# 18. Roles, Responsibilities and Professional Boundaries The reference structure is implemented by a chain of professionals in at least three jurisdictions and decided, at every point that matters, by two governments and the client's chosen bank. This chapter records who performs each function, what each professional alone can certify or decide, and where the boundaries of Kestrel Private's own role lie. Two principles govern throughout. First, coordination is not regulated advice: the legal, tax and technical judgements in the structure belong to admitted and licensed professionals in each jurisdiction. Second, no adviser of any kind — coordinator, counsel or agent — controls the outcome of any government process (§18.9). ## 18.1 Kestrel Private's coordinating role Kestrel Private's function in the reference structure is coordination: the initial strategy and suitability assessment described in Chapter 13, the sequencing of the components (§5.9 and Chapter 17), the assembly and preparation of the client's document file, the engagement and instruction of the professionals described in this chapter, and the management of the position after approval (§17.16–§17.17). The boundaries of that role are stated plainly. Kestrel Private is a trading name of 8T20 Capital (Pty) Ltd, a South African company (registration 2019/482395/07); engagements are contracted and invoiced by that company under South African governing law.[^18-1] It is an advisory firm, not a law firm. It does not practise Greek or São Toméan law, does not provide regulated legal, tax, immigration or investment advice, and is not an authorised financial services provider under South Africa's Financial Advisory and Intermediary Services Act 2002. The programmes described in this report are operated by the respective governments, not by Kestrel Private.[^18-1] Where a question turns on the law of a jurisdiction — and most load-bearing questions in this report do — the answer the client acts on must come from the regulated professional in that jurisdiction, not from the coordinator. Kestrel Private's professional engagement is charged as a fixed professional engagement fee agreed in writing before work begins; the fee is published at kestrelprivate.com/fees, and its place in the overall cost model is shown at §10.11. The fee, the scope of the coordination and the terms on which any property is presented are set out in the engagement letter and agreed before any work begins.[^18-2] Coordination displaces no statutory control. Whoever coordinates, the client's file passes through the statutory gatekeepers of both jurisdictions: Greek counsel, the notary, the engineer and the banks on the residence side; the citizenship unit's due-diligence apparatus, its review committee and the Public Prosecutor on the citizenship side. Sections 18.2 to 18.8 describe those gatekeepers; the table summarises the division of functions. | Actor | Function in the structure | What only this actor can do | |---|---|---| | Kestrel Private | Strategy, sequencing, document assembly, professional engagement, timetable | — (coordination confers no statutory function) | | Greek immigration counsel (§18.2) | Conduct of the residence application | Advise on Greek immigration law; file and defend the application | | Citizenship programme counsel (§18.3) | Advice on the São Toméan framework | Applicant-specific advice on São Toméan nationality law | | Property lawyer (§18.4) | Legal due diligence and the transaction | Title opinion; legal clearance to sign | | Notary (§18.4) | The transfer deed | Execute the deed and make its statutory certifications | | Engineer (§18.5) | Technical certification | Certify conversion, building legality and energy performance | | Tax advisers (§18.6) | Tax analysis in each relevant jurisdiction | Advise on the client's specific tax position | | Accountants and corporate-service providers (§18.7) | Filings, books, registered office | Statutory accounting and compliance filings | | Banks (§18.8) | Accounts and movement of funds | Decide whether to onboard and to transact | | Governments (§18.9) | Decision | Approve, refuse, revoke | Division of functions in the reference structure. The governing instruments and sources are cited in §§18.2–18.9; individual engagement scopes are fixed in each professional's letter of engagement. ## 18.2 Immigration counsel The Greek residence application is conducted under Greek immigration law by Greek counsel. The Immigration Code permits filing by a proxy holding an apostilled or consular-legalised power of attorney before the applicant first enters Greece — in practice, the instructed Greek lawyer.[^18-3] On filing a complete application the applicant receives a certificate of submission confirming lawful residence in Greece until the decision.