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JMLC 17,1

Politicians, political parties’ funding in Greece and anti-money laundering regulatory framework

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Spyridon Repousis Department of Economics, University of Nicosia, Nicosia, Cyprus Abstract Purpose – The purpose of this paper is to examine politically exposed persons and major Greek political parties’ funding sources as well as the anti-money laundering regulatory framework for political parties’ funding sources. Design/methodology/approach – This paper aimed at investigating data about Greek political parties’ funding by identifying new problems and developing solutions. Findings – The main findings are that Greek political parties’ major sources of revenues are public subsidies and bank loans. Also, data show that two major Greek political parties cannot easily repay their bank loans (especially PASOK) and must renegotiate terms with banks and must agree for a new, long-term and lower payment schedule at a lower interest rate. Extending the period of repayment is necessary for viability of debts, and banks will protect themselves against default and total losses of about 253.1 million euros from the two major political parties. Public subsidies are the only collateral that Greek political parties offer to banks. Practical implications – As a result of research, structural changes are necessary to immediately be made in order to cope with politically exposed persons and political parties’ corruption and funding in Greece, especially during the current fiscal crises. Greek political parties need to raise funds from other sources than only public subsidies. Anti-Money Laundering Regulatory Framework have to stop conduit contributions and force banks to apply Know Your Client Principle for donors. Also, to include on Suspicious Activity Report a checkbox of “Political Finance Violations”. Establishing a code of conduct informing employees of the risks and subsequences of political corruption, creating a culture of honesty and high ethics and implementing Controlled Foreign Corporation legislation to cope with corruption in political parties’ funding can help to recover ill-gotten assets. Finally, implementing Business Principles for Countering Bribery and UK Bribery Act will increase transparency in funding of Greek political parties. Originality/value – The paper examines corruption and funding sources of Greek political parties, especially during the period 2009-2011, suggesting policy measures to deter and detect money laundering and illegal funding to politically exposed persons and political parties. Findings offer important measures for political analysts, government and society as a whole. A stable political system is prerequisite for a healthy society and for economic growth. Keywords Money laundering, Political funding, Political parties Paper type Research paper

Journal of Money Laundering Control Vol. 17 No. 1, 2014 pp. 110-120 q Emerald Group Publishing Limited 1368-5201 DOI 10.1108/JMLC-07-2013-0027

1. Introduction Greece, after 1974 is dominated by two major political parties, New Democracy and PASOK. From national parliamentary elections of 2007 up to now, their power decreased (Table I) due to the worldwide financial crisis and especially due to the Greek fiscal crisis, structural reforms and austerity measures. During two national parliamentary elections that took place in 2012, New Democracy, continue to be between two major political parties (it is the first political party in votes, ruling government), but PASOK is not anymore. PASOK now

is the third political parties in votes, because political party called “Synaspismos” (now, new name of political party is “Syriza”) is the second one (Table II). Corruption is a known phenomenon in Greece, taking place in state and in funding of political parties. According to the General Inspector of Greek Public Administration, only 1 percent of corruption in Greek public sector is detected and Greek state fraud losses from corrupted public servants are estimated to 20 billion euros annually (Newspaper Kathimerini, 29 May 2010). Also delays in judicial processes are a common feature. According to 2007 Transparency International Corruption Perceptions Index (CPI), Greece had 4.6 CPI score which indicates medium to high degree of public sector corruption as perceived by business people and country analysts. CPI score ranges between 10 (highly clean) and 0 (highly corrupt). The “party-state” in Greece and revelations of corruption has caused in past the fall of former Prime Minister Andreas Papandreou in 1989 and forced a re-examination of some of the basic characteristics of the Greek party state (Featherstone, 1990). Political party funding came under scrutiny as concerns grew that the largest Greek political party during 1996-2004, PASOK, and members of parliament from the same political party, probably were involved in illegal funding. About that there are three examples: . Example 1. A high profile case involved a former transport minister who admitted to accepting payments from the Greek branch of German electronics company and was arrested and charged with money laundering. According to minister’s testimony, received 200,000 German marks between 1998 and 2000 and were deposited into the Swiss bank account of minister’s best man in November 1998 (Newspaper Kathimerini, 28 May 2010). . Example 2. Another widely publicized example includes the case involving the former close aid or right-hand man of former Greek Prime Minister, admitting in June 2008, that had received one million German marks in 1999, from a German electronics company, “for the political party”. The money never landed in the political party’s coffers, claimed executives.

