Greece AML

Most Greek exposures I see are documented with a conclusion and no date, and the date is the part an auditor tests.

The country-risk section needs four answers, not one: FATF's call-for-action list, FATF's increased-monitoring list, the EU high-risk third-country list, and Annex I of the EU's non-cooperative tax jurisdictions. Those lists change several times a year, so the status recorded when the file was opened says nothing about the status now. Client, beneficial owner, payment corridor — same four questions each time; the only variable is whether you wrote down when you asked.

This week, pull the files with Greek exposure and check whether each country-risk section names the date it was last verified.

Current status on all four, as of the latest list update: https://firm.cy/aml-country/greece

Not legal advice. Verify against the primary source before acting.

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