# Appendix H — Banking Application Checklist This appendix is the working form of the banking material established in §9.4, §9.5 and §9.16 and in Chapter 15; it introduces no requirement, figure or expectation that is not already stated and sourced there, and every line carries the section from which it derives. It is used in two ways: as a preparation register before an account application is made, and as a diagnostic register where an application has been refused. One point governs the whole of it and is stated at the outset rather than at the end. **No bank account can be promised. The law obliges a credit institution to refuse where customer due diligence cannot be completed and nothing obliges it to accept, so an account is applied for and never bought; an adviser who promises one is misrepresenting the position (§9.5).** Where a chapter records that a matter requires confirmation at the date of application, the qualification is carried here unchanged, and it is not removed by the passage of time. ## H.1 Part A — What the bank is deciding | # | The institution's position | What it means for the application | Derived from | |---|---|---|---| | A1 | Law 4557/2018, Article 13 (implementing Directive (EU) 2015/849): a Greek credit institution that cannot fully perform customer due diligence must not carry out the transaction, must not establish the business relationship, or must terminate it. | The obligation runs one way only. The duty stated is at article level; paragraph-level confirmation against the Government Gazette is outstanding. | §9.4, §15.1 | | A2 | From 10 July 2027 the directly applicable Regulation (EU) 2024/1624, Article 21(1), carries the same refusal duty. | The architecture does not soften with the change of instrument. | §9.4, §15.14 | | A3 | Regulation (EU) 2024/1624, Annex III point (g), treats a third-country national applying for residence rights in exchange for investment as a higher-risk factor, and Article 41 requires, as a minimum, enhanced due diligence: additional customer and beneficial-owner information; additional information on source of funds and source of wealth; senior-management approval; enhanced monitoring. | The reference client sits in an elevated-scrutiny category by design of EU law, not by suspicion of the individual. | §9.5, §15.2 | | A4 | FATF Recommendation 10 requires identification and verification, an understanding of the purpose of the relationship, and ongoing due diligence including, where necessary, the source of funds; where due diligence cannot be completed the institution should not open the account and should consider a suspicious-transaction report. | The economic rationale for the account is itself an evidential item (Part B, item B10). | §15.1, §15.14 | | A5 | Acceptance is a risk-based commercial and compliance decision of the institution. No statistic exists for refusal rates at Greek banks, and none is invented in this report. | Timelines and outcomes cannot be promised by Kestrel Private or by anyone else. | §9.5 | | A6 | The right to a basic payment account under Directive 2014/92/EU, Article 16(2), extends to consumers legally resident in the Union. | A client who does not yet hold the Greek permit holds no such right; a client holding the permit is legally resident in a member state and may engage the right subject to its conditions. | §9.4 | | A7 | Bank of Greece Executive Committee Act 172/1/29.05.2020 is reported to permit remote electronic identification of natural persons by videoconference or by an automated procedure with additional safeguards; the Act's own text has not been read. | Whether a given institution offers remote onboarding to a non-resident third-country national is that institution's commercial decision and requires confirmation with the institution. | §9.4 | *Part A restates the legal architecture of account opening as set out in §9.4 and §9.5 and the checkpoint table at §15.1; instruments are named as they are named in those sections. Items A1 and A7 carry the confirmation qualifications recorded in the body. Seven items.* ## H.2 Part B — The document pack | # | Item | What the file carries | Derived from | |---|---|---|---| | B1 | Identity, all nationalities | Current passport or equivalent for every nationality held; Regulation (EU) 2024/1624, Article 22(1)(a), requires collection of all names, place and full date of birth, and "nationalities" in the plural. | §9.4, §15.11 | | B2 | Original-identity documents | Where an investment-acquired citizenship document is presented as proof of identity, the original birth certificate and any passports held in the original identity. | §9.5, §15.11 | | B3 | Names and name history | Every former name, married name, corporate alias and transliteration variant, reconciled across documents rather than left for the examiner to infer. | §15.11, §15.13 | | B4 | Tax identification numbers and all tax residences | Self-certification stating all jurisdictions of tax