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Greece
GRschema crypto-v2.0.0trajectory: not yet assessedregulatedoverlaps: FIM, WPM
Last updated · 8 categories · 20 sourced
findings · 25 sources in the cumulative register
8Categoriesbaseline.
20Findings.claims[]
16Tier-1 sourcesrun_metadata.t1_source_count
Confidence mix(sums to 8 rendered categories; click to filter)
No categories moved this cycle.
Jurisdiction lead brief
Lead Signal
Greece's Markets in Crypto-Assets Regulation (MiCAR) implementation is fully in force, but this cycle's Challenger-verified corrections change the understood compliance timeline in a material way. Greece notified ESMA that it applied a shortened 12-month Article 143(3) transitional (grandfathering) period running from 30 December 2024, meaning the actual national deadline for previously-registered crypto firms to obtain full MiCA authorisation fell around 30 December 2025 -- not the EU-wide 18-month maximum of 1 July 2026 that some Member States, including Cyprus, Malta, Luxembourg and France, retained. Firms operating in Greece under the grandfathering clause have therefore needed full authorisation roughly six months earlier than the EU-wide backstop implied. Separately, Greek Law 5193/2025, which assigns MiCAR competences to the Hellenic Capital Market Commission (HCMC) and the Bank of Greece, was passed by the Hellenic Parliament on 10 April 2025 -- not on 1 January 2025 as originally understood. Neither correction changes the substance of Greece's dual-supervisor model, but both change the timeline against which compliance and enforcement exposure should be measured. Compounding this, Binance withdrew its MiCA licence application with the HCMC in June 2026, days before what several accounts describe as a deadline, reportedly amid concerns raised by Greek, Irish and Latvian regulators about the exchange's past legal issues and corporate structure. Taken together, these developments show a nominally settled regime (MiCAR plus Law 5193/2025, both in force) that is still working through real authorisation friction, and where several of the underlying competence-allocation claims currently rest on a single central-bank speech rather than a primary legislative or Gazette citation.
Other Developments
Token classification in Greece continues to follow the harmonised EU MiCAR taxonomy without material change this cycle: crypto-assets that qualify as financial instruments, deposits, funds, securitisation positions, insurance or pension products, or PEPPs remain excluded from MiCAR scope, and non-fungible tokens remain excluded under the uniqueness and non-fungibility tests in Recitals 10-11, though fractionalised or serially-issued 'NFT-like' items may fall back into scope under ESMA guidance. The on-chain activity picture is unchanged and thin: neither Law 5193/2025 nor MiCAR itself addresses pure crypto-asset mining or node-operation as a distinct licensing category, and EBA/ESMA's joint analysis of DeFi, lending, borrowing and staking business models under MiCAR Article 142 has not yet produced binding recommendations -- protocol-level activity sits as an unregulated gap inside an otherwise regulated CASP perimeter. The stablecoin regime is stable and fully in force: the Bank of Greece supervises and licenses credit institutions, e-money institutions and payment institutions issuing asset-referenced tokens (ARTs) and e-money tokens (EMTs), with MiCAR's systemic-risk provisions -- covering financial stability, payment systems, monetary policy transmission and monetary sovereignty -- applying to issuers under its supervision. Consumer protection obligations under MiCAR Title V, including Article 66 fair-and-clear-information requirements, custody-segregation rules for CASPs, and ESMA's Article 82(2) guidelines on transfer-service liability, remain in force, though supervisory practice is still maturing given the recently-closed transitional period and unresolved authorisation disputes. Tax treatment remains the weakest-covered domain: no primary Greek statute or confirmed AADE guidance addressing cryptocurrency capital gains or income characterisation could be located this cycle, and Greece's transposition status for DAC8's extension of automatic information exchange to crypto-asset transactions -- aligned with the OECD Crypto-Asset Reporting Framework -- remains unconfirmed.
Cross-Monitor Connections
Two overlap surfaces carry forward from this cycle. AML/CFT obligations for Greek CASPs -- including the Regulation (EU) 2023/1113 requirement that originator and beneficiary information accompany crypto-asset transfers and that intermediary CASPs transmit and retain that information for competent authorities -- sit on the financial-integrity monitor's subscribed aml_cft_regime surface rather than being independently re-analysed here; this monitor's role is limited to flagging the travel-rule nexus, not duplicating illicit-finance analysis. Separately, the stablecoin regime's payments-adjacent dimension -- Bank of Greece-supervised ART/EMT issuance and reserve requirements under MiCAR Titles III-IV -- and DAC8/CARF's cross-border tax-reporting harmonisation both carry implications relevant to the world-payments monitor's remit and are flagged accordingly.