March 2004 85.91%

New Democracy PASOK Communist Party Synaspismos Total

September 2007

October 2009

May 2012

June 2012

79.94%

77.39%

32.03%

41.94%

March 2004 (%)

September 2007 (%)

October 2009 (%)

May 2012 (%)

June 2012 (%)

45.36 40.55 5.90 3.26 95.07

41.84 38.10 8.15 5.04 93.13

33.47 43.92 7.54 4.60 89.53

18.85 13.18 8.48 16.78 57.29

29.66 12.28 4.50 26.89 73.33

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Table I. Elections results of two major parties, New Democracy and PASOK

Table II. Results of Greek national parliamentary elections

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In both examples, it was said by politicians involved, that it was a political sponsorship or campaign donation and a common practice among politicians. Both politicians were ejected from their political party in June 2008 after admitting to accepting money: . Example 3. The most widely publicized example is a currently enjailed formerly Greek politician who served as a minister in several cabinets between 1981 and 2004 also founding member of political party. On July 2011, accusations of economic scandals and off-shore companies, lead Greek Parliament to vote in favor of pressing charges against him and charged him for the attempt to pass off money obtained through illegal means as legitimate. Also accusations lead president of the political party to expel him from the party on April 2011. He was involved in briberies from German electronics companies as Minister for National Defense during 1996-2001 in relation to the purchase of submarines. On April 2012, he was arrested and sent to jail on charges of money laundering. The next section of this paper provides an overview of anti-money laundering framework in Greece. Section 3 presents data and results about political parties’ funding. Finally, Section 4 provides policy measures and concluding remarks. 2. Overview of anti-money laundering framework in Greece The cornerstone of the relevant framework in Greece is Law 3691/2008, which considerably strengthens AML/CFT mechanisms and transposes Directive 2005/60/EC of the European Parliament and the Council, as well as Commission Directive 2006/70/EC laying down implementing measures for Directive 2005/60/EC. The most significant amendments that Law 3691/08 subsequently underwent were by virtue of Law 3875/2010 (regarding the criminalization of the terrorist financing offence) and Law 3932/2011 (regarding the structure of the Greek Anti Money Laundering and Counter Terrorist Financing Authority and the procedures for freezing the assets of persons, groups or entities subject to targeted financial sanctions). The Bank of Greece, is the authority responsible for supervising credit and financial institutions and compliance with the legislative framework on the prevention and suppression of money laundering and terrorist financing (Anti-Money Laundering and Combating the Financing of Terrorism – AML/CFT – Framework) by the institutions supervised by it. The Bank of Greece, in the context of its supervisory tasks, checks supervised institutions’ compliance with their AML/CFT-related obligations and assesses the adequacy and effectiveness of their AML/CFT procedures. It should be pointed out that the Bank of Greece has no power to conduct preliminary investigations or to examine in substance suspicious transaction reports submitted by supervised institutions. These powers are reserved to the AML/CFT Committee, the law enforcement or judicial authorities, as appropriate. By Law 3932/2011 which amended Law 3691/2008 the Anti-Money Laundering, Counter-Terrorist Financing Commission was renamed the “Anti-Money Laundering, Counter-Terrorist Financing and Source of Funds Investigation Authority”. The authority is a national unit aiming at combating the legalization of proceeds from criminal activities and terrorist financing, assisting in security and sustainability of fiscal and financing stability.

Its mission, according to Law 3691/2008, as amended by Law 3932/2011, is the collection, the investigation and the analysis of suspicious transactions reports (STRs) that are forwarded to it by legal entities and natural persons, under special obligation, as well as every other information that is related to the crimes of money laundering and terrorist financing and the source of funds investigation. The authority has been restructured into three individual units as follows: (1) The Financial Intelligence Unit (FIU). In addition to the President, the FIU comprises seven board members of the authority. At the end of each year, the FIU submits an activities report to the Institutions and Transparency Committee of the Greek Parliament and the Ministers of Finance, Justice, Transparency and Human Rights and Citizen Protection. (2) The Financial Sanctions Unit (FSU). In addition to the President, the FSU comprises two board members of the authority. At the end of every year, the unit submits an activities report to the Ministers of Foreign Affairs, Justice, Transparency and Human Rights and Citizen Protection. (3) The Source of Funds Investigation Unit (SFIU). In addition to the President, the SFIU comprises two board members of the authority. At the end of every year, the unit submits an activities report to the Institutions and Transparency Committee of the Greek Parliament and the Ministers of Finance and Justice, Transparency and Human Rights. The President is an acting Public Prosecutor to the Supreme Court appointed by a decision of the Supreme Judicial Council and serves on a full-time basis. Anti-Money Laundering Framework takes also into account Law 3023/2002 about funding of politically exposed persons and political parties. According to Law 3023/2002, Article 8: [. . .] financing of a political party from the same person during the same year must not exceed 15,000 Euros and financing of members of parliament or candidate members of parliament from the same person during the same year must not exceed 3,000 Euros.

