1. Does Slovenia have a sanctions regime in place?
2. Does Slovenia implement UN sanctions?
Yes. Since Slovenia is an EU member state, sanctions imposed by binding UNSC resolutions are, as a rule, incorporated through EU legislation, EU decisions and/or Regulations.
3. Does Slovenia implement an autonomous sanctions regime?
Yes, the Act that empowers the Slovenian government to impose sanctions is the Act Regulating Restrictive Measures Introduced or Implemented by the Republic of Slovenia in Accordance with Legal Acts and Decisions Adopted by International Organisations (hereinafter the ZOUPAMO).
4. What is the nature of the sanctions regime in Slovenia?
ZOUPAMO grants special powers to the Slovenian government to introduce or implement sanctions. The government does this by adopting decrees. All restrictive measures that are currently implemented in Slovenia are presently based on the UNSC and EU legal instruments.
The decrees issued on the basis of ZOUPAMO define the violations of restrictive measures as misdemeanours. However, particular violations may involve elements of criminal acts (e. g. trade in weapons) as defined in the Criminal Code.
5. Does Slovenia maintain a list of sanctioned individuals and entities?
No, Slovenian regulations refer to the relevant EU or UN lists.
6. Are there any other lists related to sanctions in Slovenia?
7. Does Slovenia have a licensing or authorization system in place?
Yes. For some countries under sanctions, the Ministry of Economic Development and Technology is responsible for issuing licences for certain listed goods in relation to their end use subject to restrictive requirements.
8. What are the consequences for a breach of sanctions in Slovenia?
For violations of restrictive measures fines, provided by Government decrees, can be imposed. However, it is important to note that certain violations may involve elements of criminal acts (e. g. trade in weapons) as defined in the Criminal Code.
9. Who are the relevant regulators in Slovenia and what are their contact details?
The supervision of the implementation of ZOUPAMO and government decrees is carried out by public administration bodies, other entities under public law and bearers of public authority responsible for the domains to which the restrictive measures apply, unless otherwise specified by directly applicable EU legal acts. For uniform implementation of restrictive measures and coordination between the relevant bodies, the entity responsible is the Permanent coordination group for restrictive measures, established by the Government and headed by a representative of the Ministry of Foreign Affairs: Ministry of Foreign Affairs of the Republic of Slovenia Presernova cesta 25 SI-1001 Ljubljana, P.P 481 Slovenia T: (+386) 1 478 2000 E: firstname.lastname@example.org
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Mojca Nadles, LL.M. (Harvard)
Sara Ermenc Junior Associate
Odvetniška družba Rojs,
Prelesnik & partnerji o.p., d.o.o.,
Tivolska cesta 48, 1000 Ljubljana,
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