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title: "Slovakia (SK) — Financial-Integrity Intelligence · Sentinel"
canonical: https://sentinel.gi/jurisdictions/slovakia/
source_html: /jurisdictions/slovakia/index.html
description: "Financial integrity intelligence for Slovakia (SK): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings."
generated_at: 2026-11-08T04:46:02Z
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# Slovakia (SK) — Financial-Integrity Intelligence · Sentinel

Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above &ldquo;Probable&rdquo; until stronger sources are retrieved.

Financial Integrity Monitor

# Slovakia SK

Domains covered

8 of 8

Sources

153

Role actions

8

Horizon <90d

0

Jurisdiction profile

FATF status: Largely Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed

Slovakia&#x27;s AML/CFT regime rests on the AML Act (297/2008), MONEYVAL/FATF-assessed since 2020 MER, with the Financial Intelligence Unit as core authority. More Slovakia has 5 Compliant, 23 Largely Compliant and 12 Partially Compliant FATF ratings, remains in enhanced follow-up, and was placed into compliance-enhancing procedures over persistent CDD (R.10) and VASP-supervision deficiencies. EU AMLR/AMLA membership pending 2027 application.

Key deficiencies

- No risk-based supervision of virtual asset service providers by the FIU
- Recommendation 10 (customer due diligence) remains Partially Compliant, triggering FATF/MONEYVAL compliance-enhancing procedures
- Erosion of prosecutorial independence following abolition of the Office of the Special Prosecutor and penal code softening
- Weak verification framework for beneficial ownership register data despite public accessibility

Recent developments (18m)

- MONEYVAL/FATF Follow-Up Report (28 Jan 2025) re-rated R.26 from Partially to Largely Compliant but kept R.8/R.15/R.19 at Partially Compliant
- Slovak Republic placed into FATF/MONEYVAL compliance-enhancing procedures (step 1) over the &#x27;big six&#x27; R.10 deficiency
- Further MONEYVAL/FATF Follow-Up Report adopted 23 March 2026 tracking continued technical-compliance progress
- Slovakia jointly with Hungary blocked/delayed EU Russia sanctions packages (18th package, mid-2025; 20th package, Feb 2026) over Druzhba pipeline oil flows and Russian energy carve-outs
- European Commission continued rule-of-law scrutiny and plenary debates (Sept 2025, Feb 2026) on Slovak justice reforms and misuse of EU funds
- Slovak Constitutional Court struck down Fico government NGO-transparency and whistleblower-protection rollback legislation (Dec 2025)
- Transparency International&#x27;s 2025 CPI recorded Slovakia&#x27;s score falling to 48, citing weakened safeguards against political influence over corruption investigations

Law made at European Economic Area level that applies in Slovakia is covered once, on the [European Economic Area](/jurisdictions/eea/) page. This page covers Slovakia&#8217;s own layer: implementation, national authorities, national options and local enforcement.

Brief

## Lead signal

#### Lead Signal

The one confirmed structural development touching Slovakia this cycle sits in commercial banking rather than in enforcement or sanctions architecture. 365.bank, the Bratislava retail bank that has been under near-full ownership of Belgium&#x27;s KBC Group since a transaction reported at approximately EUR 708 million completed in January 2026, has legally merged into CSOB effective 1 November 2026. Brand coexistence is expected to continue into 2027 while customer-facing systems migrate, but the legal entity itself no longer exists as a separate obliged institution. This is an architecture story, not an incident: two previously distinct Slovak-licensed obliged entities now sit under a single legal and compliance perimeter, both ultimately controlled by the same Belgian banking group.

Read full brief

#### Lead Signal

The one confirmed structural development touching Slovakia this cycle sits in commercial banking rather than in enforcement or sanctions architecture. 365.bank, the Bratislava retail bank that has been under near-full ownership of Belgium&#x27;s KBC Group since a transaction reported at approximately EUR 708 million completed in January 2026, has legally merged into CSOB effective 1 November 2026. Brand coexistence is expected to continue into 2027 while customer-facing systems migrate, but the legal entity itself no longer exists as a separate obliged institution. This is an architecture story, not an incident: two previously distinct Slovak-licensed obliged entities now sit under a single legal and compliance perimeter, both ultimately controlled by the same Belgian banking group.

The significance of a merger like this is structural rather than evidentiary of any wrongdoing. Consolidating two obliged entities into one reduces the number of distinct compliance programmes, reporting lines, and transaction-monitoring environments that previously existed in parallel within the same ownership group. Whether that consolidation strengthens or weakens the overall control environment is not established by the available material; what is established is that the perimeter has narrowed, and that narrowing is itself worth tracking as KBC&#x27;s Slovak footprint consolidates under one roof.

#### Other Developments

Slovakia&#x27;s standing anti-money-laundering posture continues to be described favourably by regional evaluators. The Council of Europe&#x27;s MONEYVAL committee has found that Slovakia has made significant progress in improving its anti-money-laundering and counter-terrorist-financing framework, with upgrades recorded across eight recommendations including those concerning politically exposed persons. Slovakia has been released from the enhanced follow-up process that applied after its fifth-round evaluation, with the next on-site evaluation not expected until October 2028. This is standing context rather than a new development this cycle, but it frames the baseline against which any future Slovak AML/CTF finding should be read.

Slovakia&#x27;s transition from its prior virtual-asset-service-provider regime to the EU&#x27;s Markets in Crypto-Assets framework has closed. Using the national discretion available under Article 143 of the Markets in Crypto-Assets Regulation, Slovakia closed its transitional window early, ending 30 December 2025 rather than running the full transitional period some other member states elected. No new Slovak-specific crypto-integrity enforcement or evasion signal has been located this window; the closure itself is the extent of the dated development, and it is now part of the stable baseline rather than an active signal.

At the European level, the Anti-Money Laundering Authority has continued its preparatory work toward the first selection cycle for entities that will fall under its direct supervision from 2027. This is described as a key preparatory step on the European Union&#x27;s own timeline, running in parallel with the broader Anti-Money Laundering Regulation and the sixth Anti-Money Laundering Directive. Nothing in the material available this cycle ties this preparatory work to a Slovak-specific action or entity; it is noted here as continuing structural backdrop against which Slovak obliged entities, including the newly consolidated CSOB-365.bank perimeter, will eventually be assessed.