[^18-4] Within an exclusive 12-month period from filing, the applicant and each family member must enter Greece, give biometrics and produce the outstanding health-insurance document required by Article 8(ε); a second failure to attend a summoned appointment results in rejection of the application.[^18-3] The official administrative record for the change-of-use category states a 50-day completion deadline once the file is complete, and an administrative appeal lies within two months, with a €50 fee and a 30-day decision standard; because the file completes only when biometrics have been given, the 50-day standard is not an end-to-end processing time.[^18-5] Only admitted Greek counsel can advise on the legal position, settle the file against the documentary requirements in force (§7.7), respond to the administration's queries and lodge the appeal. Kestrel Private prepares and coordinates; the conduct of the application, and the advice on which the client acts, are counsel's. The step-by-step sequence appears at §17.9 and §17.11. ## 18.3 Citizenship programme counsel The citizenship component rests on two Portuguese-language instruments: Decree-Law No. 07/2025 and the Nationality Law, Law No. 7/2022.[^18-6][^18-7] As the executive summary states, these provisions require an applicant-specific legal explanation before engagement, not a general marketing summary. Counsel competent in São Toméan law is the only source of that explanation. The reasons are concrete. Nationality may not be granted to a person who already holds more than two foreign nationalities, and a naturalised citizen who later acquires a fourth nationality loses São Toméan nationality.[^18-7] The decree's dependant definition is narrower than the categories published by the programme's application channel (§16.4–§16.5). The Public Prosecutor may institute judicial opposition within six months of the declaration of acquisition of nationality (§6.8) — and the two texts diverge on the competent forum for it, the decree bringing the opposition before the administrative court while Article 20(2) of the Nationality Law, to which the decree's own Article 14(7) refers the right, designates the Tribunal da Primeira Instância; no reading of that divergence should be asserted without counsel's written advice. And the two instruments describe the granting act differently — the Nationality Law provides for naturalisation granted by Government decree on the Justice Minister's favourable opinion, while the decree has the citizenship unit's director deciding by reasoned decision — an articulation neither text spells out, and on which no reading should be asserted without counsel's written advice.[^18-6][^18-7] Administration of the programme is statutory. Applications are received and processed by the Citizenship by Investment and Donation Unit (UCID) under the justice minister, and a public or private managing entity may be designated by joint order, acting when private under a public-service concession contract with the unit.[^18-6] The programme's official channel states that applications are initiated through licensed marketing agents.[^18-8] The decree licenses both agents and promotion: unlicensed promotion of the programme is punishable by a fine of up to US$500,000.[^18-6] The application and due-diligence process itself is described at §6.5. ## 18.4 Property lawyer and notary Two different professionals stand between the client and a Greek property acquisition, with different functions. The property lawyer conducts legal due diligence and the transaction. In Greek professional practice this includes review of the title chain of the seller and predecessors for at least 20 years, together with encumbrances — mortgages, prenotations, seizures, claims and pending litigation — at the land registry or cadastre; legal due diligence does not extend to planning and land-use compliance, which belongs to the engineer (§18.5).[^18-9] A Greek tax number is a practical precondition of the purchase.[^18-10] At initial issuance of the residence permit, a lawyer's certificate may substitute for the completed land-registry registration, with the definitive certificate produced at renewal.[^18-11] The lawyer's clearance to sign — title, encumbrances, seller capacity, contract terms — is a legal opinion only a lawyer can give. The notary is a public official. The acquisition completes only by notarial deed, and the statute assigns the notary certifications no other actor can make: the parties, the property, the consideration, the payment method and its details, full payment through the statutory bank channels, and whether the property has previously been used for the issuance of an investor residence permit.