residence with the corresponding numbers; an institution may not rely on a self-certification it knows or has reason to know is incorrect or unreliable. | §9.14, §15.13 | | B5 | Greek tax number (AFM) | Issued to non-residents without any residence requirement, electronically via myAADE, with identification in person or by video call; a Greek-resident tax representative is typically appointed at registration (discretionary at code level under Article 8 of Law 5104/2024). | §9.4, §9.10 | | B6 | Proof of address | Evidence of the residential address and of the residence history relied on elsewhere in the file, including the countries of residence in the last five years used for criminal-record certificates. The acceptable form of evidence is set by the institution's own due-diligence policy and requires confirmation with the institution. | §15.12 | | B7 | Source of wealth — the wealth narrative | How the client's total position was built, evidenced across the years of accumulation, by the profile pack applicable to the client: business ownership (§15.3), salaried employment (§15.4), property-sale proceeds (§15.5), inheritance (§15.6), dividends and investment income (§15.7). | §15.2–§15.7 | | B8 | Source of funds — the funds narrative | The specific monies funding the structure traced from an identified wealth event, through named accounts, to the paying account, with complete bank trails, no cash steps and no unexplained intermediate accounts. | §15.2, §15.12 | | B9 | Family and third-party contributors | Where a spouse or relative funds any part of the structure, that person's identity, relationship and source of wealth and funds evidenced to the same standard as the applicant's own; family documentation is prepared to the same standard throughout. | §15.8, Chapter 16 | | B10 | Economic rationale for the account | A stated and documented purpose for the relationship — what the account is for, what will pass through it, and its connection to the property, the permit or an identified activity. | §15.1, §9.3 | | B11 | Corporate applicant — the entity | Beneficial owners identified and verified to the same standard as a personal applicant; registry and shareholding records; an articulable purpose and activity. A change-of-use property cannot serve as the company's seat or branch (Article 100 of Law 5038/2023), so the entity's seat lies elsewhere. | §9.4, §9.3, §9.2 | | B12 | Formalities | Original-language documents paired with certified translations; legalisation by Hague Apostille or, in its absence, consular authentication; documents that reconcile with one another in names, dates and amounts. | §15.12 | | B13 | Politically exposed person position | Disclosure of any prominent public function held by the client, a family member or a close associate; where present, identification is certain, approval is escalated within the institution, source-of-wealth work is the deepest of any profile, and timelines lengthen. Status is preventive, not accusatory. | §15.10 | | B14 | Crypto-origin wealth, where engaged | All four elements: licensed or registered virtual-asset service provider records; an on-chain analytics report as corroboration and not as proof; consistency with tax filings; conversion to fiat through a regulated institution with payments made by bank transfer. | §15.9 | | B15 | Banking evidence of imported funds | Evidence of the import of funds through the banking system from the client's own foreign accounts — required by the funds narrative in any event, and relevant to the acquisition presumption in Articles 32–33 of Law 4172/2013 where the non-resident client has Greek-source income in the year of acquisition. | §9.10, §15.12 | *Part B assembles the documentary requirements already stated in §9.4, §9.10 and §15.2–§15.12 for a single applicant; family members' items are additional and are prepared to the same standard (Chapter 16). Item B6 is governed by the institution's own policy and is not asserted here as a statutory requirement. Certificates age — the citizenship component's three-month rule for criminal records is the strictest in the structure — so assembly is sequenced against the filing date rather than completed far in advance (§15.12, §17.4). Fifteen items.