Greece has seen a surge in cyberattacks amidst the COVID-19 pandemic and resultant economic recession, coming on the heels of an already-vulnerable digital landscape. In January 2020, Greece’s four main banks had to cancel 15,000 debit and credit cards after a tourist services portal was hacked. Since then, an increase in remote work has made information systems even more open to attack, and Greece’s strategic location has made it attractive to hackers looking to weaken the state. As vulnerabilities have been exposed, Greece has been slow to enact regulations in response.
Still, Greece has looked towards digitalization in strengthening and modernizing its floundering and cash-heavy economy. Indeed, Greece ranks second-to-last on the EU’s Digital Economy and Society Index ranking for 2020, with only 40% of its internet users utilizing online banking.1 Alongside an affinity for cash use, a 2017 Forbes study revealed that Greece has the number one shadow economy in the world.2 Digital banking technology can help to cut down on illegal activities and rampant tax evasion, which has partly contributed to the country’s dire financial straits.
Greeks’ distrust of the central bank might prove an obstacle to the widespread adoption of online banking services. Between tax hikes, wariness of the Greek government and pandemic-driven uncertainty, many Greeks have turned towards cryptocurrency as an alternative to centralized finance. Bitcoin reported a 163.37% surge in Greek interest in 2020.3 Although the Bank of Greece issued an announcement in 2018 per a European Securities and Markets Authority (ESMA) warning regarding the risks of virtual currencies, it has done little to regulate them.
Despite friction between the government and people, Greece’s COVID-19 recovery plan could offer the state an opportunity to start anew, in a way more palatable to a traditionally cash-reliant populace. The EU has allocated EUR 30.5 billion in grants and loans towards Greece’s Covid recovery.4 The European Investment Bank (EIB) has partnered with the Greek Ministry of Finance to help manage 5 billion of the money with a focus on high-impact investment plans, including digital transformation.5 Small financial institutions like Viva Wallet have already achieved successes in digital innovation, and tech giant Microsoft announced in October 2020 the “GR for Growth” initiative, which seeks to spearhead technological advancements in Greece. Both could prove useful in attracting more foreign direct investment towards Greece’s digitalization efforts.
Financial Regulatory Bodies
The Bank of Greece is the central bank of Greece.
The Hellenic Data Protection Authority (HDPA) is the primary data protection authority in Greece. It supervises the implementation of the application of the GDPR, national laws 4624/2019 and 3471/2006, and other relevant regulations.
The Hellenic Capital Market Commission aims to ensure the protection and operation of the capital market in Greece.
Policy, Laws and Regulations
Decision Establishing the eGov-KYC, 07 April 2021
Decision No. 9747 of 2021 has established the eGov-KYC, an online Know Your Customer application. It outlines the requirements for the identity verification of natural persons and procedures for obtaining and transferring their data to obligated financial and credit institutions. The decision marks an important step in the digitalization of banking and in mitigating ML/TF risks. Its convenience will help to enfranchise previously unbanked individuals.
Greece Launches Digital Transformation Strategy, December 2020
Minister of State and Digital Governance Kyriakos Pierrakakis has launched Greece's Digital Transformation Strategy—colloquially referred to as the Digital Transformation Bible—which outlines 450 projects to encourage digitalization across both public and private sectors. The strategy is underpinned by seven major goals, one of which is to incorporate digital technologies in all economic sectors. If successfully implemented, the framework could prove pivotal in attracting more foreign direct investment to Greece, which has lagged behind other EU member states.6
April’s Decision No. 9747 to establish the eGov-KYC is part of Greece’s wider Digital Transformation Strategy. In order to advance digital transformation, it is imperative to enable citizens to have their identities verified online. That coupled with strong authentication and electronic signatures are foundational for digital transformation.
Greece Publishes its National Cyber Security Strategy 2020-2025, 07 December 2020
Greece’s updated National Cyber Security Strategy was driven by the dramatically shifting threat landscape in response to the COVID-19 pandemic. The strategy, signed off on by Minister of State and Digital Governance Kyriakos Pierrakakis, outlines 20 objectives, including balancing security with privacy, establishing and implementing policies and regulation capabilities, establishing incident reporting mechanisms, providing incentives for the private sector to invest in security measures, and a risk assessment approach. A risk-based approach will be especially crucial in a post-pandemic ecosystem, which will see more widespread adoption of remote services and the ever-present threat of cybercrime.
Establishment of Register of Exchange Services Between Providers, 05 December 2020
The Hellenic Capital Market Commission published Decision 5/898/2020 requiring registration for entities that seek to provide virtual currency exchange and digital wallet custody services. This signals an important move towards reining in Greece’s tendency to shadow economic activities, which can be facilitated by untraceable cryptocurrency transactions. Cryptocurrency has previously faced little regulation in Greece, although this will change with the likely passage of the EU’s MiCA and Greece’s continued efforts to crack down on tax evasion and money laundering.
1. Digital Economy and Society Index (DESI) 2020: Greece. European Commission, 2020.
2. McCarthy, Niall. “The Countries With The Largest Shadow Economies.” Forbes, 9 Feb. 2017, www.forbes.com/sites/niallmccarthy/2017/02/09/where-the-worlds-shadow-economies-are-firmly-established-infographic/?sh=3bf5152c742c.
3. Helms, Kevin. “9 Countries Show Huge Growth in Cryptocurrency Interest.” Bitcoin News, Bitcoin, 3 May 2020, https://news.bitcoin.com/countries-growth-cryptocurrency-coinmarketcap/.
4. “Recovery and Resilience Facility: Germany and Greece submit official recovery and resilience plans.” European Commission, 28 April 2021, https://ec.europa.eu/commission/presscorner/detail/en/IP_21_1990.
5. Willis, Richard. “Greece: EIB to help manage EUR 5 billion of investments as part of Greek National Recovery and Resilience Plan: ‘Greece 2.0.’” European Investment Bank, 12 April 2021, https://www.eib.org/en/press/all/2021-120-eib-to-help-manage-eur-5-billion-of-investments-as-part-of-greek-national-recovery-and-resilience-plan-greece-2-0.
6. World Investment Report 2020. United Nations Conference on Trade and Development, 2020.
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Last updated: November 2021