[^18-4] Every transfer deed must also incorporate the owner's declaration and an engineer's certificate that no unauthorised constructions or uses exist; breaches expose notaries, lawyers and engineers to imprisonment of at least six months and fines of €30,000–€100,000.[^18-12] Under the tax code as currently consolidated, the notary may not execute a transfer deed without a certificate covering the property's annual property-tax position for the preceding five years — a requirement whose current statutory numbering requires confirmation at the date of application.[^18-13] Both professions are also statutory anti-money-laundering gatekeepers: under Greek law, lawyers and notaries participating in real-estate transactions for a client are obliged entities, as are estate agents for transactions of at least €10,000 — with customer due-diligence duties owed by them directly, not delegated to any coordinator.[^18-14] The full property due-diligence scope is at §8.4–§8.5 and Appendix E. ## 18.5 Technical and planning advisers The change-of-use category rests on engineering certification. The documentary decision in force prescribes an engineer's technical report in a set form naming the qualifying planning acts — building permit, small-scale works approval, permit-file update or building-permit revision — with completion after 5 April 2024 evidenced by the issue date of the relevant act.[^18-11] Where the converted building is industrial, the engineer must additionally establish that no industrial activity has been installed and in operation in it for at least the last five years, by power-disconnection certificate, tax records for the preceding five years, or combined evidence from public authorities.[^18-4][^18-11] Administrative guidance issued in April 2026 — as reported by professional summaries; the circular text was not available to this report — polices the substance behind the paperwork: properties already residential on 5 April 2024 cannot be cycled out of and back into residential use, and a paper amendment to a building permit does not by itself count as a conversion.[^18-15] Both the evidentiary formula and the substance rule must be satisfied, and the engineer and counsel confirm this together for the specific property (§7.5, §8.5). The same profession certifies the building's wider legality: the no-unauthorised-constructions certificate required on every transfer deed (§18.4), the Electronic Building Identity completeness certificate reported to be required before a transfer deed can be signed,[^18-16] and the energy performance certificate required on sale and on letting to a new tenant, subject to the statutory exception for buildings under 50 m².[^18-17] None of these certifications can be produced by a coordinator, a lawyer or a seller. Technical and conversion risk is assessed at §8.5 and §14.4. ## 18.6 Tax advisers This report is general information; nothing in it is tax advice (Appendix O), and the fiscal propositions stated in outline below rest on professional secondary sources and require confirmation at the date of application. The tax questions raised by the structure are jurisdiction-specific and fact-specific, and they belong to regulated tax advisers in each relevant jurisdiction: Greece, the client's home country, and any jurisdiction to which the client may relocate. The boundaries the client should expect those advisers to confirm are these: a residence permit does not of itself create tax residence;[^18-18] the Greek elective regimes are available only to persons who transfer tax residence and separately qualify;[^18-19] home-country tax positions continue unchanged unless the client genuinely emigrates and requalifies (§9.12); and death taxes of two jurisdictions may apply to the same property in parallel (§9.12–§9.13). Chapter 9 sets out the analysis and §13.8 the suitability questions. What only the tax adviser can do is apply that framework to the client's facts, in writing, before the client commits. ## 18.7 Accountants and corporate-service providers Ownership of Greek property creates a small but permanent compliance surface — property declarations, annual property tax, and income filings where the property is let — and the optional layer adds statutory accounting, a registered office and corporate filings (§9.3, §10.13). These functions are performed by accountants and corporate-service providers in the relevant jurisdiction; the compliance calendar is at §17.16–§17.17. Under the FATF standards, countries must subject accountants, trust and company service providers and estate agents to customer due-diligence and record-keeping duties when acting in designated activities, including company formation and management;[^18-20] in Greece those duties apply under Law 4557/2018,[^18-14] and from 10 July 2027 under Regulation (EU) 2024/1624.