Outlook
The near-term picture to watch is twofold. First, sourcing: several materiality-5, binding claims about the HCMC/Bank of Greece competence split rest solely on a single T2 central-bank speech rather than the primary text of Law 5193/2025 or an official Government Gazette citation, and this record remains held pending that confirmation. Second, cross-border friction: Binance's post-withdrawal status is unconfirmed, including whether it has since sought authorisation in another Member State and whether French or other regulators formalise resistance to passporting for CASPs licensed in jurisdictions they view as more permissive. If that resistance hardens into a formal supervisory position, it would test MiCAR's single-market passporting design in practice rather than in statute. On tax treatment, the absence of confirmed AADE guidance and unresolved Greek DAC8 transposition status leave a structural gap that primary-source research should close before this domain can be assessed with confidence above Uncertain.
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Greece implements the EU Markets in Crypto-Assets Regulation (MiCAR) directly as an EU Regulation, with national implementing measures enacted via Law 5193/2025 on the Enhancement of the Capital Market, which assigns MiCAR competences to the Hellenic Capital Market Commission (HCMC) and the Bank of Greece. HCMC is the notified National Competent Authority for MiCAR Titles II and VI (white papers/offers and market abuse), while the Bank of Greece is the prudential supervisor and licensing authority for credit institutions, e-money institutions and payment institutions seeking to issue ARTs/EMTs or operate as CASPs. The pre-MiCA transitional (grandfathering) regime under Article 143(3) MiCA ended 1 July 2026, and Greece's most prominent applicant (Binance) withdrew its HCMC licence application shortly before that deadline amid reported regulatory concerns, illustrating live implementation friction.
Standing sub-brief374 words · last cycle 2026-08-25
Crypto Licensing
Greece's crypto licensing regime is legally in force through MiCAR as implemented nationally by Law 5193/2025, but this cycle surfaces two Challenger-verified factual corrections that change the understood timeline materially. The Hellenic Capital Market Commission (HCMC) is Greece's National Competent Authority notified to ESMA for MiCAR Titles II and VI, covering crypto-asset white papers, public offers and market abuse -- a Confirmed, T1-sourced fact unaffected by this cycle's corrections. The Bank of Greece is separately entrusted with prudential supervision and licensing of credit institutions, e-money institutions and payment institutions that issue e-money tokens (EMTs) or asset-referenced tokens (ARTs), or that operate as crypto-asset service providers (CASPs), with power to impose administrative measures or penalties for breaches. That competence-allocation claim, along with the claim that Law 5193/2025 itself establishes these national implementing measures, rests solely on a single T2 Bank of Greece speech reported via BIS rather than the primary statutory text or a Government Gazette citation, and both have been downgraded from Confirmed to Probable pending stronger sourcing. The effective date of Law 5193/2025 has also been corrected: the law was passed by the Hellenic Parliament on 10 April 2025, not on 1 January 2025 as originally asserted. Separately, Greece's Article 143(3) grandfathering (transitional) period ran on a shortened 12-month national timeline from 30 December 2024, giving previously-registered entities a national deadline of roughly 30 December 2025 -- materially earlier than the EU-wide 18-month/1 July 2026 maximum some other Member States retained. Against this backdrop, Binance withdrew its MiCA licence application with the HCMC in June 2026, days before a reported deadline, amid concerns said to have been raised by Greek, Irish and Latvian regulators about the exchange's past legal issues and corporate structure -- a non-normative but material signal that Greek authorisation practice, though legally settled, remains operationally unsettled.
Outlook
The principal open item is sourcing quality: upgrading the HCMC/Bank of Greece competence-allocation claims from Probable to Confirmed requires a direct citation to Law 5193/2025's primary text or an official Gazette reference, which this cycle's research did not locate. The Binance withdrawal's aftermath -- whether Binance pursues authorisation elsewhere in the EU, and whether that raises further passporting questions for Greek/EU markets -- is also unresolved and flagged for follow-up research.
