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Retail_Trading_Status

Allowed-Regulated Unknown
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Analysis ID
#184
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Archived
Created
2025-04-12 06:54
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Executive Summary

Retail cryptocurrency trading is permitted but regulated in Greece. The Hellenic Capital Market Commission (HCMC) is the primary regulator, requiring certain crypto service providers to register for AML/CTF compliance. Law 4734/2020, which amended Law 4557/2018, transposes the EU's Fifth Anti-Money Laundering Directive into Greek law. Greece is also subject to the Markets in Crypto-Assets Regulation (MiCA), with full implementation expected by December 30, 2024, and a transitional period extending to July 1, 2026, for existing CASPs registered with the HCMC.

Key Pillars

  • Primary Regulator: The Hellenic Capital Market Commission (HCMC) supervises crypto service providers, focusing on AML/CTF compliance.
  • Core Compliance: Registration with the HCMC requires compliance with AML/CTF requirements, including KYC procedures, reporting suspicious transactions, and appointing an AML Compliance Officer.
  • Licensing/Registration: Certain crypto service providers (exchanges between crypto and fiat, and custodian wallet providers) operating in or from Greece must register with the HCMC since January 2021. Full authorization under MiCA will be required starting December 30, 2024, with a transitional period until July 1, 2026, for those already registered with the HCMC.

Landmark Laws

  • Law 4734/2020: Transposes the EU's Fifth Anti-Money Laundering Directive (5AMLD) into Greek law, amending Law 4557/2018. Mandates AML/CTF supervision for certain crypto service providers.
  • Law 4557/2018: The main AML law in Greece, explicitly including providers engaged in exchange services between virtual currencies and fiat currencies, and custodian wallet providers, under its scope.
  • Regulation (EU) 2023/1114 (MiCA): Markets in Crypto-Assets Regulation. Key provisions related to stablecoins and e-money tokens began applying on June 30, 2024, with full regulation applying from December 30, 2024. Introduces a harmonized regulatory framework across the EU for crypto-asset issuers and service providers (CASPs).

Considerations

  • Cryptocurrencies are viewed primarily as portfolio assets, not legal tender.
  • The tax treatment of cryptocurrencies in Greece is somewhat unclear, with potential capital gains tax of 15% for individuals.
  • The Bank of Greece and HCMC have issued warnings about the risks associated with crypto investments, including volatility and potential loss of funds.
  • VAT exemption applies to the exchange between virtual and fiat currencies.

Notes

  • Interest in cryptocurrencies grew in Greece, partly due to the financial crisis of 2015 and declining trust in traditional banking.
  • Initially, the sector was largely unregulated, with the Bank of Greece issuing warnings as early as 2014.
  • Greece has opted for a 12-month transitional (grandfathering) period under MiCA for existing CASPs, allowing them potentially until July 1, 2026, to obtain MiCA authorization, provided they are registered with the HCMC.
  • The tax treatment of cryptocurrencies in Greece remains somewhat unclear due to the lack of specific guidelines.
  • HCMC Decision No. 5/898/3.12.2020 established a special registry for digital wallet providers and cryptocurrency exchanges to register their AML compliance policy.

Detailed Explanation

Retail trading of cryptocurrencies is permitted in Greece, though the sector is becoming increasingly regulated. No specific laws prohibit individuals from buying, selling, or holding cryptocurrencies. However, Greece lacks a comprehensive legal framework dedicated solely to crypto-assets beyond AML/CTF regulations. Existing financial regulations apply to cryptocurrency activities if they meet certain criteria, and specific requirements are imposed on service providers.

The Hellenic Capital Market Commission (HCMC) views cryptocurrencies primarily as portfolio assets, not legal tender. A significant regulatory step was the transposition of the EU's Fifth Anti-Money Laundering Directive (5AMLD) into Greek law via Law 4734/2020, amending Law 4557/2018 (the main AML law). This brought certain crypto service providers under AML/CTF supervision. Since January 2021, providers engaged in exchange services between virtual currencies and fiat currencies, and custodian wallet providers, operating in or from Greece must register with the HCMC. Registration focuses on AML/CTF compliance, including KYC procedures, reporting suspicious transactions, appointing an AML Compliance Officer, and maintaining adequate internal policies. Failure to register prohibits operation in Greece.

Greece, as an EU member state, is subject to the Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114). Key provisions related to stablecoins and e-money tokens began applying on June 30, 2024, with the full regulation, including authorization requirements for CASPs, set to apply from December 30, 2024. Greece has opted for a 12-month transitional (grandfathering) period under MiCA for existing CASPs already operating before December 30, 2024, allowing them potentially until July 1, 2026, to obtain MiCA authorization, provided they are registered with the HCMC. The HCMC is preparing for MiCA's implementation but has yet to release specific details on the local licensing process.

