1. Does Slovakia have a sanctions regime in place?
2. Does Slovakia implement UN sanctions?
3. Does Slovakia implement an autonomous sanctions regime?
4. What is the nature of the sanctions regime in Slovakia?
Slovakia is a member state of the European Union (“EU”) and United Nations Sanctions Council (“UNSC”). Sanctions are usually adopted by the EU. EU legislation consists of regulations, directives, decisions and other legal acts, of which regulations are directly applicable in every member state (Slovakia as well) and directives have to be implemented. In cases where EU legislation does not impose UNSC sanctions, a national law is used to implement them. Under Act no. 289/2016 Coll. on implementation of international sanctions, if the sanction does not follow from the directly applicable act of the EU or UNSC, 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. 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.
5. Does Slovakia maintain a list of sanctioned individuals and entities?
Only the EU and UN lists.
6. Are there any other lists related to sanctions?
7. Does Slovakia have a licensing or authorization system in place?
The Slovak Act on implementation of international sanctions stipulates that if a special permission, exception, 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.
8. What are the consequences for a breach of sanctions in Slovakia?
For breaching international sanctions, the penalties according to Act No. 289/2016 Coll. on implementation of international sanctions can be imposed, ranging from EUR 109 to EUR 132,800. If the sanction is infringed by a legal person or a natural person that is an entrepreneur and the damage caused exceeded the amount of EUR 16.600 or if they have obtained for herself/himself or a third party a benefit exceeding the amount of EUR 16.600, then a penalty of up to EUR 132 800 and EUR 1.659.700 can be imposed.
Depending on the nature of the breach, in certain cases a breach of sanctions can also be considered as a criminal offense, in which case the penalties can also include the imprisonment of the liable individuals.
9. Who are the relevant regulators in Slovakia and what are their contact details?
There is still no single central regulator responsible for the monitoring of the application of sanctions. The supervision of the application of sanctions is exercized by the following Central bodies, depending on the area of their authority:
Ministry of Economy of the Slovak Republic Mierová 19, 827 15 Bratislava 212, Slovakia T: (+421) 2 4854 1111 F: (+421) 2 4333 7827 W: www.economy.gov.sk
Ministry of Transport and Construction of the Slovak Republic Námestie slobody č. 6, P.O. BOX 100, 810 05 Bratislava, Slovakia T: (+421) 2 5949 4111 F: (+421) 2 5249 4794 W: www.telecom.gov.sk
Ministry of Culture of the Slovak Republic Nám. SNP č. 33 813 31 Bratislava Slovakia T: (+421) 2 20482 111 F: (+421) 2 20482 271 W: www.culture.gov.sk
Ministry of Education, Science, Research and Sport of the Slovak Republic Stromová 1, 813 30 Bratislava, Slovakia T: (+421) 2 5937 4111 F: (+421) 2 5937 4335 W: www.minedu.sk
Ministry of Interior of the Slovak Republic Pribinova 2, 812 72 Bratislava, Slovakia T: (+421) 2 5094 1111 F: (+421) 2 5094 4397 W: www.minv.sk
Ministry of Labour, Social Affairs and Family of the Slovak Republic Špitálska 4, 6, 8 816 43 Bratislava- Staré Mesto, Slovakia T: (+421) 2 2046 0000 W: www.employment.gov.sk
Ministerstvo spravodlivosti Slovenskej republiky
Župné námestie 13 813 11 Bratislava 1 T: (+421) 2 5935 3111 F: (+421) 2 5935 3600 W: www.justice.gov.sk
Ministry of Agriculture and Rural Development of the Slovak Republic
Dobrovičova 12 811 09 Bratislava T: (+421) 2 529 210 77 W: http://www.mpsr.sk
Ministry of Foreign and European Affairs of the Slovak Republic Hlboká cesta 2, 811 04 Bratislava 37, Slovakia
Central authority for AML reporting The Central authority for AML reporting is Finančná spravodajská jednotka – Financial Intelligence Unit (“FIU”), which is under the Ministry of Interior of the Slovak Republic. FIU has a status of a supervisory body against all the mandatory persons according to the AML Act. Ministry of Interior of the Slovak Republic Presidium of the Police Force Financial Intelligence Unit Pribinova 2 812 72 Bratislava E: firstname.lastname@example.org Notifications on suspicious trade operations are to be reported here: email@example.com T: (+421) 9610 51402 F: (+421) 9610 59047
AML regulator(s) 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.
Ministry of Health of the Slovak Republic
Limbová 2 P.O. BOX 52 837 52 Bratislava T: (+421) 2 546 506 58 W: https://www.health.gov.sk/Titulka
Ministry of Environment of the Slovak Republic
Námestie Ľudovíta Štúra 35/1 812 35 Bratislava T: (+421) 2 595 611 11 W: https://www.minzp.sk/
National Bank of Slovakia (“NBS”) and Ministry of Finance of the Slovak Republic (“MFSR”) in some circumstances cooperate 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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