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Corporate Criminal Liability in Greece: What Businesses Need to Know

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Understanding the Liability of Companies, Directors and Senior Executives Under Greek Law

As regulatory enforcement becomes increasingly sophisticated, businesses operating in Greece face growing exposure to criminal investigations, regulatory sanctions and compliance obligations. Allegations involving bribery, fraud, money laundering, tax offences, environmental crime and market abuse can have significant consequences—not only for individuals but also for the companies they manage.

Unlike jurisdictions such as the United States, the United Kingdom or France, Greece does not recognise a general principle of corporate criminal liability. Instead, Greek law is based on the principle that criminal responsibility is personal and attaches primarily to natural persons.

This distinction, however, should not lead companies to underestimate their legal exposure. While a legal entity cannot generally be convicted of a criminal offence in the same manner as an individual, Greek law provides for a wide range of administrative, financial and regulatory sanctions against companies whose representatives commit certain offences.

This article explains the Greek legal framework and outlines the principal risks businesses should consider.

Does Greece Recognise Corporate Criminal Liability?

As a general rule, no.

Greek criminal law is founded on the principle of personal criminal responsibility (nulla poena sine culpa). Criminal liability is imposed on individuals who personally commit or participate in criminal offences.

A company itself cannot generally be sentenced to imprisonment or receive a criminal conviction.

Instead, criminal responsibility normally attaches to:

  • directors;
  • members of the board of directors;
  • managers;
  • legal representatives;
  • beneficial owners;
  • employees who personally participated in the offence.

However, this is only part of the picture.

Can Companies Still Be Sanctioned?

Absolutely.

Although companies are not generally subject to criminal convictions, numerous Greek statutes provide for administrative or quasi-criminal sanctions against legal entities.

These sanctions are particularly common in areas such as:

  • bribery and corruption;
  • money laundering;
  • international sanctions;
  • environmental protection;
  • competition law;
  • financial services regulation;
  • market abuse.

Consequently, companies may face severe financial and operational consequences even where only individuals are prosecuted.

Corporate Liability for Bribery and Corruption

One of the most significant areas concerns corruption offences.

Where bribery is committed:

  • by directors;
  • by senior managers;
  • by persons exercising management authority;
  • by employees acting for the company’s benefit,

the legal entity may become subject to administrative sanctions.

Possible measures include:

  • substantial administrative fines;
  • exclusion from public procurement procedures;
  • suspension of business activities;
  • withdrawal of licences or permits;
  • publication of regulatory decisions.

For companies operating in regulated sectors, these sanctions may have serious commercial consequences.

Money Laundering and Corporate Exposure

Anti-money laundering legislation is another major source of corporate liability.

Although the offence of money laundering is committed by individuals, companies may face regulatory sanctions where failures in compliance systems contribute to unlawful conduct.

Authorities may examine whether the company maintained:

  • effective customer due diligence procedures;
  • beneficial ownership controls;
  • suspicious transaction reporting mechanisms;
  • internal AML policies;
  • employee training programmes.

Deficiencies in these areas may result in significant administrative penalties and regulatory intervention.

Tax Offences

Tax investigations often involve both corporate entities and individual decision-makers.

While criminal liability generally remains personal, companies may simultaneously face:

  • tax reassessments;
  • administrative penalties;
  • enforcement measures;
  • reputational consequences.

Corporate records frequently become central evidence in criminal tax proceedings against directors and managers.

Environmental Criminal Liability

Environmental offences increasingly expose companies to regulatory action.

Investigations may concern:

  • unlawful waste disposal;
  • pollution incidents;
  • environmental permit breaches;
  • hazardous substances;
  • industrial accidents.

Although individuals remain primarily responsible under criminal law, legal entities may face substantial administrative sanctions arising from the same conduct.

Directors’ Criminal Liability

One of the most important aspects of corporate criminal law in Greece concerns the personal exposure of directors and senior executives.

Potential investigations may involve allegations relating to:

  • fraud;
  • breach of trust;
  • tax offences;
  • bribery;
  • money laundering;
  • accounting irregularities;
  • market manipulation;
  • environmental offences.

Corporate decision-makers should therefore appreciate that limited liability under company law does not shield them from criminal prosecution.

Internal Investigations

When allegations arise, businesses often conduct internal investigations before regulators intervene.

Internal investigations may involve:

  • document collection;
  • employee interviews;
  • forensic accounting;
  • digital evidence reviews;
  • compliance assessments.