[^18-21] Where no company is formed and the property is not let, this function reduces to the annual filings; where the optional layer is added, §9.15 prices it and §9.16 asks whether it is necessary at all. ## 18.8 Banks and compliance departments Every euro and every dollar in the structure moves through banks — the statutory payment channels on the Greek side and the National Transformation Fund's exclusive bank account on the São Toméan side — and banks decide for themselves.[^18-4][^18-6] Under Greek anti-money-laundering law, an institution that cannot complete customer due diligence must not carry out the transaction or establish the business relationship, and must terminate an existing one; nothing in any instrument obliges a bank to accept a customer.[^18-14] This is the legal basis of a sentence the executive summary states and this report repeats: a bank-account application is not a bank-account approval (§9.5). EU regulation is moving towards more prescriptive duties for the whole professional chain. Regulation (EU) 2024/1624, the Union's directly applicable anti-money-laundering regulation, applies from 10 July 2027. It carries the same refusal obligation, requires collection of all nationalities held by a customer, and lists among obliged entities credit and financial institutions, notaries and lawyers participating in real-property transactions, estate agents, and "investment migration operators" permitted to represent or offer intermediation services to third-country nationals seeking residence rights in a member state in exchange for any kind of investment. It treats such an applicant as a higher-risk factor and prescribes minimum enhanced due diligence: additional customer and beneficial-owner information, additional information on source of funds and source of wealth, senior-management approval, and enhanced monitoring. Its recitals record that the Regulation should not apply to investor citizenship schemes, which "must be considered as undermining the fundamental status of Union citizenship and sincere cooperation among Member States".[^18-21] Supervision under the accompanying directive attaches to obliged entities established in each member state's territory,[^18-22] and the Union's new anti-money-laundering authority is to supervise selected financial-sector entities directly from 2028.[^18-23] For the client, the practical meaning is disclosure. FATF and OECD guidance recommends that institutions consider enhancing their onboarding policies to establish that all nationalities and passports are disclosed, and that where a citizenship-by-investment document is presented as proof of identity they routinely ask for the original birth certificate and the passports held in the original identity.[^18-24] A São Tomé passport cannot conceal a client's origin from a financial institution, and this report does not suggest otherwise. For clients whose wealth is documented, the practical consequence is typically disclosure and enhanced questions rather than exclusion; no institution is obliged to accept a customer, and the outcome remains the bank's decision (§9.5). Banking practicalities and their limits are at §9.4–§9.5 and §6.11; source-of-funds standards are the subject of Chapter 15. ## 18.9 Government decision-making authority Approval, refusal and revocation belong to governments alone. No coordinator, counsel, agent or bank controls, accelerates or guarantees any government outcome, and no engagement letter can transfer decision-making authority to an adviser. In São Tomé and Príncipe, the completed file goes to the Public Prosecutor for prior clearance; the citizenship unit's director then decides, with legal reasoning.[^18-6] After acquisition, the Public Prosecutor may institute judicial opposition within six months, and revocation of nationality is a defined sanction.[^18-6] The responsible ministers may alter the programme's fees and minimum contribution amounts by joint order, a power expressed to be without prejudice to commitments assumed by the State in specific instruments; Article 22(2) of the decree provides that an update to those amounts does not affect processes already admitted.[^18-6] Fee and threshold risk is assessed at §14.2. The Government may also exclude applicants of designated nationalities by gazetted resolution, and even the act that completes naturalisation, the oath, is sworn before a public official of the state or its diplomatic or consular agents.[^18-6] In Greece, the migration administration grants, renews and revokes the permit. Revocation follows, among other things, sale of the qualifying property during the permit's validity, prohibited short-term letting, and — per the April 2026 administrative guidance, as reported — arrangements that reduce the effective investment below the statutory minimum.