The Third Money Laundering Directive includes the following definition of a politically exposed person: “Politically Exposed Persons” (PEPs) means natural persons who are or have been entrusted with prominent public functions and the immediate family members, or individuals known to be close associates, of such persons. Close associates must be identified only when their relationship with a PEP is publicly known or when the institution suspects there is a relationship. Business relationships with individuals holding important public positions and with persons or companies clearly related to them may expose a political party to significant reputational and/or legal risks. Such PEPs are individuals who are or have been entrusted with prominent public functions, including heads of state or of government, senior politicians, senior government, judicial or military officials, senior executives of publicly owned corporations and important political party officials. 3. Greek political parties’ funding Political party financing can distort the electoral process and is a major motive for corruption both developed and developing countries. Political finance regime, include bans and limits on certain kinds of revenues and expenditures, transparency of

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Table III. Public subsidies to Greek political parties during 2012 especially for national parliamentary elections

Table IV. Bank loans as percentage to total political parties’ revenues

political funds by disclosure and reporting as well as enforcement of rules and sanctions for infringements. Revenues of political parties can be collected from individual citizens, party membership dues, lobby groups, professional organizations, bank loans, companies and public subsidies. The pressure on political parties to raise money increases the power of monied interest groups, companies and individuals to influence party behavior in exchange for financial support. In Greece, main sources of revenues for two major political parties are public subsidies and bank loans. Maximum regular public subsidy can be up to 1.02‰ of regular revenues of public budget per year. But only parties winning a minimum level of electoral support of 1.5 percent of the votes qualify for subsidies (Law 3023/2022, Articles 1, 2). Additional subsidies of 0.1‰ of regular revenues of public budget per year are paid by public for parties’ research and seminar purposes. Public subsidies decreased during 2009-2011, as a result of the Greek fiscal crisis. Public subsidies and support for party development do not seem to probity in party financing. Although public subsidies were significant, even during the current year of the severe Greek fiscal crisis (Table III), there were important cases of political corruption, briberies and money laundering, as shown with three above examples. Data about political parties’ funding are collected from Bank of Greece, Supervisory Department and Revenues-Expenditures Financial Statements of Political Parties and analyzed. During years 2003-2007, bank loans were the most important source of revenues for the two major Greek political parties and especially for PASOK (Table IV). Also, total bank loans’ balance of four Greek political parties’ accounted to 272.4 million euros end of February 2012 (Table V). As a guarantee (collateral) for receiving bank loans, political parties have offered their public subsidies.

Elections 6 May 2012 (total subsidy)

Elections 17 June 2012 (only 40 percent of total subsidy)

2,129,908.91 2,794,958.81 479,890.29 292,865.85 5,697,623.86

476,025.46 197,148.13 72,287.00 431,572.77 1,177,033.36

New Democracy PASOK Communist Party Synaspismos Total

Source: Government Gazzette B’ 1321/23 April 2012 and Government Gazzette B’ 2169/20 July 2012

2003 2004 2005 2006 2007

New Democracy

PASOK

Communist Party

Synaspismos

0.0 43.8 27.2 5.4 42.2

23.0 Not available Not available 45.9 62.7

5.3 6.8 0.0 0.2 12.0

10.1 13.9 24.5 24.5 Not available

Note: The values are in percent

As shown in Tables VI and VII, bank loans of political parties’ is not easy to be repaid. Especially, PASOK is in a very difficult position, to repay its bank loans because during years 2009-2011, it is receiving new loans to repay older loans and interest (snowball effect). Also, has a high deficit between revenues and expenditures and bank loans repayments plus interest paid for bank loans exceed public subsidy. After elections during 2012, public subsidy of PASOK will decrease more and will not be able to cover operating expenditures and bank loans repayments. Political parties (New Democracy and PASOK) must renegotiate terms with banks and must agree for a new, long-term and lower repayment schedule at a lower interest rate. Extending the period of repayment is necessary for viability of debt. So, banks will also protect themselves against default on payments and partial or total losses. Otherwise, loans cannot be repaid. Also, political parties have to cut their costs and close branches around Greece which are not necessary as they cannot receive new loans because they cannot offer any other collateral.

