Stricter Anti-Money Laundering (AML) Rules
Information for managing directors, compliance specialists and accountants
The amended AML Act has brought a fundamental shift in how companies and professional entities must approach the vetting of their business partners. Below is a concise overview of the key obligations:
Overview of the main legislative changes
Mandatory independent verification of the ultimate beneficial owner (UBO): Consulting the public register or obtaining a sworn statement from the client is no longer sufficient. The ultimate beneficial owner must be actively evidenced from internal legal documents (e.g. articles of association or shareholders’ agreements).
Switch to the goAML reporting system: Reporting of unusual business transactions through the existing channels is being discontinued. All obliged entities must register with the national goAML portal by the end of November at the latest.
Establishment of the Register of Foreign Trusts: The new register, administered by the Ministry of the Interior of the Slovak Republic, requires mandatory registration of foreign trusts that acquire real estate or enter into business relationships in the Slovak Republic.
Focus on actual influence within the company: Verification now extends beyond ownership interests to informal managers and persons who exercise de facto decision-making power in the business.
Priority tasks for your organisation:
Review of the AML policy: Incorporate the new methodology for verifying business partners using multiple independent sources.
Registration in goAML: Create an account in the portal without undue delay.
Client re-audit: Review and complete client files for ongoing business relationships.