#### Cross-Monitor Connections

The consolidation of 365.bank into CSOB is primarily a matter for commercial and corporate-structure analysis, but it has a secondary relevance to monitors tracking cross-border banking-group structures across Central and Eastern Europe, since it reduces the number of distinct legal entities through which KBC Group&#x27;s regional exposure is booked. Readers tracking state-capture or beneficial-ownership concentration questions elsewhere in the region may find this consolidation relevant background when comparing how banking groups with footprints across multiple EU member states structure their local subsidiaries. No sanctions-evasion, conflict-finance, or extractive-industry nexus is indicated by the material reviewed this cycle, and no connection to information-operations or state-capture monitors is evidenced here.

#### Outlook

The near-term question for Slovakia is how the newly merged CSOB entity integrates 365.bank&#x27;s customer base and systems through to the expected completion of brand migration in 2027, and whether that integration period surfaces any compliance-perimeter friction as two previously separate monitoring and reporting environments are combined. Slovakia&#x27;s AML/CTF framework stands on a comparatively strengthened footing following its most recent MONEYVAL follow-up, with the next full evaluation not due until October 2028, so no near-term evaluative event is expected to test that framework. Separately, Slovakia&#x27;s early closure of its crypto-asset transitional window means Slovak-authorised crypto-asset service providers are now operating fully under the Markets in Crypto-Assets Regulation, a backdrop against which any future Slovak-specific digital-asset finding will be read. As scheduled, the Anti-Money Laundering Authority&#x27;s preparatory work toward its 2027 direct-supervision selection continues on its EU-wide timeline; whether any Slovak entity, including the consolidated CSOB-365.bank perimeter, falls within the first selection cohort is not yet established.

Earlier periodic briefs (7) 4 Nov 2026 · fim-2026-11-04

#### Lead Signal

The one confirmed structural development touching Slovakia sits in commercial banking rather than in enforcement or sanctions architecture. 365.bank, the Bratislava retail bank that has been under near-full ownership of Belgium&#x27;s KBC Group since a transaction reported at approximately EUR 708 million completed in January 2026, has legally merged into CSOB effective 1 November 2026. Brand coexistence is expected to continue into 2027 while customer-facing systems migrate, but the legal entity itself no longer exists as a separate obliged institution. This is an architecture story, not an incident: two previously distinct Slovak-licensed obliged entities now sit under a single legal and compliance perimeter, both ultimately controlled by the same Belgian banking group.

The significance of a merger like this is structural rather than evidentiary of any wrongdoing. Consolidating two obliged entities into one reduces the number of distinct compliance programmes, reporting lines, and transaction-monitoring environments that previously existed in parallel within the same ownership group. Whether that consolidation strengthens or weakens the overall control environment is not established by the available material; what is established is that the perimeter has narrowed, and that narrowing is itself worth tracking as KBC&#x27;s Slovak footprint consolidates under one roof.

#### Other Developments

Slovakia&#x27;s standing anti-money-laundering posture continues to be described favourably by regional evaluators. The Council of Europe&#x27;s MONEYVAL committee has found that Slovakia has made significant progress in improving its anti-money-laundering and counter-terrorist-financing framework, with upgrades recorded across eight recommendations including those concerning politically exposed persons. Slovakia has been released from the enhanced follow-up process that applied after its fifth-round evaluation, with the next on-site evaluation not expected until October 2028. This is standing context rather than a new development, but it frames the baseline against which any future Slovak AML/CTF finding should be read.

Slovakia&#x27;s transition from its prior virtual-asset-service-provider regime to the EU&#x27;s Markets in Crypto-Assets framework has closed. Using the national discretion available under Article 143 of the Markets in Crypto-Assets Regulation, Slovakia closed its transitional window early, ending 30 December 2025 rather than running the full transitional period some other member states elected. No new Slovak-specific crypto-integrity enforcement or evasion signal has been located this window; the closure itself is the extent of the dated development, and it is now part of the stable baseline rather than an active signal.

At the European level, the Anti-Money Laundering Authority has continued its preparatory work toward the first selection cycle for entities that will fall under its direct supervision from 2027. This is described as a key preparatory step on the European Union&#x27;s own timeline, running in parallel with the broader Anti-Money Laundering Regulation and the sixth Anti-Money Laundering Directive. Nothing in the material available ties this preparatory work to a Slovak-specific action or entity; it is noted here as continuing structural backdrop against which Slovak obliged entities, including the newly consolidated CSOB-365.bank perimeter, will eventually be assessed.

#### Cross-Monitor Connections

The consolidation of 365.bank into CSOB is primarily a matter for commercial and corporate-structure analysis, but it has a secondary relevance to monitors tracking cross-border banking-group structures across Central and Eastern Europe, since it reduces the number of distinct legal entities through which KBC Group&#x27;s regional exposure is booked. Readers tracking state-capture or beneficial-ownership concentration questions elsewhere in the region may find this consolidation relevant background when comparing how banking groups with footprints across multiple EU member states structure their local subsidiaries. No sanctions-evasion, conflict-finance, or extractive-industry nexus is indicated by the material reviewed, and no connection to information-operations or state-capture monitors is evidenced here.

#### Outlook

The near-term question for Slovakia is how the newly merged CSOB entity integrates 365.bank&#x27;s customer base and systems through to the expected completion of brand migration in 2027, and whether that integration period surfaces any compliance-perimeter friction as two previously separate monitoring and reporting environments are combined. Slovakia&#x27;s AML/CTF framework stands on a comparatively strengthened footing following its most recent MONEYVAL follow-up, with the next full evaluation not due until October 2028, so no near-term evaluative event is expected to test that framework. Separately, Slovakia&#x27;s early closure of its crypto-asset transitional window means Slovak-authorised crypto-asset service providers are now operating fully under the Markets in Crypto-Assets Regulation, a backdrop against which any future Slovak-specific digital-asset finding will be read. As scheduled, the Anti-Money Laundering Authority&#x27;s preparatory work toward its 2027 direct-supervision selection continues on its EU-wide timeline; whether any Slovak entity, including the consolidated CSOB-365.bank perimeter, falls within the first selection cohort is not yet established.

