Does Slovakia implement an autonomous sanctions regime?
What is the nature of the sanctions regime in Slovakia?
Slovakia is a member state of the EU and UNSC sanctions are usually adopted by the EU. EU legislation is directly applicable in Slovakia. In cases where EU legislation does not impose UN Security Council sanctions, a national law is used to implement them. Under Act no. 126/2011 Coll. on implementation of International Sanctions, if the sanction does not follow from the directly applicable act of the EU, it should be declared by the Government of the Slovak Republic through a Government Decree.
Moreover, the EU 3rd Anti-Money Laundering Directive no. 2005/60/EC was implemented in Slovakia by Act no. 297/2008 Coll. on the prevention of money laundering and terrorist financing and on changes and amendments of some other acts. This Act stipulates the rights and obligations of companies and natural individuals on the prevention and detection of the use of the financial system for the purpose of money laundering and terrorist financing and also includes the penalties for non-compliance with this Act.
Does Slovakia maintain a list of sanctioned individuals and entities?
No – only the EU and UN lists.
Are there any other lists related to sanctions?
Does Slovakia have a licensing or authorization system in place?
The Slovak Act on implementation of International Sanctions stipulates that if a special permission, consent or preceding consent is required in connection with the implementation of the international sanctions the Central bodies, determined by the Act (see below their list and contact details), are responsible to act and decide.
What are the consequences for a breach of sanctions in Slovakia?
For breaching international sanctions the penalties according to Act no. 126/2011 Coll. on implementation of International Sanctions can be imposed, ranging from EUR 5,000- to EUR 132,800 in respect of private individuals and ranging from EUR 50,000- EUR to 1,659,700 in respect of companies or entrepreneurs.
Depending on the nature of the breach, in certain cases a breach of sanctions can also be considered as a criminal offence, in which case the penalties can also include the imprisonment of the liable individuals.
Who are the relevant regulators in Slovakia and what are their contact details?
There is no single central regulator responsible for the monitoring of the application of sanctions. The supervision of the application of sanctions is exercised by the following Central bodies, depending on the area of their authority:
Ministry of Economy of the Slovak Republic
827 15 Bratislava 212,
Central authority for AML reporting
The Central authority for AML reporting serves the Financial Intelligence Unit (“FIU”) at the National Criminal Agency of the Slovak Interior Ministry, Presidium of the police forces (Financná spravodajská jednotka)
Ministerstvo vnútra SR (Slovak Interior Ministry)
Financial Intelligence Unit – based at Police forces
National Bank of Slovakia and Ministry of Finance of the Slovak Republic in some circumstances in cooperation with the FIU. The National Bank of Slovakia and the Ministry of Finance are under an obligation to inform the FIU about an intended control of mandatory persons. The FIU together with the NBS or the MFSR may upon their agreement conduct joint control over mandatory persons.
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