Political party

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Balance 29 February 2012

New Democracy PASOK Communist Party Synaspismos Total

132,438 120,757 10,977 8,277 272,449

Table V. Bank loans of Greek political parties’

Note: In thousands euros

Revenues 2009 Public subsidy

2010

2011

Expenditures 2009 2010

26,280 15,056 12,750 Operating expenditures Additional public subsidy for 7,054 – – Expenditures for elections services, etc. Memberships dues 3,525 2,810 4,049 Interest paid for bank loans and bank commissions Revenues from property 1,551 122 89 Other party expenditures (to branch all over Greece) Difference between new bank 32,665 24,957 4,449 Expenditures during elections loans and repayments of bank period loans Cash (beginning of year) 365 743 2,356 Cash (end of year) Total revenues 71,440 43,688 23,693 Total expenditures 2 7,213 1,890 355 Difference between total revenues and total expenditures (deficit/surplus) Note: In thousands euros

8,025

2011

8,091

7,537

36,228 17,960

4,672

3,656

6,357

9,992

2,436

7,034

837

27,565





743 2,356 300 78,653 41,798 23,338

Table VI. New Democracy

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Revenues 2009 Public subsidy Additional public subsidy for elections Memberships dues Other revenues Bank loans

Table VII. PASOK

2010

24,175 6,506

19,810 –

4,501

2,942

547

23

46,800

40,810

Total revenues 82,529 63,585 28,132 23,483 Difference between total revenues and total expenditures (deficit)

2011

Expenditures 2009

16,309 Operating expenditures – Expenditures for services, etc. 1,687 Interest paid for bank loans and bank commissions 24 Other party expenditures (to branch all over Greece) 12,510 Expenditures during elections period Bank loans repayments 30,530 Total expenditures 25,895

2010

6,050 6,133 24,554 13,511

2011 5,425 6,784

3,497

6,493 10,259

6,253

5,621

1,921

24,132





26,175 35,310 12,036 90,661 67,068 36,425

Note: In thousands euros

Perhaps, public subsidies decrease parties’ interest in sustaining or increasing their membership. The parties’ dependence on membership dues and other voluntary financial contributions may decline. Also parties’ important incentive to mobilize and activate members declines. Literature suggest that public subsidies cannot explain the decline in party membership in cross-national data nor is there evidence to suggest that the public subsidies were introduced as a response to membership decline and that other income sources have lost their significance for political parties (Pierre et al., 2000). Greek political parties need to raise funds from other sources than only public subsidies. This is a necessity not only due to the bad economic crises in Greece and the pressure on public finance but also to the viability of economics and debts of Greek political parties. 4. Policy measures and conclusions Greek public financed parties, especially those in power, are tempted to take advantage of opportunities to corruptly acquire additional illegal contributions. Also, expectations of Greek citizens from politics were low but included receiving favors at elections and from their elected representative on their election. The better prospects now of improving services and tackling corruption more widely creates the possibility of changing expectations. Civic education should aim to persuade citizens to explore new kinds of demands as for example, for honest and effective public services in place of vote-buying. There is a need for implementation of a regulatory framework and reforms about disclosure of funding sources and bans on foreign donations. Experiences from political finance reform debates in Germany suggested that even when scandals lend salience to the issue of party finance reform, parties will not necessarily sacrifice assured economic gains for possible political payoffs (Scarrow, 2007).

