According to Law 4557/2018, as amended, the following are understood as liable persons, i.e. persons subject to the obligations of the Law:
a) Credit institutions and every creditor of Law 4438/2016 (A’ 220),
b) financial institutions,
c) certified public accountants and certified public accountant companies registered in the public register of the Accounting Standardization and Audit Committee, as well as private auditors,
d) external tax accountants and any other person who undertakes to provide, either directly or through other related persons, material assistance, assistance or advice on tax matters, as a main business or professional activity,
e) notaries and lawyers, when they participate, acting in the name and on behalf of their clients, in financial or real estate transactions and when they help plan or carry out transactions for their clients regarding:
• the purchase or sale of real estate or businesses,
• the management of money, securities or other assets of their clients;
• the opening or management of bank accounts, savings accounts or securities accounts, as well as the establishment of monetary deposits and primarily those relating to guarantees ordered by the judicial authority in the context of criminal proceedings,
• the necessary contributions for the establishment, operation or management of companies,
• the establishment, operation or administration of companies, trusts, confidential management companies, businesses, foundations or similar schemes or corresponding legal structures,
f) providers of services to trust management companies or businesses that do not already fall within the scope of cases c’, d’ and e’,
g) the persons who provide services to companies or trusts (trusts), which include those referred to in c., d. and e., who provide any of the following services to third parties as part of their business activity:
• set up companies or other legal entities,
• exercise the same or arrange for another person to exercise the duties of director, manager or partner of a company or holder of a corresponding position in other legal entities or formations,
• provide registered office, business address, postal or administrative address and any other related services for a company or any other legal entity or formation;
• act themselves or arrange for another person to act as trustee of an express trust or equivalent legal form,
• act themselves or arrange for another person to act as proxy for a shareholder of a company, if that company is not listed on a regulated market subject to disclosure requirements, in accordance with EU legislation or equivalent international standards;
h) the real estate brokers of Law 4093/2012 (A’ 222), for transactions whose value amounts to at least ten thousand (10,000) euros, regardless of whether this amount concerns the purchase, sale or monthly rental of a property, and the credit brokers of Law 4438/2016 (A’ 220) for a credit agreement amounting to at least ten thousand (10,000) euros,

i) casino businesses and casinos operating on ships in Greece or under the Greek flag, as well as businesses, organizations and other bodies that provide gambling services and agencies related to these activities,
j) traders and auctioneers of high-value goods, when the value of the transaction amounts to at least ten thousand (10,000) euros, regardless of whether it is carried out with a single transaction or with several, between which there appears to be some connection. Traders of high-value goods mean in particular:
• the mining, production, processing and trading of precious and semi-precious stones, the production, processing and trading of precious metals and derivative products, the trading of pearls and corals and the manufacturing and trading of jewelery and watches,
• businesses trading in old valuables (antiques), antiquities, medals, old stamps and coins and other valuable collectibles, as well as businesses or professionals producing or manufacturing and trading works and art objects in general, as well as musical instruments,
• persons trading or acting as intermediaries in the trade in works of art, including trade carried out in art galleries and auction houses;
• businesses that produce and trade carpets and rugs, fur products, leather goods and clothing in general,
• businesses trading passenger cars for private use, helicopters, aircraft and pleasure boats in general,
• persons who store, trade or act as intermediaries in the trade in works of art, when this is carried out from free ports;
k) pawnbrokers and moneylenders,
l) the providers of exchange services between virtual currencies and fiat currencies and
m) digital wallet custodian service providers.
In cases where the liable person undertakes professional activity as an employee of a liable legal entity, the obligations arising from this are borne by the legal entity and not the natural person. If he undertakes a professional activity as an employee or collaborating with any contract or agreement with a non-obligatory legal entity, the obligated natural person shall comply with the obligations arising from this, in accordance with the decisions of the competent authority that supervises the category of obligated persons to which the above natural person. (article 5 par. 2)
By joint decision of the Ministers of Finance and Economy and Development, following a proposal from the Authority, specific criteria may be defined for determining the liable persons in cases j’ and k’, as well as the more specific obligations to which they are subject, by way of derogation from the provisions of articles 17 et seq., as long as this is justified by the nature and amount of the transactions, as well as to add new categories of businesses. (article 5 par. 3)