3 Nov 2026 · fim-2026-11-03

#### Lead Signal

The one dated development in Slovakia sits in commercial activity rather than enforcement. 365.bank, the Bratislava retail bank majority-controlled by KBC Group, legally merges into CSOB on 1 November 2026, consolidating two Slovak-licensed obliged entities under a single legal and compliance perimeter. The reported transaction value is EUR 708 million, with CSOB holding a 98.45 percent stake going into completion. This is a structural consolidation of the obliged-entity landscape, not an integrity finding in itself, but it is the kind of architecture-level shift the monitor tracks because it changes who is accountable for AML/CTF controls across two previously separate institutions.

The sourcing for this development rests on a tertiary account that cites the acquirer&#x27;s own newsroom, rather than a primary CSOB or KBC release opened directly this pass. That gap is noted rather than papered over: the merger date and structure are treated as probable rather than confirmed pending a primary-source read.

#### Other Developments

No new sanctions-evasion, beneficial-ownership, enabler-jurisdiction or compliance-technology signal was located for Slovakia. These typology areas remain on their standing baseline, with no dated development to report.

Slovakia&#x27;s anti-money-laundering framework continues on an improving standing trajectory. MONEYVAL&#x27;s fifth-round follow-up report, issued in March 2026, found that Slovakia had made significant progress strengthening its anti-money-laundering and counter-terrorist-financing framework, with upgrades recorded on eight recommendations including those concerning politically exposed persons. Slovakia was released from enhanced follow-up ahead of a sixth-round onsite evaluation scheduled for October 2028. This is a standing-posture confirmation rather than a new cycle event, but it is the backdrop against which the single commercial development should be read.

Slovakia&#x27;s transition from the prior virtual-asset-service-provider regime to the Markets in Crypto-Assets authorisation regime closed on 30 December 2025 , with Slovakia having used the national discretion available under the regulation to close its transitional window early. No new Slovakia-specific enforcement or evasion signal attaches to digital assets; this is carried forward as stable.

#### Cross-Monitor Connections

The 365.bank-CSOB consolidation is the kind of event that properly belongs on the payments side of the fleet&#x27;s coverage as a commercial and market-structure matter, while this monitor&#x27;s interest in it is narrower: a merger of two obliged entities concentrates compliance accountability and worth tracking for whether consolidated AML/CTF governance proves adequate across the combined institution post-completion. No conflict-finance or extractive-industry signal, and no state-capture indicator, arose for Slovakia. The European Union&#x27;s Anti-Money Laundering Authority continues preparatory work toward its 2027 first selection cycle for entities under direct supervision, a structural development that sits above any single Member State and has no Slovakia-specific dating this window; it is noted here as context for how Slovakia&#x27;s own supervisory architecture will eventually interface with the Authority once direct-supervision selection begins.

#### Outlook

Slovakia&#x27;s improving AML/CTF standing, confirmed by MONEYVAL&#x27;s March 2026 follow-up, gives the jurisdiction room before its next onsite evaluation in October 2028. The nearer-term item to watch is how the 365.bank-CSOB merger completion translates into consolidated compliance practice, and whether a primary-source account of the transaction becomes available to firm up what is currently a probable, tertiary-sourced finding. Absent new material in sanctions, beneficial ownership, enabler-jurisdiction exposure, conflict finance, digital assets or compliance technology, Slovakia&#x27;s broader risk posture is read as stable on a mixed enforcement-and-enablement basis, with no indication of a near-term shift in either direction.

25 Oct 2026 · fim-2026-10-25

#### Lead Signal

Slovakia has enacted a confirmed tightening of its beneficial-ownership verification regime. Zakon c. 73/2026 Z.z., approved by the National Council on 14 April 2026 and published 6 May 2026, amends the standing AML/CFT Act (Zakon c. 297/2008 Z.z.) to require multi-source verification of beneficial owners, extends the scope of identification duties to foreign trusts and asset pools, mandates filing exclusively through the goAML system, and restricts public access to beneficial-ownership register data to requesters who can demonstrate a legitimate interest. The general provisions of the amendment took effect on 1 June 2026, while the narrower provisions restricting public UBO-register access (Article XI, points 14 and 15) took effect on 10 July 2026. The instrument states its own purpose as remedying deficiencies previously identified by MONEYVAL, placing Slovakia among the enabler-jurisdiction correction cases where legislative remediation is visibly underway rather than merely announced.

The amendment does not resolve every structural concern raised about the Slovak beneficial-ownership regime. UBO data continues to be held within a non-public section of the Commercial Register rather than in a freestanding public register, a structural feature that outside observers have continued to flag as a continuing adequacy concern notwithstanding the verification-tightening changes. The co-existence of stronger verification duties with continued restricted public access is itself an architectural signal: Slovakia is strengthening who must be identified and how, while narrowing who may see the result.

#### Other Developments

Mandatory goAML filing extends across sectors. The amended AML/CFT Act requires obliged entities, including banks, payment companies, and crypto-asset operators, to register with and file unusual-transaction reports exclusively through the goAML system, subject only to narrow outage exceptions. Secondary commentary diverges on the exact registration deadline applicable to existing obliged entities, with reported dates of 30 November 2026 and 31 August 2026 circulating, possibly reflecting different sub-categories of obliged entity; the primary legislative text located supports the later date. This is flagged as an open discrepancy rather than resolved fact.

Dual supervision of crypto-asset service providers confirmed. The FATF/MONEYVAL 2025 follow-up report on Slovakia confirms a split-supervision architecture for crypto-asset service providers and asset-referenced-token issuers under Act 248/2024 Z.z.: the National Bank of Slovakia holds prudential supervisory authority, while the Financial Intelligence Unit holds AML/CFT supervisory authority over the same population of firms. This bifurcation is a structural feature of the Slovak regime, not a transitional artefact, and separates the solvency and conduct oversight line from the illicit-finance oversight line for the same regulated population.