But, in Greece, regulations are only a partial solution because ways are often found of evading or exploiting loopholes through channels which remain unregulated to exert influence through secret funds. Measures also have to be taken to stop conduit contributions. According to Law 3023/2002, banks’ cannot deny the acceptance of deposits above the limit of 15,000 euros for political parties and 3,000 euros for members of parliament or candidate members of parliament but it is recommended to contact and inform them. A conduit contribution is a political donation made through someone else. The individual making the contribution acts as a straw donor in order to conceal the identity of the real donor and the true source of funds. Conduit contribution scheme is designed to circumvent political contribution limits, which were established for the purpose of reducing influence on incumbent and potential public officials. Conduit contributions are a violation of Law 3023/2002, and a felony, with possible additional charges for money laundering being brought. Detecting a conduit contribution scheme requires a review of the political account, identifying the red flag associated with the scheme, then following the money trail. A red flag regarding the timing of conduit contributions is that they may be intentionally made very late in the campaign cycle, even after the election, since some expenditures may not be due immediately. Also, banks must apply Know Your Client Principle for straw donors because can be anyone but his/her socio-economic profile, may be a tip-off to a conduit contribution scheme and analysis may reveal that he/she does not fit the profile of someone who may be politically active. Like other economic crimes, banks are uniquely positioned to expose this particular violation of law. This is an open issue on political corruption and political parties’ funding in Greece since there is excessive reliance on banks for implementing PEPs policy and anti-money laundering methods to deter and detect political corruption. The obligation to undertake enhanced due diligence for PEPs is probably a controversial aspect. Dealing with political corruption and identifying it is undoubtedly extremely challenging and poses difficult challenges of “guarding the guardians”, these individuals and political parties that are by definition politically influential and generally command substantial resources. Greek banks as a measure to promote political transparency, expect PEPs policy, is to include on Suspicious Activity Report, a checkbox of “Political Finance Violations”. Because accepting and managing funds from corrupt PEPs and political parties will severely damage the bank’s and own reputation and can undermine public confidence in the ethical standards of an entire financial centre, since such cases usually receive extensive media attention and strong political reaction, even if the illegal origin of the assets is often difficult to prove. In addition, the bank may be subject to costly information requests and seizure orders from law enforcement or judicial authorities (including international mutual assistance procedures in criminal matters) and could be liable to actions for damages by the state concerned or the victims of a regime. Under certain circumstances, the bank and/or its officers and employees themselves can be exposed to charges of money laundering, if they know or should have known that the funds stemmed from corruption or other serious crimes. So, Greek banks should gather sufficient information from a new customer, and check publicly available information, in order to establish whether or not the customer is PEP. Have appropriate risk-based procedures to determine whether the customer

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is a political party or a PEP and obtain a written statement from all customers, in which a customer states whether or not it is a PEP. Banks should investigate the source of funds before accepting PEP. The decision to open an account for PEP should be taken at a senior management level. Government investigation must determine if bank filed a suspicious activity report for a PEP or a political party and then can perform an analysis of the target and finally determine when and how to notify person of the arrest or freeze and confiscation of accounts and other assets. A restraining order or court order, subpoenas and summonses will freeze a bank account and assets from being withdrawn or moved. The frozen funds or other assets remain the property of the political person(s) or political party(ies) that held an interest in the specified funds or other assets at the time of the freezing and may continue to be administered by the financial institution or other arrangements designated by such political person(s) or political party(ies) before initiation of the action under a freezing mechanism. Forfeiture laws are the legal means by which political persons or political parties who gain illicit profits are divested of their illegal gains. Forfeiture is a legal action that Greek Government authorities initiate against the proceeds of an illegal activity. In a typical forfeiture case, government authorities brings suit against the property or owner of the property. If the suit is successful, Greek Government gains the right, title and interest thereof. To initiate a forfeiture action, Greek Government (the prosecutor) needs to show that probable cause exists. Probable cause, in forfeiture, is a belief that the property and assets in question of political persons or political parties were either used illegally or represents the proceeds from illegal activity. When ill-gotten income and assets from corruption are found, then a restraining order or court order will help to recovery assets by freezing and finally confiscating them by two types of forfeiture, criminal and civil forfeitures. Establishing a code of conduct informing employees in banks and political parties of the risks of corruption and money laundering, creating a culture of honesty and high ethics and implementing Controlled Foreign Corporation legislation to cope with off-shore companies trading, can help to deter corruption and recover ill-gotten assets. Greek Legislation can cope with off-shore companies’ problems by implementing Controlled Foreign Corporation legislation (or CFC legislation). Controlled Foreign Corporation rules are features of an income tax system designed to limit artificial deferral of tax by using offshore low taxed entities. Taxpayers must include in their income statements, amounts earned by foreign entities they or related persons control. Simultaneously, Greece must fight not only political parties’ corruption but also corporate corruption. To fight such corruption Greece must fully implement the Business Principles for Countering Bribery (Business Principles) released by Transparency International (2009) intending to engage the private sector in anti-corruption efforts. An anti-corruption program should target areas such as political contributions, PEPs, charitable contributions and sponsorships, gifts, hospitality, and expenses. Disclosure of donors’ identity because public’s right to know about financial backers may interfere with the need to protect privacy of political preferences. A practical solution is distinguishing among categories of donors or defining a cut off point for privacy, e.g. 10,000 euros. But Hogan (2005), demonstrated that limits on political contributions leads to other forms of electioneering in support of candidates