Periodic update · new data 2026-09-22
Crypto Licensing
The Hellenic Capital Market Commission requires Crypto-Asset Service Provider authorisation under the EU's Markets in Crypto-Assets Regulation, as implemented via Law 5193/2025, for the provision of crypto-asset services in Greece. This is a directly applicable EU regulatory requirement with an operating national authorisation procedure. The EU-wide MiCA transitional period, under which prior national virtual-asset-service-provider registrations could substitute for full MiCA authorisation, closed on 1 July 2026; Greek Hellenic-Capital-Market-Commission-registered virtual-asset-service-providers were required to submit full applications by 30 December 2025 to preserve grandfathering.
On 22 July 2026, the Hellenic Capital Market Commission granted Greece's first two Crypto-Asset Service Provider authorisations, to Capital Wallet Greece and Xenios Blockchain Group, under the Commission's Decision 8/1059 authorisation procedure of 30 July 2025 — the first live grants under the national authorisation track and confirmation that the procedure is now fully operative rather than merely established in principle.
Separately, Binance has stated that it was denied a Greek MiCA authorisation ahead of the 1 July 2026 transitional-period close, notwithstanding reports that its application was found compliant on technical review. This finding rests solely on Binance's own public statement as relayed by secondary press; the Hellenic Capital Market Commission has not independently confirmed the denial, and it is accordingly treated as a lower-confidence, unconfirmed episode rather than an established fact about Commission gatekeeping practice.
Outlook
Direct Hellenic Capital Market Commission confirmation or denial of the Binance authorisation outcome is the key data point to watch next cycle. The pace and pattern of further Crypto-Asset Service Provider authorisations will indicate how quickly the post-transitional Greek MiCA regime is being operationalised.
Sources and findings (5)
T2 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — Greece's 2025 Law 5193/2025 on the Enhancement of the Capital Market establishes the national measures implementing MiCAR, assigning respective competences and powers to the Hellenic Capital Market Commission and the Bank of Greece.retrieved M5bindingin force
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — HCMC is the Greek National Competent Authority notified to ESMA for MiCAR Titles II and VI, covering crypto-asset white papers/public offers and market abuse provisions.retrieved M5bindingin force
T2 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — The Bank of Greece is entrusted with prudential supervision and licensing of credit institutions, electronic money institutions and payment institutions that plan to issue e-money tokens (EMTs) and/or asset-referenced tokens (ARTs) or to operate as crypto-asset service providers (CASPs), and is empowered to impose administrative measures or penalties for breaches.retrieved M5bindingin force
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Entities providing crypto-asset services under applicable Greek/national law before 30 December 2024 could continue operating under MiCA's Article 143(3) grandfathering clause until 1 July 2026 or until granted/refused MiCA authorisation, whichever occurred sooner.retrieved M4bindingin force
T4 · CoinDeskCoinDesk — Binance withdrew its MiCA licence application with the Hellenic Capital Market Commission days before the 1 July 2026 deadline after Greek, Irish and Latvian regulators reportedly raised concerns about the exchange's past legal issues and corporate structure.retrieved M3non-binding
Greece applies the MiCAR taxonomy directly: asset-referenced tokens (ARTs), e-money tokens (EMTs), and 'other' crypto-assets (utility tokens) are distinguished per Titles III, IV and II respectively. Crypto-assets qualifying as MiFID II financial instruments, deposits, funds, insurance/pension products or securitisation positions fall outside MiCAR scope entirely and remain subject to existing Greek securities/banking law administered by HCMC/Bank of Greece. NFTs are excluded from MiCAR scope under specified conditions (uniqueness/non-fungibility tests), though ESMA guidance flags that misclassified 'NFT-like' fractionalised or serially-issued items may fall back into scope.
Standing sub-brief223 words · last cycle 2026-08-25
Token Classification
Greece's token classification regime follows the harmonised EU MiCAR taxonomy with no material change this cycle. MiCAR excludes from its scope crypto-assets that qualify as financial instruments, deposits (including structured deposits), funds (except where they qualify as e-money tokens), securitisation positions, insurance products, pension products, or pan-European personal pension products, per ESMA's final guidelines on the qualification of crypto-assets as financial instruments. Non-fungible tokens are likewise excluded from MiCA scope under the uniqueness and non-fungibility conditions set out in Recitals 10-11 of MiCAR and related ESMA guidance, though fractionalised or serially-issued 'NFT-like' items may fall back into scope where those conditions are not met. On the e-money token side, the Bank of Greece supervises and licenses credit institutions, e-money institutions and payment institutions intending to issue e-money tokens and/or asset-referenced tokens -- a materiality-5, binding claim that shares the same T2-only sourcing pattern flagged elsewhere in this cycle's licensing claims, though it was not itself named in the specific Challenger sourcing flag raised against sibling claims.
