\/src\/jquery\/components\/filter-guides.js\" async><\/script><\/div>"}},"_links":{"self":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide\/106304","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide"}],"about":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/types\/comparative_guide"}],"wp:attachment":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/media?parent=106304"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}