such as increased voter mobilization. Also suggests that public subsides may divert more private resources and influence to outside groups. Currently none political party provides full transparency of all political revenues and expenditures. Reporting and monitoring revenues and expenditures in Greek Parliament with control from external charted accountants is a useful solution for transparency avoiding money laundering. Greek parties first have to follow an accounting system based on revenues and expenditures financial statements annually and publish them each year. Especially during election period, have to publish revenues and expenditures financial statements two months after elections (Law 3023/2002). But this is not really happening up to now. Also, Greece has to update the country’s anti-corruption laws, implementing laws such as UK Bribery Act in May 2010. Legislation must criminalize direct and indirect acts of general bribery (including commercial bribery), bribery of foreign officials and must exercise broad jurisdiction over all individuals and corporate entities occurs in Greece. Another solution for avoiding money laundering would be if Greek public subsidies were given to candidates or member of parliament rather than to political parties. Members of parliament should be free to make independent judgments that reflect constituency preferences and the common good rather than be influenced by particular groups. But politicians think that when public funds flow directly to candidates or members of parliament should weaken the party because members would become less reliant on the party for funds and would not create party cohesion. Literature suggests that party-controlled does not create party cohesion (Cantor and Herrnson, 1997; Damore and Hansford, 1999). There is also a need for international action on political party financing. OECD convention on bribery currently covers only the bribery of foreign public officials which includes members of parliament but does not extend to political party financing. Open issues on political corruption and political parties’ funding are: excessive reliance on the private sector for designing and implementing PEPs policy, problem of how far to expand PEPs coverage both vertically (down the hierarchy) or horizontally (to PEPs’ families and associates). Examining political funding and corruption we must see money laundering and anti-money laundering as coupled activities, subsystems each of which stimulates the other to expand its own powers within its particular domain, so that the harder that anti-money laundering pushes, money laundering pushes back. Argues that anti-money laundering is not a “solution” to the “problem” of money laundering, and that there can be no solution: money laundering is as old as money itself. Policy of party financing is difficult even if there are regulations, independent electoral commissions and parliamentary ethics committees. The effectiveness of measures depends on the commitment of the main political parties and electorate to more ethical behavior. References Cantor, D. and Herrnson, P. (1997), “Party campaign activity and party unity in the US House of Representatives”, Legislative Studies Quarterly, Vol. 22, pp. 393-415. Damore, D. and Hansford, T. (1999), “The allocation of party controlled campaign resources in the House of Representatives: 1986-1996”, Political Research Quarterly, Vol. 52, pp. 371-385.

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Featherstone, K. (1990), “The ‘party-state’ in Greece and the fall of Papandreou”, West European Politics, Vol. 13, pp. 101-115. Hogan, R. (2005), “State campaign finance laws and interest group electioneering activities”, Journal of Politics, Vol. 67, pp. 887-906. Newspaper Kathimerini (2010), 28 May/29 May (in Greek language). Pierre, J., Svasand, L. and Widfeldt, A. (2000), “State subsidies to political parties: confronting rhetoric with reality”, West European Politics, Vol. 23, pp. 1-24. Scarrow, S. (2007), “Explaining political finance reforms: competition and context”, Party Politics, Vol. 13, pp. 437-455. Transparency International (2009), Progress Report 2009: Enforcement of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, Transparency International, Berlin, June. About the author Spyridon Repousis received his BA degree in economics from the Athens University of Economics and Business in 1994, his MSc degree in banking and finance from University of Stirling, Scotland, UK, in 1995 and his PhD, degree in economics in 2012 from the Department of Economics, University of Peloponnese. Now, he is an MBA student in University of Nicosia, Cyprus. He has taught in Technological Educational Institute of Patras (state-owned educational institute) and he is working in a private bank. He has written scientific articles that have been published in English journals, in areas such as banking, finance, fraud and money laundering and has participated in international conferences. Spyridon Repousis can be contacted at: [email protected]

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