Outlook
No classification-boundary disputes are recorded for Greece this cycle. The main watch items are EU-level: ongoing ESMA guidance on the financial-instrument boundary and on NFT uniqueness tests could shift which assets fall inside or outside MiCAR scope, and any such shift would apply to Greece automatically as an EU Member State implementing MiCAR directly.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (3)
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — MiCAR does not apply to crypto-assets that qualify as financial instruments, deposits (including structured deposits), funds (except where they qualify as e-money tokens), securitisation positions, insurance products, pension products, or PEPPs.retrieved M4bindingin force
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Non-Fungible Tokens (NFTs) are outside the scope of MiCA under certain conditions related to uniqueness and non-fungibility, as set out in Recitals 10-11 of MiCA and clarified by ESMA guidelines.retrieved M3bindingin force
T2 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — The Bank of Greece supervises and licenses credit institutions, e-money institutions and payment institutions intending to issue e-money tokens (EMTs) and/or asset-referenced tokens (ARTs).retrieved M5bindingin force
MiCAR does not create a bespoke licensing category for staking, DeFi lending, DEX operation, mining, node operation or standalone validation; these activities are regulated only insofar as they are performed as a CASP-defined service (e.g., custody, execution, exchange) requiring HCMC/Bank of Greece authorisation. Pure protocol-level mining, node operation and non-custodial DeFi/DEX protocols currently fall outside MiCAR's direct licensing perimeter at EU level, and no Greece-specific supplementary regime for these activities has been identified.
Standing sub-brief185 words · last cycle 2026-08-25
On-Chain Activity Regime
Greece has no dedicated licensing or authorisation regime for staking, DeFi participation, mining or node operation outside MiCAR's CASP service categories, and this remains unchanged this cycle. The European Banking Authority and ESMA have jointly analysed EU crypto-asset market trends in DeFi adoption, lending, borrowing and staking business models under MiCAR Article 142, but this analysis has not produced binding policy recommendations. Separately, neither Greek Law 5193/2025 nor MiCAR itself addresses pure crypto-asset mining or node-operation activity as a distinct licensing or authorisation category -- a negative finding (an absence of a licensing category) rather than an evidentiary gap, and one that leaves protocol-level activity as an effective unregulated space within an otherwise regulated CASP perimeter.
Outlook
This is a structurally thin-evidence module by design, reflecting the genuine absence of EU-level on-chain-activity rulemaking rather than a research shortfall. Any binding EBA/ESMA policy recommendation on DeFi, lending or staking business models arising from the Article 142 analysis would be the most likely trigger for a status change here, and would apply to Greece as an EU Member State without requiring separate national transposition.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (2)
T1 · European Banking Authority (EBA)European Banking Authority (EBA) — EBA and ESMA jointly analysed EU crypto-asset market trends focusing on DeFi adoption, lending, borrowing and staking business models under MiCAR Article 142, without issuing binding policy recommendations specific to these activities.retrieved M3non-binding
T2 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — No Greece-specific or MiCAR-level licensing obligation for pure crypto-asset mining or node operation activity has been identified; such activity is not addressed as a distinct authorisation category under Greek Law 5193/2025 or MiCAR.retrieved M2non-bindinga fact about the regime
Stablecoin (ART/EMT) issuance in Greece is governed by MiCAR Titles III and IV, in force since 30 June 2024, with the Bank of Greece as the competent prudential authority for authorising and supervising credit institutions, e-money institutions and payment institutions issuing ARTs/EMTs, including imposing administrative penalties for breaches. Euro-denominated stablecoin issuance has picked up since early 2025 following MiCAR regulatory clarity, though USD-denominated stablecoins continue to dominate the broader EU market.
Standing sub-brief185 words · last cycle 2026-08-25
Stablecoin Regime
Greece's stablecoin (asset-referenced token and e-money token) regime remains fully in force under MiCAR Titles III-IV, with the Bank of Greece as the designated national supervisor. The Bank of Greece licenses credit institutions, e-money institutions and payment institutions to issue EMTs and/or ARTs, and holds power to impose administrative measures or penalties for MiCAR breaches -- a binding, materiality-5 claim whose confidence was recalibrated this cycle from Confirmed to Probable, reflecting that it rests on a single T2 central-bank speech rather than a primary statutory or Gazette source. MiCAR's systemic-risk provisions -- addressing financial stability, payment systems, monetary policy transmission and monetary sovereignty risks linked to crypto-assets purporting to maintain a stable value -- apply to ART/EMT issuers under Bank of Greece supervision, and this claim is Confirmed and unchanged this cycle.