The tax treatment of cryptocurrencies in Greece remains somewhat unclear, but general interpretations suggest that capital gains from selling cryptocurrencies could be subject to a 15% capital gains tax for individuals, potentially plus a solidarity contribution for income above certain thresholds. VAT exemption applies to the exchange between virtual and fiat currencies, following an EU Court of Justice ruling, although specific Greek guidance is limited. The Bank of Greece and HCMC have issued warnings about the risks associated with crypto investments, including volatility and potential loss of funds. In 2014, the Bank of Greece issued warnings echoing European Banking Authority (EBA) concerns about risks like price volatility. HCMC Decision No. 5/898/3.12.2020 established a special registry for digital wallet providers and cryptocurrency exchanges to register their AML compliance policy.

Summary Points

**Retail Cryptocurrency Trading Status in Greece: Regulatory Analysis**

**I. Overall Regulatory Status:**

*   **Allowed-Regulated:** Retail trading (buying, selling, holding) of cryptocurrencies by individuals is permitted in Greece.
*   No specific laws prohibit ownership or trading by individuals.
*   The sector is not entirely unregulated; existing financial regulations apply if certain criteria are met.

**II. Key Regulatory Bodies and Their Roles:**

*   **Hellenic Capital Market Commission (HCMC):**
    *   Primary regulator for AML/CTF compliance for specific crypto service providers.
    *   Views cryptocurrencies primarily as portfolio assets.
    *   Responsible for registering and supervising crypto-to-fiat exchanges and custodian wallet providers.
    *   Preparing for MiCA implementation and will oversee authorization of CASPs.
*   **Bank of Greece (BoG):**
    *   Central Bank; has issued warnings about the risks associated with crypto investments (volatility, potential loss of funds).

**III. Important Legislation and Regulations:**

*   **Law 4557/2018 (as amended by Law 4734/2020):**
    *   Greek Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Law.
    *   Transposition of the EU's Fifth Anti-Money Laundering Directive (5AMLD).
    *   Brings crypto-to-fiat exchanges and custodian wallet providers under AML/CTF supervision.
*   **Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114):**
    *   EU regulation introducing a harmonized framework for crypto-asset issuers and service providers (CASPs).
    *   Key provisions related to stablecoins and e-money tokens applied from June 30, 2024.
    *   Full regulation, including authorization requirements for CASPs, applies from December 30, 2024.

**IV. Requirements for Compliance:**

*   **AML/CTF Compliance (for specific service providers):**
    *   Registration with the HCMC is mandatory for crypto-to-fiat exchanges and custodian wallet providers operating in or from Greece.
    *   Implementation of Know Your Customer (KYC) procedures.
    *   Reporting of suspicious transactions.
    *   Appointment of an AML Compliance Officer.
    *   Maintenance of adequate internal AML policies.
    *   Submission of detailed business information during registration (ownership, management, business plans, AML policies).
*   **MiCA Authorization (for CASPs):**
    *   CASPs will need authorization under MiCA to operate in the EU from December 30, 2024.
    *   Passporting rights to offer services across EU member states upon authorization.

**V. Notable Restrictions or Limitations:**

*   **HCMC Registration Requirement:** Crypto-to-fiat exchanges and custodian wallet providers are prohibited from operating in Greece without HCMC registration.
*   **MiCA Compliance:** CASPs must comply with MiCA regulations to operate legally in Greece and the EU.
*   **Tax Uncertainty:** The tax treatment of cryptocurrencies lacks specific guidelines, leading to uncertainty.

**VI. Recent Developments or Changes:**

*   **MiCA Implementation:** Greece is implementing MiCA, with key provisions already in effect and full implementation by December 30, 2024.
*   **Transitional Period under MiCA:** Greece has opted for a 12-month transitional (grandfathering) period for existing CASPs registered with the HCMC, potentially allowing them until July 1, 2026, to obtain MiCA authorization.
*   **HCMC Preparation for MiCA:** The HCMC is preparing for MiCA's implementation but has not yet released specific details on the local licensing process.

Full Analysis Report

Report: Retail Cryptocurrency Trading Status in Greece

Topic: Retail_Trading_Status
Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

1. Current Status: Allowed-Regulated

2. Narrative Explanation:

Retail trading (buying, selling, holding) of cryptocurrencies by individual citizens and residents is permitted in Greece. There are no specific laws prohibiting the ownership or trading of cryptocurrencies by individuals [5, 10]. However, the sector is not entirely unregulated. While Greece lacks a comprehensive, dedicated legal framework specifically for crypto-assets beyond AML/CTF rules [3, 6, 15], activities involving cryptocurrencies are subject to existing financial regulations if they meet certain criteria, and specific requirements apply to service providers [3, 4].

