Financial Crime World

Slovenia Tightens Restrictions on Financial Transactions

In an effort to comply with European Union (EU) and international regulations, Slovenia has introduced new measures aimed at preventing the misuse of financial transactions for illicit purposes.

Supervision and Implementation

The country’s institutions responsible for supervising the implementation of financial restrictive measures have been tasked with ensuring compliance with these regulations. The Bank of Slovenia, Securities Market Agency, and Insurance Supervision Agency are working together to monitor financial transactions and prevent any potential violations.

Fines for Violations

Those who fail to comply with these restrictions may face severe fines:

  • Legal persons: up to EUR 500,000 (Article 10a of the ZOUPAMO)
  • Individual sole traders or self-employed individuals: up to EUR 150,000
  • Responsible persons in legal entities: fine ranging from EUR 40 to EUR 10,000
  • Natural persons: up to EUR 5,000

In addition, violating these restrictions is considered a criminal offense under Article 374a of the Criminal Code. Legal entities may be held liable for such violations under Article 25 of the Liability of Legal Persons for Criminal Offences Act.

Coordination Efforts

To ensure more uniform implementation of restrictive measures, a Permanent Coordination Group (SKSOU) has been established. The group is headed by a representative from the Ministry of Foreign and European Affairs and is responsible for coordinating efforts between relevant bodies.

The Government may also adopt implementing acts to further regulate the implementation of restrictive measures, such as:

  • Designating additional competent authorities
  • Imposing additional fines

Lifting Sanctions

In some cases, individuals whose funds have been frozen may be able to file an application to lift these restrictions. The competent ministry will then review the request and decide whether to release a certain amount of funds for basic needs, such as:

  • Foodstuffs
  • Healthcare services
  • Other essential expenses

If the restrictive measures against a person or entity are lifted, the freeze on their funds will also be lifted. In addition, individuals or entities may submit requests to be removed from sanctions lists if they believe they were mistakenly included.

EU and UN Procedures

The procedures for lifting sanctions and de-listing vary depending on whether they are related to EU autonomous sanctions or UN Security Council measures:

  • Requests for removal from EU autonomous sanctions lists must be submitted to the Secretariat General of the Council of the EU.
  • Requests related to UNSC resolutions can be submitted directly to the relevant UNSC sanctions committee.

In Slovenia, listed persons may also request de-listing by submitting a request to the Ministry of Foreign and European Affairs. In addition, they may:

  • Institute proceedings against an EU act addressed to them in the General Court of the EU
  • File a lawsuit against a decree on their placement on sanctions lists with Slovenian courts