[^18-4][^18-15] The investment thresholds themselves have been changed twice since 2022, by Law 5007/2022 and again by Law 5100/2024, and may change again; legislative and policy-change risk is assessed at §7.14 and §14.1–§14.2.[^18-25][^18-26] Nor does any adviser control timing: alongside the 50-day completion standard, the Ministry's official statistics recorded 3,399 initial investor applications filed in 2024 still pending in March 2026.[^18-27] Any later Greek naturalisation is a further, separate state decision on statutory conditions (§7.13). This is the boundary on which the whole chapter rests: the structure is a sequence of applications to sovereign decision-makers. Everything the coordinator and the professional chain contribute — completeness, accuracy, evidence, sequencing — improves the quality of the file. It does not determine the answer. ## 18.10 Matters Kestrel Private does not guarantee Consistent with §1.7 and §19.8, Kestrel Private does not guarantee, and no professional described in this chapter can properly guarantee: - approval of any application — citizenship, residence or banking; - processing or issuance times in either jurisdiction; - the continuity of either programme, or of current contributions, fees and thresholds; - the stability of the legislation on which either component rests; - any tax outcome, tax residence, or the availability of any elective tax regime; - rental income from the property; - preservation of the €250,000, its appreciation, its recoverability or its liquidity on resale; - the eligibility of any family member under the rules in force at the date of application. A second category is different in kind, and is stated in the indicative because it is not a matter of degree. The structure does not provide EU citizenship, an EU passport, employment rights in the European Union, or visa-free entry to the Schengen Area arising from the São Tomé passport, together with the other rights listed as not provided in §1.7. Nationals of São Tomé and Príncipe are listed in Annex I of Regulation (EU) 2018/1806 and are absent from Annex II, and so require a visa to cross the external borders of the Schengen member states.[^18-28] Short-stay movement of up to 90 days in any 180-day period arises instead from the Greek residence permit, which is issued as a uniform-format residence permit and takes effect under Article 21 of the Convention Implementing the Schengen Agreement.[^18-3][^18-29] The citizenship component must therefore not be presented as the source of European mobility. These are not disclaimers appended to the structure; as Chapter 1 states, they define its legal and commercial boundaries. Where a client requires any outcome in the first list to be certain, or requires any right in the second, the structure is not suitable and the engagement should not proceed (§13.14). ## 18.11 Client responsibilities The structure also depends on the client. The responsibilities below are conditions of every stage; where they fail, the failure surfaces later as refusal, delay or revocation, at higher cost (Chapter 14). - **Truthful and complete disclosure.** Identities, all nationalities held, family circumstances, criminal and regulatory history, and the full wealth and funds history. Both regimes key decisions to disclosure, and some rules make completeness decisive of eligibility itself — the São Toméan cap on existing nationalities among them (§6.3, §13.2).[^18-7] - **Authentic, current documents.** Criminal-record certificates within their validity windows, apostille or consular legalisation, and certified translations (§16.7–§16.10).[^18-6] - **Evidence of source of wealth and source of funds.** A bank-documented declaration of lawful origin on the citizenship side; traceable transfers through the statutory payment channels on the property side; the standards of Chapter 15 throughout.[^18-6][^18-4] - **Timely instructions and attendance.** On the citizenship side, delivery of the approval certificate is conditional on deposit of the contribution within 90 days, failing which the process lapses.[^18-6] On the residence side, entry, biometrics and the outstanding health-insurance document within the exclusive 12-month window; renewal applications in the two months before expiry — late filing is possible for up to three months after expiry, at €100 for each month of delay; declaration of changes of passport, nationality or personal status within the statutory deadlines; annual renewal of the required insurance; and the tax filing calendar (§17.16–§17.17).[^18-3][^18-11] - **Maintaining the qualifying conditions.