Historical Context & Regulatory Development:
* Interest in cryptocurrencies grew in Greece, partly due to the financial crisis of 2015 and declining trust in traditional banking [2].
* Initially, the sector was largely unregulated [2, 6]. The Bank of Greece issued warnings as early as 2014, echoing European Banking Authority (EBA) concerns about risks like price volatility [8, 19].
* The Hellenic Capital Market Commission (HCMC) views cryptocurrencies primarily as portfolio assets, not legal tender [2, 6, 11].
* A significant step towards regulation was the transposition of the EU's Fifth Anti-Money Laundering Directive (5AMLD) into Greek law via Law 4734/2020, amending Law 4557/2018 (the main AML law) [3, 11]. This brought certain crypto service providers under AML/CTF supervision.

Current Regulatory Landscape:
* AML/CTF Framework: Law 4557/2018, as amended, explicitly includes providers engaged in exchange services between virtual currencies and fiat currencies, and custodian wallet providers, under its scope [3, 7, 20]. These entities are designated as "obliged entities."
* HCMC Registration: Since January 2021, these specific crypto service providers (exchanges between crypto and fiat, and custodian wallet providers) operating in or from Greece must register with the HCMC [2, 4, 7, 16]. This registration focuses on ensuring compliance with AML/CTF requirements, including implementing Know Your Customer (KYC) procedures, reporting suspicious transactions, appointing an AML Compliance Officer, and maintaining adequate internal policies [2, 4, 7]. Registration requires submitting detailed information about the business, including ownership, management, business plans, and AML policies [2, 7]. Failure to register prohibits operation in Greece [3, 16]. The HCMC supervises the ongoing compliance of registered entities [3].
* MiCA Implementation: Greece, as an EU member state, is subject to the Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114) [4, 7, 15]. MiCA introduces a harmonized and comprehensive regulatory framework across the EU for crypto-asset issuers and service providers (CASPs) [4, 18]. Key provisions related to stablecoins and e-money tokens began applying on June 30, 2024, with the full regulation, including authorization requirements for CASPs, set to apply from December 30, 2024 [4, 7, 18]. CASPs will need authorization under MiCA to operate in the EU, benefiting from passporting rights to offer services across member states [4]. Greece has opted for a 12-month transitional (grandfathering) period under MiCA for existing CASPs already operating before December 30, 2024, allowing them potentially until July 1, 2026, to obtain MiCA authorization, provided they are registered with the HCMC [4, 9]. The HCMC is preparing for MiCA's implementation but has yet to release specific details on the local licensing process [3].
* Taxation: The tax treatment of cryptocurrencies in Greece remains somewhat unclear due to the lack of specific guidelines [5, 16, 19]. However, general interpretations suggest that capital gains from selling cryptocurrencies could be subject to a 15% capital gains tax for individuals, potentially plus a solidarity contribution for income above certain thresholds [5, 6, 16, 19]. VAT exemption applies to the exchange between virtual and fiat currencies, following an EU Court of Justice ruling, although specific Greek guidance is limited [5, 15]. Income from crypto mining is generally viewed as business profit, taxable at applicable rates after deducting costs, but official guidance is lacking [19].
* Consumer Protection: General consumer protection laws apply [3, 15]. The Bank of Greece and HCMC have issued warnings about the risks associated with crypto investments, including volatility and potential loss of funds [8].

In summary, while individuals can freely trade crypto, the environment is becoming increasingly regulated, particularly for service providers who must register with the HCMC for AML purposes and will soon need full authorization under MiCA.

