On 27th July, the Slovenian Office for Money Laundering Prevention from the Ministry of Finance published a new draft of their Prevention of Money Laundering and Terrorist Financing Act (ZPPDFT) to bring it in line with 4MLD. The EMA’s response raises 4 issues with the draft:
- The draft scope of the Act extends to credit institutions, payment institutions and electronic money institutions passporting into Slovenia on a cross-border basis under Freedom of Services, and should be limited to those authorised in Slovenia or operating in Slovenia under the Freedom of Establishment only;
- The translation of the term “payment instrument” as “electronic medium” is legally unclear, potentially narrowing the e-money exemption from CDD, so the original EU translation should be used
- The draft has incorrectly transposed the e-money CDD exemption by requiring EMIs providing reloadable cards that can be used outside of Slovenia to conduct CDD, regardless of any limits on the amount.
- The current draft translation of the redemption provision under the e-money exemption from CDD doesn’t permit redemption transfers over €100 to a bank account to be exempt from CDD, so should be amended.
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