Crypto-asset market context. A National Bank of Slovakia survey as of 8 October 2026 reports six entities holding MiCA-derived crypto-asset service provider authorisation, with a seventh (Tatra banka) reported as pending, and approximately six percent of Slovak adults reported as holding crypto-assets. This is market-structure context adjoining the supervisory architecture rather than itself a supervisory-architecture change.

#### Cross-Monitor Connections

The beneficial-ownership tightening and the crypto dual-supervision finding both intersect directly with the World Payments Monitor&#x27;s coverage of Slovakia&#x27;s MiCA implementing law and crypto-asset service provider authorisation population, since the same six-to-seven licensed entities and the same NBS/FIU supervisory split are relevant to payments-sector market access as well as to financial-integrity oversight. The data-protection dimension of the beneficial-ownership register&#x27;s restricted public access provisions also connects to the Data Protection Monitor&#x27;s interest in how legitimate-interest access gating is implemented in practice, though that implementation detail was not independently confirmed. No conflict-finance or sanctions-evasion nexus was identified for Slovakia.

#### Outlook

As an EU member state, Slovakia is bound directly by the EU AML Regulation once its supervisory architecture is fully operational, and Act 73/2026 Z.z. functions as an interim national tightening ahead of that fuller AMLR/AMLA build-out. The unresolved goAML registration-deadline discrepancy and the continued non-public structure of the Commercial Register&#x27;s UBO data are the two items most likely to generate further regulatory or commentary activity in coming cycles, as is clarification of how the legitimate-interest access test introduced on 10 July 2026 is being applied in practice.

18 Oct 2026 · fim-2026-10-18

#### Lead Signal

Slovakia has enacted a confirmed tightening of its beneficial-ownership verification regime. Zakon c. 73/2026 Z.z., approved by the National Council on 14 April 2026 and published 6 May 2026, amends the standing AML/CFT Act (Zakon c. 297/2008 Z.z.) to require multi-source verification of beneficial owners, extends the scope of identification duties to foreign trusts and asset pools, mandates filing exclusively through the goAML system, and restricts public access to beneficial-ownership register data to requesters who can demonstrate a legitimate interest. The general provisions of the amendment took effect on 1 June 2026, while the narrower provisions restricting public UBO-register access (Article XI, points 14 and 15) took effect on 10 July 2026. The instrument states its own purpose as remedying deficiencies previously identified by MONEYVAL, placing Slovakia among the enabler-jurisdiction correction cases where legislative remediation is visibly underway rather than merely announced.

The amendment does not resolve every structural concern raised about the Slovak beneficial-ownership regime. UBO data continues to be held within a non-public section of the Commercial Register rather than in a freestanding public register, a structural feature that outside observers have continued to flag as a continuing adequacy concern notwithstanding the verification-tightening changes. The co-existence of stronger verification duties with continued restricted public access is itself an architectural signal: Slovakia is strengthening who must be identified and how, while narrowing who may see the result.

#### Other Developments

Mandatory goAML filing extends across sectors. The amended AML/CFT Act requires obliged entities, including banks, payment companies, and crypto-asset operators, to register with and file unusual-transaction reports exclusively through the goAML system, subject only to narrow outage exceptions. Secondary commentary diverges on the exact registration deadline applicable to existing obliged entities, with reported dates of 30 November 2026 and 31 August 2026 circulating, possibly reflecting different sub-categories of obliged entity; the primary legislative text located this cycle supports the later date. This is flagged as an open discrepancy rather than resolved fact.

Dual supervision of crypto-asset service providers confirmed. The FATF/MONEYVAL 2025 follow-up report on Slovakia confirms a split-supervision architecture for crypto-asset service providers and asset-referenced-token issuers under Act 248/2024 Z.z.: the National Bank of Slovakia holds prudential supervisory authority, while the Financial Intelligence Unit holds AML/CFT supervisory authority over the same population of firms. This bifurcation is a structural feature of the Slovak regime, not a transitional artefact, and separates the solvency and conduct oversight line from the illicit-finance oversight line for the same regulated population.

Crypto-asset market context. A National Bank of Slovakia survey as of 8 October 2026 reports six entities holding MiCA-derived crypto-asset service provider authorisation, with a seventh (Tatra banka) reported as pending, and approximately six percent of Slovak adults reported as holding crypto-assets. This is market-structure context adjoining the supervisory architecture rather than itself a supervisory-architecture change.

#### Cross-Monitor Connections

The beneficial-ownership tightening and the crypto dual-supervision finding both intersect directly with the World Payments Monitor&#x27;s coverage of Slovakia&#x27;s MiCA implementing law and crypto-asset service provider authorisation population, since the same six-to-seven licensed entities and the same NBS/FIU supervisory split are relevant to payments-sector market access as well as to financial-integrity oversight. The data-protection dimension of the beneficial-ownership register&#x27;s restricted public access provisions also connects to the Data Protection Monitor&#x27;s interest in how legitimate-interest access gating is implemented in practice, though that implementation detail was not independently confirmed this cycle. No conflict-finance or sanctions-evasion nexus was identified for Slovakia this cycle.

#### Outlook

As an EU member state, Slovakia is bound directly by the EU AML Regulation once its supervisory architecture is fully operational, and Act 73/2026 Z.z. functions as an interim national tightening ahead of that fuller AMLR/AMLA build-out. The unresolved goAML registration-deadline discrepancy and the continued non-public structure of the Commercial Register&#x27;s UBO data are the two items most likely to generate further regulatory or commentary activity in coming cycles, as is clarification of how the legitimate-interest access test introduced on 10 July 2026 is being applied in practice.