3. Relevant Excerpts:

  • Manimama Law Firm: "In essence, cryptocurrency transactions are the responsibility of the individual conducting them... Despite this dynamic, the Greek government has yet to implement particular regulatory measures... As a consequence, digital asset markets are completely unregulated [Note: This statement seems slightly outdated given AML registration requirements]... Law 4734/2020... includes the following AML requirements: the obligation to apply KYC (know your client) measures; the obligation to report any suspicious transactions; and commitment to adopt and implement adequate AML internal policies... ​​A special registry has been established by HCMC Decision No. 5/898/3.12. 2020, in which all digital wallet providers and cryptocurrency exchanges must register certain information about their AML compliance policy..." [2]
  • CMS Law: "Strictly speaking, cryptoassets and cryptoasset services are not regulated in Greece [beyond AML/CTF]... The only regulation in respect of cryptoassets under Greek Law stems from the Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Law... Pursuant to Law 4557/2018, the HCMC is the AML and CTF supervisor for certain cryptoasset services providers in Greece. Certain cryptoasset service providers are prohibited from operating in Greece unless they are registered with the HCMC." [3]
  • Bernitsas Law Firm (Oct 2023): "The provision of crypto-related services is currently for the most part unregulated in Greece... Irrespective of whether a crypto asset qualifies as a financial instrument, entities wishing to provide exchange services between virtual currencies and flat currencies or provide custody services in relation to virtual currencies in from Greece should register with the Hellenic Capital Market Commission (HCMC) prior to the providing these services... Firms must also comply with the Greek AML Law..." [4]
  • Kryptos.io (2025 Guide): "As of now, there is no official legal status for cryptocurrencies in Greece. However, there are no regulations barring residents from using cryptocurrencies... Cryptocurrency taxation in Greece is somewhat uncertain. For individual investors, there's a general interpretation that profits from cryptocurrency sales could be subject to a 15% capital gains tax (CGT)." [5]
  • ICLG (Nov 2024): "For cryptocurrency assets, MiCA applies and its provisions will take effect on December 30, 2024... The scope of the Greek AML Law... encompasses providers engaged in exchange services between virtual currencies and fiat currencies (cryptocurrency exchange) and custodian digital wallet providers. In this framework, by virtue of HCMC Decision 5/898/3.12.2020, a specific registry was established for the above providers..." [7]
  • Global Legal Insights (Oct 2024): "Apart from certain AML/CTF provisions, no specific legislation has been enacted in Greece to regulate cryptocurrencies... However, the use of cryptocurrencies is not forbidden per se... The only specific legislation to date is the EU Regulation on Markets in Crypto-Assets (MiCAR)... which will apply in Greece on 30 December 2024." [15]

4. Source Links:

  • [2] Manimama Law Firm - Greece cryptocurrency regulation: https://www.manimama.eu/en/knowledge/greece-cryptocurrency-regulation
  • [3] CMS Law - Expert Guide to Crypto Regulation in Greece: https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-regulation/greece
  • [4] Bernitsas Law Firm - Legal framework for cryptos in Greece (Oct 2023): https://www.bernpark.com/financial-services-briefing-special-edition-legal-framework-for-cryptos-in-greece-just-over-a-year-left-to-register-with-the-hcmc/ (Link also used for [13])
  • [5] Kryptos.io - Greece Crypto Tax Guide 2025: https://kryptos.io/guides/greece-crypto-tax-guide/
  • [6] ICO Greece - Advice for Crypto Companies (Feb 2024): https://www.companyformationgreece.com/ico-in-greece
  • [7] ICLG - Fintech Laws and Regulations Greece 2024-2025: https://iclg.com/practice-areas/fintech-laws-and-regulations/greece
  • [8] Cointelegraph - Bank of Greece Bitcoin Statement (Feb 2014): https://cointelegraph.com/news/bitcoin_statement_populated_by_the_bank_of_greece
  • [9] Harneys - ESMA statements on MiCAR transitional measures (Jan 2025): https://www.harneys.com/insights/regulatory-blog/esma-issues-statements-on-micar-transitional-measures-and-grandfathering-periods-for-casps/
  • [10] BitcoinWide - How to buy bitcoin with cash in Greece?: https://bitcoinwide.com/news/en/how-to-buy-bitcoin-with-cash-in-greece
  • [11] Norton Rose Fulbright - Bitcoin and public policy in international arbitration enforcement: https://www.nortonrosefulbright.com/en/knowledge/publications/7a735b5a/bitcoin-and-public-policy-in-international-arbitration-enforcement
  • [15] Global Legal Insights - Blockchain & Cryptocurrency Laws & Regulations 2025 | Greece: https://www.globallegalinsights.com/practice-areas/blockchain-laws-and-regulations/greece
  • [16] Coincub - Crypto in Greece: 7 Reasons It's a Hidden Gem for Investors: https://coincub.com/guide/can-i-trade-bitcoin-and-cryptocurrency-in-greece/
  • [18] DLA Piper - Regulating crypto-assets in Europe: Practical guide to MiCA | Greece: https://www.dlapiper.com/en/insights/publications/2024/06/regulating-crypto-assets-in-europe-practical-guide-to-mica/greece
  • [19] Millionero Magazine - The State of Cryptocurrency in Greece (Sep 2023): https://magazine.millionero.com/the-state-of-cryptocurrency-in-greece-an-overview/
  • [20] ICLG - Anti Money Laundering Laws and Regulations Greece 2024-2025: https://iclg.com/practice-areas/anti-money-laundering-laws-and-regulations/greece
  • Hellenic Capital Market Commission (HCMC - Primary Regulator): https://www.hcmc.gr/en/
  • Bank of Greece (BoG - Central Bank): https://www.bankofgreece.gr/en/

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