* ## H.3 Part C — How banks treat citizenship-by-investment passports | # | Position | Practical consequence | Derived from | |---|---|---|---| | C1 | EU onboarding law requires collection of all nationalities held (Regulation (EU) 2024/1624, Article 22(1)(a)), and the FATF–OECD joint report of November 2023 records that financial institutions should consider enhancing their policies to establish that all nationalities and passports are disclosed at onboarding. | Every nationality is disclosed. Partial disclosure is not an option available to the client. | §9.4, §9.5, §15.11 | | C2 | Where an investment-acquired document is presented as proof of identity, the institution should routinely ask for the original birth certificate and any passports held in the original identity. | The original identity is produced, not replaced. | §9.5 | | C3 | Recommended practice includes verifying place of birth and all citizenship holdings, tagging accounts opened with such passports, and marking the passports themselves as investment-acquired. | The account is capable of being identified as such within the institution. | §9.5 | | C4 | Whatever any passport prints, due diligence collects place of birth, all nationalities and original-identity documents. | A São Tomé and Príncipe passport cannot place the client's origin beyond a bank's sight, and any expectation to the contrary is misconceived. For a legitimate client the consequence is disclosure and possibly additional questions — not exclusion. The client should expect to present both the original-nationality documents and the São Tomé documents; whether a given Greek institution accepts the São Tomé passport as the primary identity document requires confirmation with the institution. | §9.5 | | C5 | Reporting under the Common Reporting Standard is keyed to jurisdictions of tax residence, never to citizenship; a second citizenship is not a tax residence; São Tomé and Príncipe had, as at 27 July 2026, made no commitment to automatic exchange of financial account information. | Any suggestion of a reporting benefit from the citizenship component would be false. A Greek account opened by the client will be reported by the Greek bank to the client's jurisdictions of tax residence. | §9.14, §15.13 | | C6 | The joint report notes that reputational risks associated with citizenship-by-investment programmes can bear on small states' correspondent-banking relationships. | No São Tomé-specific banking consequence is evidenced, and none should be assumed in either direction. | §9.5 | *Part C reproduces the position stated at §9.5 and §15.11 and the reporting position at §9.14; the FATF–OECD material is the joint report of November 2023 as cited in those sections. Six items.* ## H.4 Part D — Practical sequencing | # | Stage | Banking position at that stage | Derived from | |---|---|---|---| | D1 | Before any commitment | Source-of-funds preparation precedes reservation of property and the filing of any application; it is the first workstream of the structure, and the same file supports the banking application. | §15.1, §9.5, §17.4 | | D2 | Registration | The Greek tax number is obtained; it is available to non-residents remotely and does not depend on any account. | §9.4, §9.10 | | D3 | Property acquisition | A Greek account of the buyer's own is not a statutory precondition. Article 100 §5 of Law 5038/2023 fixes the payment channels — crossed bank cheque, credit transfer, or payment through a provider operating in Greece, into the seller's account at a credit institution operating in Greece — with every payment detail recorded in the notarial deed, so the purchase may be funded by transfer from the client's existing foreign accounts. Payment may also be made by the buyer's spouse or by relatives by blood or marriage up to the second degree, with those details likewise recorded. | §9.4, §9.16, §15.8 | | D4 | Citizenship contribution | The contribution moves only by deposit into the National Transformation Fund's exclusive bank account, within 90 days of approval and after approval (Decreto-Lei n.º 07/2025, Articles 8 and 14(4)), supported by a declaration of the lawful origin of the funds with bank documentation. The decree makes no provision for payment by a third party; any funding otherwise than from the applicant's own resources requires confirmation with the programme's responsible unit at the date of application. | §6.5, §15.1, §15.8 | | D5 | After the permit is issued | The client is legally resident in a member state and may engage the basic-payment-account right under Directive 2014/92/EU subject to its conditions. Applying earlier is possible; the right is not. | §9.4 | | D6 | If the property is let | From 1 April 2026 residential rents must be paid into a landlord bank account declared to the Greek tax administration, so a client who lets the property needs a declared account; collection outside it is reported to cost the landlord the 5% deemed-expense deduction. Long-term letting of the qualifying property is permitted; short-term letting is prohibited for this category. | §9.4, §9.10, §8.10 | *Part D sequences the banking steps against the acquisition and permit sequence described in §9.4, §9.10 and §9.16 and the citizenship payment mechanic at §6.5 and §15.1. The Greek rent-account rule is reported tier and the deferring instrument is not independently confirmed (§9.10); each stage requires confirmation at the date of application. Six items.