Outlook
The regime itself is stable and shows no material change this cycle. The open item is sourcing depth rather than substance: upgrading the Bank of Greece's licensing-and-penalty-power claim toward Confirmed would require a primary Law 5193/2025 citation or Gazette reference, the same gap affecting sibling claims in crypto_licensing and token_classification.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (2)
T2 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — The Bank of Greece licenses credit institutions, e-money institutions and payment institutions to issue e-money tokens (EMTs) and/or asset-referenced tokens (ARTs) and is empowered to impose administrative measures or penalties for breaches of MiCAR.retrieved M5bindingin force
T2 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — MiCAR addresses systemic risks linked to crypto-assets purporting to maintain a stable value, concerning financial stability, payment systems, monetary policy transmission and monetary sovereignty, applicable to ART/EMT issuers supervised by the Bank of Greece.retrieved M4bindingin force
CASPs operating in Greece under MiCAR Title V must provide clients with information that is fair, clear and not misleading, including in marketing communications, and must meet knowledge-and-competence standards for staff providing crypto-asset advice per ESMA Guidelines. Custody and administration of crypto-assets on behalf of clients is a distinct regulated CASP service subject to HCMC/Bank of Greece oversight. Cross-border transfer service guidelines (Article 82 MiCA) impose liability and procedural obligations on CASPs providing transfer services to Greek clients.
Standing sub-brief199 words · last cycle 2026-08-25
Consumer Protection
Core consumer protection obligations for Greek crypto markets remain in force under MiCAR Title V and show no material change this cycle. MiCA Article 66 requires crypto-asset service providers to give clients information that is fair, clear and not misleading, including identified marketing communications -- a Confirmed, T1-sourced obligation. CASPs offering custody and administration services are subject to distinct MiCAR Title V authorisation and conduct requirements administered jointly by the HCMC and the Bank of Greece. ESMA's guidelines issued under MiCA Article 82(2) establish consistent, efficient and effective supervisory practices for crypto-asset transfer services, including liability provisions applicable to CASPs serving Greek clients. All three obligations are legally settled and in force, but supervisory practice around them is still maturing, given the recent close of the Article 143(3) transitional period and the unresolved Binance/HCMC authorisation dispute playing out in the same period.
Outlook
No consumer-protection-specific disputes are recorded for Greece this cycle, but the module's traffic light remains amber because the surrounding authorisation environment -- rather than the disclosure and custody rules themselves -- is unsettled. Continued monitoring of how HCMC/Bank of Greece enforce these Title V obligations against CASPs navigating the post-transitional authorisation landscape is warranted.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (3)
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Article 66 of MiCA provides that crypto-asset service providers shall provide their clients with information that is fair, clear and not misleading, including in marketing communications, which shall be identified as such.retrieved M4bindingin force
T1 · EUR-Lex / European UnionEUR-Lex / European Union — CASPs offering custody and administration of crypto-assets on behalf of clients are subject to distinct MiCAR Title V authorisation and conduct requirements administered by HCMC/Bank of Greece.retrieved M4bindingin force
T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — ESMA guidelines under Article 82(2) of MiCA establish consistent, efficient and effective supervisory practices for crypto-asset transfer services, including liability provisions applicable to CASPs serving Greek clients.retrieved M3bindingin force
No dedicated Greek statute specifically taxing cryptocurrency capital gains or income has been identified as of this research pass; general Greek income tax code provisions are presumed to apply by default to crypto disposals, but a confirmed rate/treatment could not be verified from available sources and requires primary-source escalation to the Greek Independent Authority for Public Revenue (AADE). Separately, at EU level, amendments to the Directive on Administrative Cooperation (DAC8/CARF) extend automatic exchange of information to crypto-asset transactions, which Greece as an EU Member State is obliged to transpose, though confirmation of Greek transposition status was not found in this pass.
Standing sub-brief170 words · last cycle 2026-08-25
Tax Treatment
Greek crypto tax treatment remains the weakest-covered domain in this cycle. No dedicated statute specifically addressing cryptocurrency capital gains taxation was located on the AADE (Independent Authority for Public Revenue) portal or elsewhere; general Greek income tax code provisions are presumed to apply by default, but this is a negative finding pending primary-source confirmation rather than a confirmed position. Separately, DAC8 -- the Directive on Administrative Cooperation amendment extending automatic exchange of information among EU Member States to crypto-asset transactions, aligned with the OECD Crypto-Asset Reporting Framework (CARF) -- is enacted at EU level but not yet effective, and Greece's specific transposition status and effective date have not been confirmed this cycle.
