Financial Crime World

Slovenia Implements Tough Sanctions for Violations of Restrictive Measures

Strengthening Efforts Against Terrorism and Other Threats

The Government of Slovenia has introduced a robust system to supervise the implementation of financial restrictive measures, aimed at combating terrorism and other threats.

Fines for Non-Compliance

According to Article 10a of the ZOUPAMO (Zakon o urejanju prekoračkovnih ukrepov v zvezi s trgovino), fines ranging from €200 to €500,000 will be imposed on legal entities that violate EU and national regulations on restrictive measures. Individuals, including sole traders and self-employed persons, face fines of between €200 and €150,000.

Supervision and Coordination

The supervision of the implementation of these sanctions falls under the remit of several institutions, including:

  • Bank of Slovenia
  • Securities Market Agency
  • Insurance Supervision Agency
  • Financial Administration of the Republic of Slovenia
  • Police
  • Internal Affairs Inspectorate
  • Defence Inspectorate

A Permanent Coordination Group (SKSOU) has been established to ensure uniform implementation of restrictive measures and coordination between relevant bodies. The group is headed by a representative of the Ministry of Foreign and European Affairs.

Crimes and Liability

Violations of restrictive measures are also considered a crime under Article 374a of the Criminal Code. Legal entities found guilty can face liability under Article 25 of the Liability of Legal Persons for Criminal Offences Act.

Lifting Sanctions and Freeze on Funds

In cases where a person’s funds have been frozen, they may file an application with the competent bodies to lift the sanction. A certain amount of funds will be released to cover basic needs, such as:

  • Foodstuffs
  • Healthcare services
  • Similar expenses

The freeze on funds is lifted when restrictive measures against a person cease to apply. Slovenian decrees implementing UN or EU acts automatically cease to apply when the acts in question cease to apply.

De-Listing

If it is established that persons, groups, or entities are wrongly included in an EU, UN, or Slovenian sanctions list, they may submit a request for removal from the list(s). The procedures for de-listing vary depending on whether they are related to:

  • Autonomous EU sanctions: Requests are submitted to the Secretariat General of the Council of the EU.
  • UN Security Council measures: Requests are submitted directly to the relevant UNSC sanctions committee via the UNSC focal point or via the Ministry of Foreign and European Affairs.

In Slovenia, listed persons may also request de-listing from the Slovenian sanctions list by submitting a request to the Ministry of Foreign and European Affairs. They may also institute proceedings before Slovenian courts against decrees on their placement on sanctions lists.

Conclusion

The implementation of these measures is aimed at strengthening Slovenia’s efforts in combating terrorism and other threats, while ensuring effective coordination and supervision between relevant institutions.