* ## H.5 Part E — Common causes of refusal | # | Cause | Where it is examined | Derived from | |---|---|---|---| | E1 | Customer due diligence cannot be completed at all — the statutory refusal case, in which the institution must not establish the relationship. | The whole file | §9.4, §15.14 | | E2 | Source of wealth not evidenced to a substantive standard: declarations and narratives organise a file, they do not evidence it. | Part B, item B7 | §15.12 | | E3 | Breaks in the funds chain — the specific funds cannot be traced from an identified wealth event to the paying account. | Part B, item B8 | §15.13 | | E4 | Unexplained third parties in the payment path, including remittances from entities with no visible relationship to the applicant. | Part B, item B9 | §15.8, §15.13 | | E5 | Tax filings that conflict materially with the stated wealth history, or arithmetic gaps between declared income and the accumulated position. | Part B, items B4 and B7 | §15.13, §15.4 | | E6 | Residence declarations inconsistent with the banking footprint, in circumstances where the institution may not rely on a self-certification it has reason to know is unreliable. | Part B, item B4 | §15.13, §9.14 | | E7 | Name, identity or nationality variations left unreconciled, or nationalities not fully disclosed. | Part B, items B1–B3 | §15.11, §15.13 | | E8 | A corporate applicant with no articulable purpose or activity: an entity formed for the appearance of substance fails at the first banking question about its purpose. | Part B, items B10–B11 | §9.3, §9.5, §9.16 | *Part E lists the causes recorded in §15.13 and §15.14 and the corporate-purpose point at §9.3 and §9.16, mapped to the Part B items that address each. The list is indicative of the causes identified in the body and is not exhaustive; no refusal statistic exists for Greek institutions and none is stated (§9.5). Eight items.* ## H.6 Part F — What to do on refusal | # | Step | Basis | Derived from | |---|---|---|---| | F1 | Classify the deficiency before doing anything else, using the distinction the report already draws: evidential and realistically curable, or structural. A missing document, a closable gap in the funds chain, an unresolved screening match that identifiers may resolve, or an aged certificate is the first case; an unexplainable source of wealth, untraceable funds, an unresolved material conflict with the tax record, an unexplained third party in the payment path, or unresolved sanctions, criminal or material regulatory concerns is the second. | §15.14 | §15.14 | | F2 | Where the deficiency is evidential, complete the file with documents before any further application. Resolution comes before filing; explanation after refusal comes too late. | §15.13, §15.14 | §15.13 | | F3 | Do not present the same file to another institution in the hope of a different answer. A file that would fail these tests is not submitted for a second opinion. | §15.14 | §15.14 | | F4 | Record that a refusal becomes part of the client's record in subsequent applications of any kind, and plan the sequence of any further application accordingly. | §15.13 | §15.13 | | F5 | Confirm what the refusal does and does not affect. The property purchase is payable by credit transfer from the client's existing foreign accounts through the statutory channels; Greek tax accounts are operable remotely; a declared rent account matters only where the property is let; the citizenship contribution moves through the Fund's own account. A personal Greek account is a convenience worth applying for, not a dependency on which to build a plan. | §9.16, §9.4 | §9.16 | | F6 | Where the client's plan depended on an account being obtained, revisit the plan rather than the institution. A client whose plan depends on guaranteed banking should not proceed, and Kestrel Private's assessment must say so, including where that ends the engagement. | §9.5, §13.9, §13.14 | §9.5 | *Part F applies the defer-or-decline framework of §15.14 to a banking refusal and the independence of the structure from any single account as stated at §9.16. No procedural entitlement to reasons, review or appeal is asserted, because none is established in the body; whether an institution gives reasons is its own commercial decision. Six items.* ## H.7 Item count | Part | Content | Items | |---|---|---:| | A | What the bank is deciding | 7 | | B | The document pack | 15 | | C | Citizenship-by-investment passports at onboarding | 6 | | D | Practical sequencing | 6 | | E | Common causes of refusal | 8 | | F | What to do on refusal | 6 | | **Total** | | **48** | *Count of the numbered items in §H.1–§H.6 (7 + 15 + 6 + 6 + 8 + 6 = 48), for a single applicant; family members' documentation is additional and is prepared to the same standard (Chapter 16). Every item derives from §9.2–§9.5, §9.10, §9.14, §9.16 or Chapter 15 as stated in its row, and none states a legal position beyond those sections. Statements of Greek law are made as at 2 August 2026 and are subject to confirmation at the date of application; the decision on any application rests with the institution, and on any immigration or citizenship application with the governments concerned (§18.9).*