Reed Smith Client Alerts

作者: Anthony Poulopoulos

On 18 July 2015, the Greek Government passed a law ending the bank holiday period imposed on 28 June 2015. At the same time, restrictions continue on cash withdrawals and the transfer of funds.

The legislative act provides the following:

  • As of Monday, 20 July 2015, the bank holiday period ends and banks re-open.
  • Restrictions on cash withdrawals and capital movement are imposed.
  • The provisions apply to the following institutions:
    • a. All banking institutions operating within Greece, including branches of foreign banking institutions
    • b. Specific funds and institutions under Greek law
    • c. E-money institutions legally operating in Greece
  • As of the entry into force of this Act, any form of cash withdrawal from a branch or ATM exceeding €60 per depositor (customer ID), per credit institution, per day, from institutions in Greece and abroad is not permitted. Cash not withdrawn on any day or days can be withdrawn cumulatively up to €420 per week.
  • The cash withdrawal prohibition applies also to any other cash payment by institutions, in all currencies. This includes collecting cheques and payments under letters of guarantee that are deposited with a bank account, from which withdrawals are covered by the above restrictions.
  • Cash withdrawals using credit and prepaid cards in Greece and abroad are prohibited. The transfer of funds or cash abroad, by any means, is prohibited. This includes the transfer of funds to accounts held with banking institutions registered and operating abroad, as well as funds transfers using credit, prepaid and debit cards for cross-border payments.
  • The use of credit and debit cards abroad for purchases of goods or services without cash, up to the maximum limit set by the relevant banking institution, is permitted.
  • Opening new current or deposit accounts, adding co-beneficiaries to already existing ones and activating dormant accounts is prohibited.
  • Opening accounts specifically for the following transactions is permitted, provided the need is documented in writing and no other available account exists:
    • a. Payroll payments
    • b. Payment of obligations of the depositor vis-à-vis the same banking institution deriving from agreements entered into prior to 28 June 2015
    • c. Payment of new pensions and new welfare allowances
    • d. Settlement of card transactions under new acquiring agreements
    • e. Servicing of entities established after 1 May 2015
    • f. Servicing of start-ups participating in programmes supporting new entrepreneurship
    • g. The deposit of cash as cash collateral for letters of guarantee, documentary credit or loans with the same banking institution
    • h. Opening an account in favour of a third party for the purposes either to comply with an enforcement order of a claim, on the basis of a court order, a court decision or other enforceable title; or to pay a claim, regarding which seizure in the hands of a third party has been imposed in favour of the beneficiary of the claim, unless a deposit account has been declared through any procedural action
    • i. Credit of funds from abroad in any currency of at least €10,000 or the equivalent in a foreign currency
    • j. Acceptance of a term deposit only in cases where its beneficiaries are the same with the beneficiaries of its feeder deposit or current account
    • k. Any other case following the approval by the Committee for the Approval of Banking Transactions.
  • The early, partial or total prepayment of a loan in a banking institution is prohibited, excluding the repayment by cash or remittance from abroad.
  • The early, partial or total expiry of fixed term deposits is prohibited, but may be permitted for payments in the following circumstances:
    • a. Obligations vis-à-vis the state and social security funds
    • b. Current instalment and overdue loan debts with the same credit institution
    • c. Payroll payments within the same credit institution
    • d. Hospital expenses and tuition fees in Greece and abroad
    • e. Suppliers holding an account with the same banking institution against invoices or equivalent documents provided there are insufficient funds in an existing savings or current account
  • The prohibitions and restrictive measures (among other things) do not apply to:
    • a. Transactions of the Hellenic Republic
    • b. Transactions of the Bank of Greece
    • c. Specific transactions approved by a decision of the Committee for the Approval of Banking Transactions
    • d. Cross-border payment orders exclusively relating to the crediting of an account held with an institution operating in Greece
    • e. All the amounts transferred from abroad by a credit transfer to accounts held in a banking institution operating in Greece, provided they are re-transferred to an account held with a banking institution operating abroad
    • f. The payment of hospital and medical expenses and tuition fees, upon production of the necessary documents to the banking institution through which the transaction is carried out
  • The Black Sea Trade and Development Bank does not fall within the restrictions and prohibitions.
  • By decision of the Governor of the Bank of Greece, restrictions may be imposed on the transport of bank notes in euro or foreign currency outside the Greek territory.


Client Alert 2015-204