** Ownership and possession of the property for the life of the permit, no short-term letting, no use of the property as a company seat, and the continuing obligations listed at §19.9.[^18-4] - **Independent advice.** The client should take independent legal and tax advice in each relevant jurisdiction, and is entitled to do so at any stage. This report is general information addressed to no particular person (Foreword; Appendix O). Where disclosure, evidence or instructions cannot meet these standards, the appropriate professional response is deferral or decline — before filing, not after (§13.14, §15.14). ### Notes [^18-1]: Kestrel Private, "Regulatory scope" and related legal notices, https://kestrelprivate.com/legal/regulatory-scope (route client-rendered; text as published in the site bundle, last updated 6 July 2026); entity, company registration and governing-law details corroborated by https://kestrelprivate.com/llms.txt (accessed 2 August 2026). [^18-2]: Kestrel Private, published fee page, https://kestrelprivate.com/fees (accessed 4 August 2026). [^18-3]: Law 5038/2023 (Immigration Code, Government Gazette A′ 81/01.04.2023), Articles 8(ε), 10(11), 11(1), 14(1)–(2) and 14(7), and 19; gazette facsimile via https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf; Articles 11(1) and 17(1) per the consolidated text (codified through Law 5307/2026) at https://www.taxheaven.gr/law/5038/2023 (accessed 2 August 2026). [^18-4]: Law 5038/2023, Articles 10(8) and 100 (as amended by Law 5100/2024, Article 64), consolidated text via https://www.taxheaven.gr/law/5038/2023/article/100/view (accessed 2 August 2026). [^18-5]: Hellenic Republic, National Registry of Administrative Public Services (mitos.gov.gr), "Permanent golden visa (change of use) – Initial issuance", last updated 31 July 2026, https://en.mitos.gov.gr/index.php/ΔΔ:Permanent_golden_visa_(change_of_use)_–_Initial_issuance (accessed 2 August 2026). [^18-6]: São Tomé and Príncipe, Decreto-Lei n.º 07/2025 ("Regulamentação da Nacionalidade por Investimento ou Doação"), Diário da República I Série N.º 33, 1 August 2025, pp. 429–440 (Portuguese; gazette facsimile), Articles 4, 6, 8, 9–11, 14, 17–18 and 22, and Anexos I and III, https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026). [^18-7]: São Tomé and Príncipe, Lei n.º 7/2022 (Lei da Nacionalidade), Diário da República I Série N.º 25, 10 March 2022 (Portuguese; gazette facsimile), Articles 10–12, https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf (accessed 2 August 2026). [^18-8]: São Tomé and Príncipe Citizenship by Investment Unit, official programme site cip.gov.st (statement of the official site; archived capture of 10 July 2026), https://web.archive.org/web/20260710224801/https://cip.gov.st/ (accessed 2 August 2026). [^18-9]: Sioufas & Associates, "Legal due diligence for real estate in Greece" (professional practice description), https://www.sioufaslaw.gr/legal-due-diligence-for-real-estate-in-greece-4/; Global Law Experts, "How to check property title, Greece", https://globallawexperts.com/how-to-check-property-title-greece/ (both accessed 2 August 2026). [^18-10]: Independent Authority for Public Revenue (AADE), "Issuance of Tax Identification Number and Authentication Key and Appointment of tax representative" (non-residents), https://www.aade.gr/en/greeks-abroad-non-residents/registration-tax-register/issuance-tax-identification-number-and-authentication-key-and-appointment (accessed 2 August 2026). [^18-11]: Joint Ministerial Decision 214926/2025 (Government Gazette B′ 6014/11.11.2025), Articles 1–3, gazette PDF via https://www.pomida.gr/assets/File/1236_20250206014.pdf (accessed 2 August 2026). [^18-12]: Law 4495/2017, Article 83 (Government Gazette A′ 167/03.11.2017), consolidated text via https://www.taxheaven.gr/law/4495/2017/article/83/view (accessed 2 August 2026). [^18-13]: Article 54Α of Law 4174/2013 (Code of Tax Procedure), as read in the consolidated text, https://www.taxheaven.gr/law/4174/2013/article/54α/view (accessed 2 August 2026); the provision's numbering under the recodified Code of Tax Procedure (Law 5104/2024) requires confirmation at the date of application. [^18-14]: Law 4557/2018 (Government Gazette A′ 139/30.07.2018), Articles 5 and 13, consolidated texts via https://www.taxheaven.gr/law/4557/2018/article/5/view and https://www.taxheaven.gr/law/4557/2018/article/13/view (accessed 2 August 2026). [^18-15]: Circular 1/2026 of the Secretary General for Migration Policy, 21 April 2026 — content as reported by two concordant professional summaries (the circular text itself was not available to this report): Sioufas & Associates, https://www.sioufaslaw.gr/golden-visa-διευκρινίσεις-εφαρμογής-του-άρθρ-100/; IMI Daily, https://www.imidaily.com/europe/greece-cracks-down-on-golden-visa-fraud-in-sprawling-new-circular/ (accessed 2 August 2026). [^18-16]: proper.gr, Electronic Building Identity guide (trade description of the completeness-certificate requirement), https://proper.gr/ilektroniki-taftotita-ktiriou-odigos/ (accessed 2 August 2026). [^18-17]: Law 4122/2013, Article 12 §1 (certificate required on sale and on letting to a new tenant) with Article 12 §6 and Article 4 §7(ε) (exception for buildings of less than 50 m²), consolidated texts via https://www.taxheaven.gr/law/4122/2013/article/12/view and https://www.taxheaven.gr/law/4122/2013/article/4/view (accessed 2 August 2026). [^18-18]: ICLG, Private Client Laws and Regulations 2026 — Greece (Zepos & Yannopoulos), 14 January 2026, https://iclg.com/practice-areas/private-client-laws-and-regulations/greece/ (professional source; Greek tax rules stated as reported, subject to confirmation against the gazette texts) (accessed 2 August 2026). [^18-19]: Greece, Law 4172/2013, Article 5A §§1–5 (non-Greek tax residence in seven of the eight preceding years; qualifying Greek investment of at least €500,000 to be completed within three years, the condition being disapplied only for a holder of a residence permit for investment activity under Article 16 of Law 4251/2014; flat tax of €100,000 per tax year plus €20,000 per included relative, with no credit for foreign tax; maximum 15 tax years; cessation on non-payment or on failure to complete the investment); consolidated text, https://www.taxheaven.gr/law/4172/2013/article/5Α/view (accessed 2 August 2026; Greek). Amounts and conditions are amended from time to time and require confirmation at the date of application. Corroborated by Iason Skouzos TaxLaw, "The non-dom tax regime — Article 5A of the Greek Income Tax Code", https://www.taxlaw.gr/en/practice-areas/tax-law/the-non-dom-tax-regime-alternative-taxation-of-foreign-source-income-of-individuals-transferring-their-tax-residence-to-greece-article-5a-of-the-greek-income-tax-code/ (accessed 2 August 2026). [^18-20]: FATF, The FATF Recommendations (2012, as updated October 2025), Recommendations 10 and 22, https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/FATF%20Recommendations%202012.pdf.coredownload.inline.pdf (accessed 2 August 2026). [^18-21]: Regulation (EU) 2024/1624 of 31 May 2024 (OJ L, 19.6.2024), Articles 3, 21(1), 22(1)(a), 41 and 90, recital 21 and Annex III, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401624 (accessed 2 August 2026). [^18-22]: Directive (EU) 2024/1640 of 31 May 2024 (OJ L, 19.6.2024), Article 37(1), https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401640 (accessed 2 August 2026). [^18-23]: Regulation (EU) 2024/1620 of 31 May 2024 (OJ L, 19.6.2024), Articles 4 and 108 and recital 86, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401620 (accessed 2 August 2026). [^18-24]: FATF and OECD, *Misuse of Citizenship and Residency by Investment Programmes*, FATF, Paris, November 2023, ¶¶139 and 170–172, https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Misuse-CBI-RBI-Programmes.pdf (accessed 2 August 2026). [^18-25]: Law 5100/2024, Article 64 (Government Gazette A′ 49/05.04.2024), as codified with Law 5167/2024, official consolidated PDF via https://migration.gov.gr/wp-content/uploads/2025/03/Νόμος-5100_2024-κωδικοποιημένος-με-τον-5167_2024-ΦΕΚ-Α-49_5.4.2024.pdf (accessed 2 August 2026). [^18-26]: Law 5007/2022 (Government Gazette A′ 241/23.12.2022), Article 91 (the €500,000 minimum in designated high-demand areas) and Article 92 (the transitional provision); the gazette text was not opened for this report, and the 2022 limb is stated as reported, corroborated by the Hellenic Bank Association note, https://www.hba.gr/News/Details/2285, and, for the deposit-deadline extension, https://lawnet.gr/law-news/egk-syntonistikis-symv-fon-paratasi-pliromis-prokatavolis-a92-n-5007-2022-golden-visa-eos-31-7-2023/ (both accessed 2 August 2026). [^18-27]: Hellenic Ministry of Migration and Asylum, monthly statistical bulletin "Νόμιμη Μετανάστευση — Μάρτιος 2026", Annex B, golden-visa tables, https://migration.gov.gr/wp-content/uploads/2026/04/ΠΑΡΑΡΤΗΜΑ-Β_Μάρτιος_2026_ΥΜΑ-GR-Ενημερωτικό-Μάρτιος-Β-Νόμιμη-Μετανάστευση.pdf (accessed 2 August 2026). [^18-28]: Regulation (EU) 2018/1806 (visa lists), consolidated version of 30 December 2025, Annex I (São Tomé and Príncipe listed; absent from Annex II), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). [^18-29]: Convention Implementing the Schengen Agreement, Article 21, as replaced by Article 1(2) of Regulation (EU) No 265/2010, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265; the "90 days in any 180-day period" formulation substituted by Regulation (EU) No 610/2013, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R0610 (both accessed 2 August 2026).