law, torture performed “systematically”, using certain specific methods (electroshock, mock executions, etc.), incurs a prison sentence of a minimum of ten years, whereas “ordinary” torture incurs a prison sentence of up to ten years. This is a distinction with great practical significance, both in terms of the actual time served in the vast majority of cases involving torture, and in terms of the applicable rules on commuting prison sentences. It is worth noting that both these sentences constitute a regression from the previous framework, which provided for a prison sentence of up to twenty years and did not distinguish between different types of torture. Second, in addition to allowing the conversion of prison sentences for torture into non-custodial sentences, Greece also continues to apply limitation periods to the prosecution of torture, despite being strongly urged by international actors to abolish them. Practical Barriers While Greek authorities consistently refute allegations on the widespread use of torture and illtreatment against persons in police custody, the CPT has recorded a multitude of suspect or confirmed incidents and considers the indications that such actions systemically take place as “overwhelming”. It has, thus, urged Greece to take concrete action, going as far as warning to set in motion the procedure of Article 10, paragraph 2 of the Convention, and issue a statement publicly condemning the State’s practices (see the CPT Report on its visit to Greece from 28 March to 9 April 2019). The CPT has highlighted the following key areas of concern:  Inadequate investigations, which are not carried out promptly, expeditiously or thoroughly;  Ineffective mechanisms for the gathering of forensic medical evidence in instances of alleged torture; and  Systematic conversion of all prison sentences into non-custodial sentences. Similar concerns have been raised by the CAT, in the context of its concluding observations on the seventh periodic report of Greece. Despite the CAT specifically requesting it, Greece has failed to provide complete information on the number of complaints of torture or ill- treatment, the corresponding investigations and prosecutions, or disciplinary action taken against the offenders, including their removal from public service pending the outcome of the investigations against them. Greece has also failed to provide any examples of cases dismissed by the courts due to the submission of evidence or testimonies/confessions having been obtained through torture or ill treatment. The above mentioned legislative deficiencies and problematic practices in relation to the investigation and prosecution of torture perpetrated by law enforcement officers have led to the establishment of a culture of impunity, as observed by the CPT and corroborated by a number of convictions by the European Court of Human Rights for lenient sentencing and ineffective investigations (see cases of Zontul and Makaratzis, among others). This culture leaves open the possibility of evidence obtained through torture to be used in criminal proceedings, especially in cases involving migrants, Roma, and other vulnerable groups. Policy barriers - The National Mechanism Despite the fact that it does not officially acknowledge the issues raised above, the Greek State has established a “National Mechanism for the Investigation of Arbitrary Incidents by Law Enforcement and Prison Officers” within the Ombudsman’s Office. The Mechanism began its operation in June 2017 with a mandate to collect, record, assess and further transmit to the competent bodies complaints about the actions of law enforcement officers regarding a) torture and other violations to human dignity; b) intentional and unlawful violations against life, physical integrity, health, personal or sexual freedom; c) unlawful use of a firearm; or d) racial or hate-motivated crimes. 35