12 Oct 2026 · fim-2026-10-11

#### Lead Signal

Slovakia&#x27;s financial-integrity posture moved on two fronts this cycle, both improving rather than deteriorating. MONEYVAL closed the enhanced follow-up process opened under its fifth-round mutual evaluation, upgrading Slovakia on eight FATF Recommendations in its Fourth Enhanced Follow-up Report. The Slovak Republic is now rated compliant with seven Recommendations, largely compliant with twenty-nine, and partially compliant with four of the forty FATF standards, a rating profile MONEYVAL itself frames as a significant strengthening of the national AML/CFT framework. The upgraded Recommendations span customer due diligence, politically exposed persons, correspondent banking, and sanctions-screening obligations, meaning the improvement is concentrated in exactly the controls that touch cross-border and correspondent exposure rather than in peripheral administrative requirements.

Alongside the AML/CTF upgrade, the national crypto-asset authorisation regime reached operational maturity. Six Slovak-headquartered firms now hold Crypto-Asset Service Provider authorisation from the National Bank of Slovakia as of a 29 July 2026 stocktake, out of 312 such authorisations issued across the European Union under the Markets in Crypto-Assets framework. That stocktake figure comes from third-party reporting of NBS-origin data rather than from a primary NBS publication retrieved this cycle, a distinction worth preserving given the figure is a count rather than a contested legal characterisation.

#### Other Developments

A record securities-dealer fine preceded a licence revocation. The National Bank of Slovakia revoked the investment-services authorisation of U.P. o.c.p., a.s. on 15 April 2026, a step that followed what NBS itself described as the historically highest fine ever imposed on a securities dealer in Slovakia, at 250,000 euros. NBS has petitioned a court to appoint a liquidator for the firm. This sits slightly outside the strict weekly evidence window but remains the most recent material enforcement action located for the jurisdiction and is carried forward as the clearest demonstrated instance of supervisory teeth being used against a regulated entity.

A March 2026 amendment tightened crypto-asset authorisation requirements. An amendment to Slovakia&#x27;s MiCA-implementing law, effective 1 March 2026, added a mandatory external cybersecurity audit to every Crypto-Asset Service Provider application and introduced ESMA-aligned knowledge and competence criteria for crypto-asset advisers. The change raises the bar for market entry at the point a firm first applies rather than through post-authorisation supervision, which is the more structurally durable place to intervene.

Sanctions exposure remains unremarkable but is not unwatched. No international sanctions designation is currently in force against Slovakia, and third-party commentary locates no enforcement action tied to sanctions evasion this cycle. The same commentary flags Slovakia&#x27;s trade links to Turkey, the United Arab Emirates, Armenia, Georgia, and Central Asia, together with Druzhba-pipeline and Slovnaft refining infrastructure, as a standing watch area rather than an active finding. Slovakia also remains off both the FATF grey list and black list as confirmed at the 19 June 2026 Plenary.

#### Cross-Monitor Connections

The crypto-asset authorisation tightening connects directly to the digital-asset regulatory tracking the crypto monitor performs for Slovakia this cycle: the same National Bank of Slovakia CASP regime, the same March 2026 cybersecurity-audit amendment, and the same six-licensee count are substrate for both monitors, viewed here through an AML/CTF and sanctions-screening lens rather than a market-structure lens. The securities-dealer licence revocation is a pure enforcement event with no identified crypto, sanctions, or conflict-finance nexus this cycle, and is not routed elsewhhere.

#### Outlook

Slovakia&#x27;s sixth-round MONEYVAL mutual evaluation is scheduled with an onsite visit in October 2028, which will reset the jurisdiction&#x27;s FATF Recommendation ratings against the current baseline established by this cycle&#x27;s enhanced follow-up closure. In the nearer term, the crypto-asset authorisation regime looks set to keep tightening at the point of entry rather than loosening, given the cybersecurity-audit requirement is newly in force rather than newly proposed. Whether the improved MONEYVAL rating translates into any change to Slovakia&#x27;s sanctions-screening practice for the correspondent-banking and PEP exposures the upgraded Recommendations specifically target is not yet evidenced and will depend on supervisory follow-through rather than the rating itself.

28 Sep 2026 · fim-2026-09-28

#### Lead Signal

Slovakia exited MONEYVAL&#x27;s fifth-round enhanced follow-up process on 15 January 2026, with the follow-up report finding the jurisdiction compliant with seven of the FATF&#x27;s forty Recommendations, largely compliant with twenty-nine, and partially compliant with four (Recommendations 8, 18, 28 and 35, covering non-profit organisations, internal controls, DNFBP supervision and sanctions implementation respectively). Slovakia will not be subject to further fifth-round follow-up reporting; its sixth-round on-site evaluation is scheduled for October 2028. This is a genuine architecture improvement, but it arrives alongside two structural developments that qualify how far the improvement can be read as settled: an approaching AMLD6 beneficial-ownership-register transposition deadline of 10 July 2026 for which no Slovak national transposition instrument has yet been located, and the expiry of the EU-wide MiCA transitional period on 1 July 2026, which now makes the National Bank of Slovakia&#x27;s MiCA authorisation regime the sole lawful basis for crypto-asset services in the jurisdiction.

#### Other Developments

AMLD6 transposition gap. Slovakia is bound directly by the AML Regulation from 10 July 2027 and must separately transpose the sixth AML Directive&#x27;s beneficial-ownership-register provisions, Articles 11 through 13 and 15, by 10 July 2026. No Slovak transposition instrument has been located as of this cycle, which is a live gap rather than an assumed compliance. This sits against a residual finding, unresolved in the January 2026 follow-up report, that Slovakia&#x27;s beneficial-ownership register still lacks a verification mechanism at the point of registration, with only limited ex-post control mechanisms in place.

MiCA crypto-asset authorisation now binding. The National Bank of Slovakia is the sole competent authority for MiCA crypto-asset service provider authorisation. Following the expiry of the EU-wide MiCA transitional period on 1 July 2026, the prior national VASP transitional trade-licensing route is no longer available, and providers operating without MiCA authorisation are in breach of EU law. The National Bank has indicated that crypto-asset service providers and issuers of asset-backed tokens are expected among its supervised population going forward.

