Business Crimes & Compliance

Business Crimes & Compliance

As part of our legal assistance to foreign legal entities conducting business in Greece which comprises more than 90% of our clientele Zepos & Yannopoulos has for many years handled issues related to compliance, including for example, issues involving bribery, transparency and compliance for their Greek subsidiaries or operations. Likewise, our firm has often advised US clients on FCPA related audits, and on similar internal anti-corruption audits and compliance projects. In this respect, we had the opportunity, on several occasions to conduct compliance and anti-corruption reviews to diagnose the level of a client’s regulatory and internal compliance, to produce reports with proposed self-cleaning measures, to implement compliance procedures and participate in the implementation of measures for the restoration of compliance. Our involvement mainly covered the areas of anti-corruption regulation, public procurement laws and related sanctions, tax and accounting compliance, labour and data protection issues, corporate law as well as criminal aspects of all of the above. Our firm drafts guidelines for dawn raids tailored to the specific needs of each client while we provide immediate support and assistance in case of such raids.
 
By way of example, recent assignments include advising the following:
  • a major international group on a particular type of cross-border fraud, based on the VAT system which is known as VAT missing trader intra-community fraud (MTIC fraud). VAT intra-community missing trader fraud is a systematic criminal attack on the VAT system, which has been detected in many EU Member States including Greece. Our work on the matter was to assess Greek implications (tax, administrative, labour, corporate, criminal and other) arising from the involvement in such fraud of high-ranking employees of our client and propose appropriate actions to comply with the applicable framework, including the handling of disclosures and collaboration with Greek authorities
  • a major European automobile industry on white-collar criminal and tender-debarment risks and on the obligations of disclosure to the Greek criminal authorities and public-procurement agencies, as well as on the implementation of its compliance mechanism for its Greek operation in conformity with Greek corporate, criminal, labour and data protection laws
  • a major US corporation on the compliance of various policies and procedures implemented by the Greek subsidiary ranging from employment, commercial matters, M&A, anti-corruption, etc. 
  • a major international industrial and telecom company on tender-debarment risks and on the methods to achieve compliance for its future projects in Greece
  • a major international IT company regarding its participation in a high-volume public contract in Greece (following a tender) and irregularities revealed through internal audits of the group; contributing to the identification of the legal issues and to the planning and implementation of the necessary self-cleaning measures in line with Greek law
  • significant US and non-US defence manufacturers on legal issues connected to their domestic compliance with respect to the use of commercial sales representatives and/or consultants while bidding for Greek public tenders or contracting with the Greek State
  • a non-listed German corporation in relation to its cooperation with the German prosecuting authorities in revealing irregularities in obtaining large contracts with the Greek State and producing related evidence and in the carrying out of related audit work and interviews
  • a major German house-appliances company by assisting in the implementation of internal audits regarding the compliance of its promotional and marketing activities in Greece
  • US defence industries on issues related to FCPA ramifications stemming from public procurement contracts.

Zepos & Yannopoulos is the exclusive correspondent for Greece of TRACE International (Transparent Agents and Contracting Agencies, www.traceinternational.org ), a non-profit membership association that specialises in anti-bribery due diligence reviews and compliance training for international commercial intermediaries. Our active participation in TRACE helps us follow developments in this field internationally and deepen our relevant knowledge and understanding of related matters.

Zepos & Yannopoulos also assists OECD by participating in workshops organised in Greece. Our goal is to promote compliance, internal controls and ethics in Greek companies, providing to the attendees of such workshops insight and practical advice on the Greek Anti-Corruption legal environment.  

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