Response to Slovenian Prevention of Money Laundering and Terrorist Financing Act

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.

[button link=”” style=”download” color=”green”]Download full response (PDF)[/button]