Cambodia sanctions and crypto-laundering activity, external context. A U.S. Treasury OFAC designation targets a sitting Cambodian senator and businessman whose commercial network, including casino and resort properties, is alleged to house scam-centre operations. In a parallel development, a joint Cambodia-U.S. operation dismantled a crypto-laundering network moving proceeds linked to Mexico&#x27;s Sinaloa Cartel through Cambodia, with approximately USD 7 million in digital assets seized. Neither development is Slovakia-specific, but both corroborate a standing cross-jurisdictional pattern connecting Southeast Asian scam-compound infrastructure to Latin American narcotics proceeds via crypto rails, a pattern relevant to any jurisdiction, including Slovakia, assessing counterparty risk in crypto-asset transaction flows.

#### Cross-Monitor Connections

The MiCA authorisation-regime finding connects directly to the crypto monitor&#x27;s licensing-domain reading of the same transitional-period expiry, and to the world-payments monitor&#x27;s digital-money domain, both of which are addressed under their own subscribed-slot arrangements rather than here. The AMLD6 beneficial-ownership-register gap is a matter that intersects with the advennt monitor&#x27;s gambling-sector player-protection developments only insofar as Slovakia&#x27;s broader corporate-transparency architecture underpins beneficial-ownership disclosure expectations for any regulated entity, gambling operators included, though no gambling-sector-specific beneficial-ownership finding arose this cycle.

#### Outlook

The two items most likely to determine whether Slovakia&#x27;s improving architecture narrative holds are the appearance of a national AMLD6 beneficial-ownership transposition instrument ahead of the 10 July 2026 deadline, and the practical enforcement posture the National Bank adopts toward crypto-asset service providers that fail to secure MiCA authorisation following the 1 July 2026 transitional-period expiry. A further full AMLD6 transposition deadline falls in the third quarter of 2027, covering the remainder of Slovakia&#x27;s supervisory, FIU and sanctions-regime alignment obligations. Residual partial compliance on FATF Recommendations 8, 18, 28 and 35 will be the natural focus of Slovakia&#x27;s preparation ahead of its sixth-round on-site visit scheduled for October 2028.

14 Sep 2026 · fim-2026-09-05

#### Lead Signal

Slovakia&#x27;s Register of Beneficial Owners (RBO) has been suspended since 10 July 2025, precisely coinciding with the 6AMLD Article 74 legitimate-interest-access deadline, and Slovakia now sits among eleven European Union Member States facing European Commission infringement proceedings for missing that deadline. Only the narrower public-sector RPVS register remains open, meaning beneficial-ownership verification for corporate and fund structures currently relies on a partial substitute rather than the full statutory register. This is assessed as a structural rather than episodic transparency gap, and its resolution depends on further 6AMLD beneficial-ownership-register provisions (Articles 11-13 and 15) due nationally by 10 July 2026.

#### Other Developments

Sanctions veto leverage. Slovakia, alongside Hungary, used veto leverage to delay the EU Council&#x27;s 20th Russia sanctions package — which added 120 individuals and entities across the energy, finance, trade and military sectors — until its formal adoption on 23 April 2026. This repeats a pattern established in mid-2025, when Slovakia held up the 18th package for roughly six weeks. The delay is best characterised as intra-EU cohesion friction tied to unrelated energy-policy concessions rather than a technical sanctions-evasion architecture; no direct EU Council primary-source citation was reached this cycle for the exact negotiating terms behind the delay.

Crypto-asset supervisory transition. Slovakia&#x27;s national VASP trade-licence regime has been fully superseded by the EU MiCA Regulation, transposed via Act No. 248/2024 Coll., with the National Bank of Slovakia (NBS) now the sole competent authority for Crypto-Asset Service Provider (CASP) authorisation. The exact grandfathering transition deadline for existing VASP-licensed providers remains unresolved between two reported dates, 30 December 2025 and 1 July 2026. Separately, licensed Slovak CASPs became subject to EU DAC8 crypto-asset tax-reporting obligations from 1 January 2026.

Enforcement architecture reference point. Illustrating the broader Russia-sanctions enforcement environment within which Slovakia&#x27;s veto leverage operates, the UK&#x27;s Office of Financial Sanctions Implementation (OFSI) issued its first-ever penalty for a sanctions-circumvention offence, a GBP 1,000,920.59 fine against Sabre Global Technologies Limited on 26 May 2026. This is not a Slovak-specific action but is retained as a reference point for rising enforcement intensity around the same sanctions regime.

#### Cross-Monitor Connections

The MiCA CASP transition and the DAC8 tax-reporting obligation are directly relevant to the World Payments Monitor&#x27;s tracking of the National Bank of Slovakia&#x27;s supervisory perimeter, which now spans both traditional payment institutions and crypto-asset service providers under a single prudential authority. The beneficial-ownership register suspension should be read against the durable structural backdrop of the EU AML Package, which restructures beneficial-ownership and corporate-transparency supervision across three distinct instruments: the directly applicable AML Regulation (AMLR, Regulation (EU) 2024/1624); the sixth AML Directive (6AMLD, Directive (EU) 2024/1640), transposed nationally per Member State and the instrument whose Article 74 deadline Slovakia&#x27;s suspension coincides with; and the AMLA Regulation (Regulation (EU) 2024/1620), establishing the Anti-Money Laundering Authority and shifting supervision of cross-border obliged entities from purely national authorities toward a hybrid EU-level regime. Slovakia&#x27;s transposition gap sits precisely at the seam this architecture is designed to address over time.

#### Outlook

Watch for the 10 July 2026 deadline on further 6AMLD beneficial-ownership-register provisions (Articles 11-13, 15), which will determine the shape of restored legitimate-interest access to Slovakia&#x27;s RBO, and for progress in the European Commission infringement proceedings against Slovakia and the ten other Member States that missed the July 2025 deadline. On the crypto side, watch for a Tier-1 National Bank of Slovakia confirmation of the exact VASP-to-CASP transition deadline, which remains split between two reported dates. On sanctions, watch whether Slovakia&#x27;s veto-leverage pattern recurs on the next EU Russia-sanctions package, which would reinforce the assessment that this is a durable bargaining posture rather than a one-off event.

