The Slovak Parliament approved a government bill amending and supplementing the Act on Protection Against Money Laundering and Terrorist Financing (AML). The amendment addresses deficiencies in Slovak legislation identified by the Committee of Experts of the Council of Europe on the Evaluation of Anti-Money Laundering Measures.
The previous legislation showed significant deficiencies in the identification and verification of beneficial owners, trust arrangements, identification of persons performing management functions, and powers related to suspicious transactions.
◼ Overview of the main changes
The most important changes introduced by the government bill affect several laws, mainly the Act on Protection Against Money Laundering and Terrorist Financing. The main amendments include the following:
- 1) Amendment to the definition of the beneficial owner in the case of an arrangement of assets – when identifying future beneficiaries of funds, it will no longer be required that such persons receive a “significant” benefit from the establishment or operation of the arrangement of assets. Also, the definition is supplemented by a new rule under which a natural person is considered a beneficial owner if that person exercises actual control over the assets of the arrangement through direct or indirect ownership or by other means.
- 2) Inclusion of the concept of a trust – an arrangement of assets in the form of a foreign trust is also considered an arrangement in which a natural person benefits as a beneficial owner.
- 3) Identification of members of the governing body of a legal entity – the identification process for legal entities as beneficial owners is amended. In addition to the name and surname of the managing director, the names and surnames of persons who are members of the governing body of the legal entity or arrangement of assets must also be identified.
- 4) Verification from multiple sources – the so-called basic due diligence procedure is amended. Information on beneficial owners must now be verified not only through the Commercial Register, but also through the Register of Legal Entities and Public Authorities, as well as foundation agreements and related documents.
If an unusual transaction is identified, a report on an unusual business operation must be submitted immediately.
- 5) New GoAML information system – the legislation formally incorporates the new information system of the Financial Intelligence Unit of the Police Presidium for the receipt and analysis of unusual business operations. The system has already been operational since 1 January 2025. Reporting entities must register in this information system within 30 days from the identification of an unusual business transaction.
- 6) Administration of foreign trusts – a trustee of a foreign trust established in Slovakia will be required to maintain and update records of managed assets for at least five years.
◼ Register of foreign trusts
The government bill introduces a new register of foreign trusts. The register will be administered by the Ministry of Interior of the Slovak Republic as a public administration information system. This change follows recommendations of the European Commission requiring Slovak legislation to address foreign trust arrangements.
This mainly concerns situations where:
- a trust established under foreign law has links to Slovakia
- the trustee has residence in Slovakia
- business relationships are carried out in Slovakia
- real estate under trust administration is located in Slovakia
A trustee of a foreign trust established in Slovakia will therefore be required to register beneficial ownership information in the following structure:
- name or designation of the foreign trust
- registered office or address where the trust is administered, if no registered office exists
- identifier assigned to the foreign trust in the state where it was established
- identification details of the settlor, trustee, person supervising the administration of the trust, beneficiaries of the trust assets, and persons exercising actual control over the trust
- details of the beneficial owner
Registration may be carried out at any district office located in a regional capital. The foreign trust will receive a unique identifier under which it will be recorded in the register of foreign trusts.
Registration of a foreign trust in the register does not affect cadastral proceedings or the validity of agreements under which a foreign trust acquires real estate. The cadastral department of the district office will not examine registration in the register of foreign trusts.
◼ Amendments related to other legislation
As part of addressing deficiencies in Slovak legislation, the government also incorporated amendments into other laws. Below is a summary of the most important impacts on legal entities and individuals in business activities.:
| Type of legislation | Description of amendment or impact |
| Trade Licensing Act | The Act introduces a condition of integrity of the beneficial owner for legal entities authorised to provide asset management services, for example activities related to the start of business operations |
| Administrative Fees Act | The schedule of administrative fees is supplemented by official fees for: registration of a foreign trust (EUR 100) and changes to registered data (EUR 25) |
| Act on the Register of Legal Entities, Entrepreneurs and Public Authorities | Data from the register of foreign trusts will be provided to the Register of Legal Entities, Entrepreneurs and Public Authorities, which serves as the central register of beneficial owners.
At the same time, unrestricted access to the register of beneficial owners will be limited. For the protection of personal data, access will only be granted upon demonstration of a legitimate interest related to the prevention of money laundering, terrorist financing, related predicate offences, and measures against them. |
| Act on the Implementation of International Sanctions | The amendments introduce a more effective administrative procedure for the implementation of international sanctions in accordance with FATF requirements. The Act will also allow sanctions to be imposed for misdemeanours |
All of the above amendments will enter into force on 1 June 2026.
◼ Practical implications
In connection with the amendments concerning beneficial owners and foreign trusts, we would like to highlight the following practical implications of the government bill:
- stricter identification of beneficial owners and increased administrative burden for verification of information
- increased requirements for foreign clients and identification of their beneficial owners
- mandatory registration of foreign trusts
- stricter verification of transactions, ownership structures, and business relationships involving foreign trusts
- increased administrative burden and costs related to new reporting obligations and updates of internal verification processes
