On 28 June the Greek government imposed capital controls and introduced a bank holiday period, during which the banks remained closed. On 18 July 2015 a new legislative act was passed, with which the bank holiday period ended and banks re-opened. However, certain restrictions on cash withdrawals and transfers of funds remained. Since then, a number of ministerial decisions and a legislative act have been issued and have softened these restrictions.

The current legal frame with regard to financial instruments, cash withdrawal and capital movement is summarised below:

1. Drawdowns are allowed for up to €60 per day, per account holder, and per bank. Alternatively, drawdowns may take place once a week for up to €420 per week, with Friday counting as the last day of each week. The same applies for withdrawals in foreign currencies.
2. The depositing of bank cheques and private cheques is permitted, only to the credit of a bank account. Payment in cash against cheques is not permitted.
3. Drawdowns from abroad with debit cards issued from Greek banks are allowed up to the same daily or weekly amount as in Greece, namely €60 per day or €420 per week.
4. Credit cards and prepaid cards may not be used for drawdown of cash, regardless of whether in Greece or abroad.
5. Credit card, debit card and prepaid card holders may use their cards in order to buy products and services within Greece up to the contractual limit that the relevant bank has set.
6. Credit card, debit card and prepaid card holders may use their cards in order to purchase goods and services abroad only up to the contractual limit that the relevant bank has set and only up to the daily limit, which is approved for each bank by the Approval Committee for Bank Transactions.
7. On-line shopping via credit, debit or/and prepaid cards is allowed without limitations with e-shops which maintain a bank account with a bank which operates in Greece.
8. A new bank account can only be opened for very specific purposes, and only if no other bank account is available for these same purposes. For example, a special purpose account can be opened for the:
   
   a. Payment of wages
   b. Payment towards the bank
   c. Payment of pensions and social allowances
   d. Service of start-up companies which participate in supporting programmes for young entrepreneurship
   e. Cash collateral against a letter of guarantee
9. Adding an account co-holder to an existent bank account is not permitted.
10. Pre-payment of a loan in full or in part is only permitted in cash or through a remittance from abroad.
11. Early termination of fixed term deposits are not permitted, unless it results in payment of an equal amount (a) toward the Greek state or social security funds; (b) toward outstanding loans or instalments with the same bank; (c) toward wages to beneficiaries with the same bank; (d) for hospital treatment or student fees in Greece or abroad; and (e) to suppliers under certain circumstances and with the same bank.
12. It is impermissible to deny payment transactions through the use of credit or debit cards. A refusal to accept credit or debit cards will result in penalties, such as fines or/and imprisonment.
13. Credit and debit cards which have been issued abroad may be used without restrictions in Greece for the purchase of goods and services as well as for money withdrawals, up to the limit the card holder has agreed with the issuing bank.
14. Money transfers from bank accounts of foreign banks into Greek bank accounts is permitted.
15. The transfer of money from Greece to abroad is not permitted, except in cases where the Approval Committee for Bank Transactions grants special permit pursuant to specifically provided types of transactions, which are expressly exempted from this restrictive regime.
16. Money remitted from abroad to a Greek bank account may be again remitted abroad in full. However, cash withdrawals of such money is permitted only to the extent of the daily/weekly limits (namely €60 per day, or €420 per week – always per account holder, and per bank). An exception to such limits is provided for shipping companies falling under the scope of laws 959/1979 (Maritime Companies) and 27/1975 and Legislative Decree 2687/1953 (Foreign Capitals, Κεφάλαια Εξωτερικούl). All such companies may withdraw cash from their Greek bank account up to €50,000 per day, if such amount has been credited to their Greek bank account from abroad.
17. The transfer of cash (banknotes) abroad is permitted in either euros or a foreign currency, for an amount up to the equivalent of €2,000 per individual and per voyage abroad. Individuals who have their permanent residence abroad do not fall within the scope of this restriction.
18. Payments can be made with letters of guarantee, provided that the money is deposited in a bank account.
19. The repayment/reimbursement of existing loans and limits is permitted, pursuant to the terms and conditions of the relevant agreement with the bank.
20. Payment of salaries abroad is not permitted in circumstances where the bank account which is debited is with a Greek bank, and the bank account which is credited is with a foreign bank. An exception to this restriction is provided for individuals working in the field of diplomatic services for the Greek state.
21. No enforcement of executory titles may take place until 30 September 2015 in Greece. This period may be further extended.

Client Alert 2015-255