Domain intelligence (D1–D8)

#### Sanctions Architecture and Evasion

Slovakia&#x27;s sanctions-relevant signal this cycle is narrow but structurally important: Bratislava withdrew its opposition, alongside Budapest, enabling adoption of the 20th EU Russia sanctions package on 23 April 2026, a resolution assessed at moderate confidence as tied to settlement of the Druzhba pipeline dispute. The finding is corroborated across a law-firm commentary source and Bloomberg reporting, but no direct EU Council text was located this cycle to confirm the precise linkage between the pipeline settlement and the veto withdrawal, so the causal claim is held at Assessed rather than High confidence.

Continue reading This is best read as an architecture-level finding rather than an incident-level one: it says nothing about Slovak sanctions non-compliance, and everything about how a single Member State&#x27;s energy-security bargaining position can hold bloc-wide designation timing hostage to an unrelated bilateral commercial dispute. The pattern is not unique to this cycle; Slovakia has previously exercised conditional holds on EU sanctions packages, and the recurrence of the dynamic is itself the structural signal worth tracking, more so than any single package&#x27;s adoption date. Both jurisdictions cited elsewhere in this cycle&#x27;s enabler-jurisdiction findings are tracked because their casino and scam-centre sectors function as documented placement venues for proceeds generated elsewhere, a pattern distinct from Slovakia&#x27;s own veto-leverage dynamic but relevant background for any Slovak-linked entity with correspondent exposure into those corridors.

No Slovakia-specific sanctions-evasion finding, such as a national enforcement action, asset freeze, or designated-entity discovery within Slovak territory, was identified this cycle. Signal for this domain is accordingly thin and confined to the veto-posture dynamic described above; this sub-brief is flagged limited-signal rather than padded with material from adjacent domains.

#### Outlook

Watch for whether the Druzhba settlement proves durable or whether Slovakia reasserts a conditional hold on a future sanctions package tied to a different bilateral grievance, and for whether a primary EU Council text becomes available that would upgrade the current Tier-3 sourcing on the veto-Druzhba linkage.

Judgment: No SK-specific sanctions-architecture or evasion development located this window. Uncertain

#### Beneficial Ownership and Corporate Transparency

Slovakia&#x27;s beneficial-ownership regime moved materially this cycle with the entry into force of Zakon c. 73/2026 Z.z., amending the AML/CFT Act (Zakon c. 297/2008 Z.z.). The amendment, approved by the National Council on 14 April 2026 and published 6 May 2026, tightens the identification and verification duty on obliged entities by requiring confirmation of beneficial-owner status from multiple independent sources rather than a single attestation. It extends the scope of the beneficial-ownership identification regime to foreign trusts and asset pools, categories that had previously sat at the margin of the domestic register&#x27;s coverage. It also mandates that filings connected to beneficial-ownership reporting obligations proceed through the goAML system. The general provisions took effect 1 June 2026; the provisions restricting public access to beneficial-ownership register data to persons demonstrating a legitimate interest took effect 10 July 2026, on a staggered commencement schedule within the same instrument. The amendment states directly that it is intended to remedy deficiencies identified by MONEYVAL in prior assessment rounds, which is a notable degree of legislative self-documentation of the remediation link.

Continue reading As durable structural backdrop, the EU AML Package now consists of three distinct instruments operating on different transposition logics: the AML Regulation (AMLR, Regulation (EU) 2024/1624), which is directly applicable across the EU-27 without national transposition; the sixth AML Directive (6AMLD), which requires Member State transposition on its own timeline; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and begins shifting supervision of higher-risk obliged entities from purely national authorities toward a hybrid EU-level regime combining direct AMLA supervision of selected entities with indirect oversight of the remainder through national authorities. Slovakia, as an EU member state, is bound directly by the AMLR once its supervisory architecture around it matures, and Act 73/2026 Z.z. reads as an interim national tightening occurring ahead of that fuller build-out rather than as a transposition of the AMLR or 6AMLD itself; independent confirmation of Slovakia&#x27;s 6AMLD transposition status was not obtained this cycle. This AMLA architecture is the frame against which Slovakia&#x27;s own national legislative activity should be read: a national government moving early to close gaps that the EU-level supervisory architecture has not yet fully operationalised.

Notwithstanding the verification-tightening, a structural feature of the Slovak beneficial-ownership regime persists unchanged by this amendment: beneficial-ownership data continues to be held in a non-public section of the Commercial Register rather than in a standalone, freestanding public register. This has been noted by external assessors, including in MONEYVAL-adjacent commentary, as a continuing adequacy concern distinct from the verification-quality question that Act 73/2026 Z.z. addresses. The practical effect is a regime that is simultaneously tightening on the input side (who must verify what, and from how many sources) while narrowing on the output side (who may view the resulting register entry, now gated to demonstrated legitimate interest from 10 July 2026). Readers should treat these as two separate structural questions rather than assume that tightened verification implies broadened transparency; in Slovakia&#x27;s case this cycle, the two moved in different directions on different axes simultaneously.

#### Outlook

The most immediate open item is the unresolved discrepancy in secondary reporting over the goAML mandatory-registration deadline for existing obliged entities, cited variously as 30 November 2026 and 31 August 2026; the primary legislative text available this cycle supports the later date but the discrepancy has not been definitively resolved across all obliged-entity sub-categories. Independent confirmation of how the legitimate-interest access test introduced 10 July 2026 is being administered in practice, and whether Slovakia has progressed its 6AMLD transposition in parallel with this national amendment, are the two items most likely to generate material findings in subsequent cycles.

Judgment: No SK-specific beneficial-ownership registry development located this window. Uncertain

#### Enabler Jurisdictions and Professional Facilitators

No enabler-jurisdiction finding specific to Slovakia was identified this cycle; this domain&#x27;s signal in the corpus this period is drawn from two Southeast Asian jurisdictions tracked for their general relevance to the enabler-jurisdiction typology class rather than for any direct Slovak nexus. Cambodia faces renewed risk of a third FATF grey-listing amid a scam-centre and casino money-laundering crackdown, a High-confidence finding corroborated by Tier-1 FATF material alongside multiple Tier-3 trade-press sources. Laos remains under FATF increased monitoring, and the Kings Roman Casino in the Golden Triangle Special Economic Zone continues as a documented laundering venue for cyber-scam proceeds, a structural rather than episodic finding.