These investigations should be carefully structured to preserve legal privilege where applicable, protect employee rights and minimise additional legal risks.

Poorly managed internal investigations may inadvertently prejudice both the company and individual employees.

Compliance Programmes

An effective compliance programme has become one of the most important tools for reducing corporate risk.

A modern compliance framework typically includes:

  • anti-corruption policies;
  • anti-money laundering procedures;
  • whistleblowing mechanisms;
  • third-party due diligence;
  • sanctions screening;
  • internal reporting channels;
  • periodic employee training;
  • documented risk assessments.

Although the existence of a compliance programme does not automatically exempt a company from liability, it demonstrates proactive governance and may be an important factor during regulatory investigations.

Whistleblowing

The implementation of the EU Whistleblower Directive has significantly increased the importance of internal reporting mechanisms.

Companies should ensure that employees can safely report concerns regarding:

  • bribery;
  • fraud;
  • accounting irregularities;
  • harassment;
  • regulatory breaches;
  • conflicts of interest.

An effective whistleblowing system allows businesses to identify and address problems before they escalate into criminal investigations.

Dawn Raids and Regulatory Inspections

Companies should be prepared for unannounced inspections by regulatory authorities.

Such investigations may involve:

  • requests for documents;
  • interviews with employees;
  • examination of electronic devices;
  • seizure of records;
  • cooperation with prosecutors.

Businesses should have clear internal procedures governing their response to regulatory inspections.

Preparation before an investigation occurs is often crucial.

Cross-Border Investigations

Corporate investigations increasingly involve multiple jurisdictions.

Greek companies may simultaneously become involved in investigations conducted by:

  • Greek prosecutors;
  • foreign enforcement agencies;
  • the European Public Prosecutor’s Office (EPPO);
  • financial intelligence units;
  • regulatory authorities in other jurisdictions.

Cross-border coordination has become particularly important in cases involving:

  • international fraud;
  • corruption;
  • sanctions violations;
  • tax offences;
  • money laundering.

Common Mistakes Made by Businesses

Ignoring Early Warning Signs

Many companies underestimate the significance of initial complaints or regulatory enquiries.

Conducting Informal Internal Investigations

Unstructured interviews and document collection may create additional legal risks.

Delaying Legal Advice

Early legal assessment often helps contain regulatory exposure.

Treating Compliance as a Paper Exercise

Compliance programmes should be actively implemented, reviewed and updated.

Failing to Preserve Evidence

Once an investigation becomes foreseeable, document preservation is essential.

Practical Recommendations for Businesses

Companies operating in Greece should:

  • implement a tailored compliance programme;
  • conduct regular legal risk assessments;
  • provide periodic compliance training;
  • establish whistleblowing procedures;
  • review relationships with third parties and intermediaries;
  • prepare protocols for regulatory inspections;
  • seek legal advice immediately if criminal allegations arise.

Preventive compliance is generally less costly than responding to a criminal investigation after it has begun.

Conclusion

Although Greece does not recognise general corporate criminal liability in the same manner as some other jurisdictions, companies remain exposed to significant administrative, regulatory and financial sanctions arising from criminal conduct committed for their benefit or within their organisational structure.

At the same time, directors, managers and other decision-makers may face personal criminal liability for offences committed in the course of corporate activities.

For businesses operating in Greece, effective governance, robust compliance systems and early legal advice are essential components of modern corporate risk management.

Frequently Asked Questions

Can a company be criminally convicted in Greece?

As a general rule, no. Greek criminal law is based on the principle of personal criminal responsibility. However, companies may face administrative and regulatory sanctions for certain offences.

Can directors be prosecuted personally?

Yes. Directors, managers and other individuals may incur criminal liability for offences committed in connection with the company’s activities.

What types of offences create the greatest corporate risk?

Common areas include bribery, money laundering, tax offences, fraud, environmental offences, market abuse and sanctions violations.

Does having a compliance programme protect the company?

A compliance programme does not automatically eliminate liability, but it is an important element of corporate governance and may significantly reduce legal and regulatory risk.

Should a company conduct an internal investigation?

In many cases, yes. Internal investigations can help identify the facts, assess legal exposure and support informed decision-making, provided they are conducted appropriately.

About the Authors

Karydas – Fouskarinis & Associates advises Greek and international companies on corporate criminal liability, compliance programmes, anti-corruption frameworks, anti-money laundering obligations, internal investigations, regulatory enforcement and cross-border criminal matters. The firm regularly represents corporate clients, directors and senior executives in complex white-collar crime investigations before Greek authorities.