Outlook
This module requires direct research into AADE circulars or statutes addressing crypto capital gains and income characterisation, including whether crypto-to-crypto swaps are treated as taxable events, and confirmation of the Greek DAC8 transposition instrument and its effective date. Until that primary-source research is completed, this domain should be treated as materially under-confirmed rather than settled.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (2)
T3 · Independent Authority for Public Revenue (AADE), GreeceIndependent Authority for Public Revenue (AADE), Greece — No dedicated Greek statute specifically addressing cryptocurrency capital gains taxation has been identified; general income tax code provisions are presumed to apply by default pending primary-source confirmation.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
T1 · European Commission / EUR-LexEuropean Commission / EUR-Lex — EU Directive amendments (DAC8) extend the Directive on Administrative Cooperation to require automatic exchange of information on crypto-asset transactions among Member States, aligning with the OECD Crypto-Asset Reporting Framework (CARF).retrieved M4bindingenacted not yet effective
As an EU/EEA Member State operating under MiCAR, Greece imposes no domestic outbound restriction on crypto-asset transfers within the EU passporting framework; a MiCA-authorised CASP in any Member State (including Greece via HCMC) may in principle offer services across all 27 EU Member States. Cross-border crypto-asset transfers are subject to Regulation (EU) 2023/1113's travel-rule requirements, obliging CASPs to attach originator/beneficiary information to transfers and retain such records, with suspicious-activity flagging to the Financial Intelligence Unit as a disambiguation-only AML nexus (out of scope for this baseline's aml_cft_regime module).
Standing sub-brief222 words · last cycle 2026-08-25
Cross-Border Transfer
Greece's cross-border transfer framework is legally codified and in force, but this cycle surfaces reported friction around its practical operation. Under Regulation (EU) 2023/1113, the crypto-asset service provider of the originator must ensure that transfers of crypto-assets are accompanied by required information on the originator and the beneficiary, and intermediary CASPs must ensure that this information is transmitted with the transfer and that records are retained and made available to competent authorities on request -- both Confirmed, T1-sourced obligations unchanged this cycle. On passporting, a MiCA-authorised CASP licensed via the HCMC would formally be entitled to operate and market crypto services across all 27 EU Member States under MiCA's passporting framework; however, reporting on the Binance/HCMC episode indicates that French regulators have publicly signalled willingness to resist passporting for firms authorised in Member States they view as more permissive. This caveat downgraded the underlying passporting claim's confidence from Confirmed to Probable this cycle, reflecting that formal legal entitlement and reported supervisory practice may diverge.
Outlook
The travel-rule obligations are settled and stable; the passporting question is the live watch item. Whether French or other regulators formalise resistance to passporting for CASPs licensed in more permissive Member States -- and whether this affects Greek-authorised CASPs specifically -- would be the key trigger for reassessing this module's traffic light and confidence levels.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (3)
T4 · The BlockThe Block — If approved by the Hellenic Capital Market Commission, a MiCA licence obtained in Greece would allow a CASP to operate and market crypto services across all 27 EU member states under MiCA's passporting framework.retrieved M4bindingin force
T1 · EUR-Lex / European UnionEUR-Lex / European Union — The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by required information on the originator and the beneficiary, per Regulation (EU) 2023/1113.retrieved M4bindingin force
T1 · EUR-Lex / European UnionEUR-Lex / European Union — Intermediary crypto-asset service providers must ensure that all information received on the originator and the beneficiary accompanying a transfer of crypto-assets is transmitted with the transfer and that records are retained and made available on request to competent authorities.retrieved M3bindingin force
AML/CFT obligations for crypto-asset service providers are addressed under the Financial Integrity Module (FIM) consumer subscription and are out of scope for this crypto baseline. For disambiguation purposes only: pre-MiCA Greek VASP registration operated under AMLD5-derived national law with FIU oversight; under MiCAR's transition, registration under the AML/CFT framework alone (not MiCA authorisation) does not qualify an entity for the simplified Article 143(6) authorisation procedure. EBA AML/CFT powers transferred toward the EU Anti-Money Laundering Authority (AMLA) framework at the end of 2025.
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