Continue reading Both jurisdictions are tracked here under the enabler-jurisdiction and professional-facilitator typology class because their casino and scam-centre sectors function as documented placement and layering venues for proceeds generated elsewhere, a pattern distinct from Slovakia&#x27;s own domestic financial-integrity profile but relevant to any Slovak-linked entity with correspondent, remittance, or investment exposure into Southeast Asia. These findings are included as standing enabler-jurisdiction context rather than as Slovakia-specific developments; any Slovak obliged entity with correspondent, payment, or investment exposure to Southeast Asian casino-linked corridors should treat them as background risk context rather than as a domestic finding. This sub-brief is flagged limited-signal because the gap register for this cycle explicitly notes that no Slovakia-specific enabler-jurisdiction dynamic was located.

#### Outlook

Watch for a formal FATF grey-listing decision on Cambodia, which would sharpen the enabler-jurisdiction risk read materially and warrant renewed correspondent-exposure review by any obliged entity with Southeast Asian counterparty relationships, Slovak or otherwise.

Judgment: No SK-specific enabler-jurisdiction development located this window. Uncertain

#### Conflict Finance and Extractive-Industry Integrity

This cycle&#x27;s conflict-finance signal is concentrated in North America and its immediate periphery rather than in Slovakia directly, consistent with this domain&#x27;s cross-jurisdictional remit. A fresh FinCEN supplemental alert, paired with OFAC designations of two individuals and nine entities, targets a fiscal fuel-theft and oil-smuggling trade-based-money-laundering scheme linked to Cartel de Jalisco Nueva Generacion, alongside Cartel del Noreste-linked casino networks; this is a High-confidence, Tier-1 finding corroborated by independent Tier-3 reporting and grounded in Bank Secrecy Act reporting obligations under 31 U.S.C. 5318.

Continue reading The scheme illustrates a conflict-finance typology worth naming explicitly: fuel theft and smuggling generate proceeds that are then layered through trade-finance documentation and, per the casino-network linkage, through gaming-sector cash-intensive channels, a combination that sits at the intersection of extractive-industry integrity and conventional casino-sector money laundering. The paired OFAC designations targeting eleven individuals and entities in total represent a coordinated-action model: a financial-intelligence alert issued in parallel with, rather than sequentially after, a sanctions-designation action. The Bank Secrecy Act reporting obligation cited in the underlying FinCEN alert applies specifically to banks and other Bank Secrecy Act-covered financial institutions, meaning the primary compliance burden generated by this finding falls on the correspondent and trade-finance banking sector rather than on non-bank payment or crypto-asset firms; this reinforces why this domain&#x27;s findings this cycle skew toward the banking and cross-sector affected-firm-type categories rather than toward crypto-asset operators, a category more prominent in this cycle&#x27;s crypto and digital-assets domain instead.

Separately, record coca cultivation and cocaine production levels in Colombia, per the United States State Department&#x27;s own drug-transit determination for the current cycle, represent a structural deterioration in narco-finance supply-side conditions; this finding is drawn from the jurisdiction-risk-tracker entry for Colombia rather than from a dedicated structured claim, and is included as scene-setting context for the broader Latin American conflict-finance picture rather than as a standalone high-confidence finding in its own right. The pairing of a fiscal fuel-theft typology with a casino-network laundering channel is also a useful illustration of why conflict-finance findings resist single-typology classification: fuel theft is an extractive and commodity-integrity finding at its origin, but the laundering method chosen, casino-network placement, is a typology more conventionally associated with retail cash-intensive money laundering, and analysts should resist forcing either finding into a single typology bucket when the underlying scheme spans both.

No Slovak nexus to either the CJNG fuel-theft scheme or the Colombian narco-finance deterioration was identified this cycle; this domain&#x27;s Slovak-specific signal remains at zero for the period, and the content above is included under this domain&#x27;s cross-jurisdictional, architecture-over-incident remit rather than as a Slovakia finding. This is consistent with the three-pillar balance principle: conflict-finance findings, being CTF/CPF-adjacent rather than conventional AML-enforcement-volume-driven, are represented here even where the jurisdictional nexus to Slovakia is absent, because the typology itself, trade-based laundering of extractive-sector proceeds through parallel cash-intensive channels, is a standing pattern financial-integrity monitoring should track regardless of a single-cycle jurisdictional match. No FATF Recommendation reference was attached to this cycle&#x27;s CJNG finding in the underlying claim set, and no customer-typology tag beyond trade finance was recorded; the finding is nonetheless treated as material given the Tier-1 sourcing and the scale of the coordinated designation action.

#### Outlook

Watch for further OFAC or FinCEN action extending the CJNG fuel-theft designations chain, for any formal FATF or State Department follow-up on the Colombian cultivation data that would elevate it from a scene-setting note to a dedicated tracked finding, and for any emerging Slovak or broader Central European nexus to either typology, none of which was evidenced this cycle.

Judgment: No SK-specific conflict-finance development located this window. Uncertain

#### Crypto, Digital Assets, and Financial Innovation

The FATF/MONEYVAL 2025 follow-up report on Slovakia confirms, as a primary assessment-body finding, that Slovakia operates a split-supervision model for crypto-asset service providers and asset-referenced-token issuers authorised under Act 248/2024 Z.z. The National Bank of Slovakia functions as the prudential supervisor of these entities, responsible for authorisation, capital adequacy and conduct oversight consistent with the EU&#x27;s Markets in Crypto-Assets framework, while the Financial Intelligence Unit functions as the AML/CFT supervisor of the identical population of firms. This is a structural architecture decision rather than an incidental arrangement, and it means that a single crypto-asset service provider operating in Slovakia answers to two distinct supervisory lines for two distinct regulatory purposes: solvency and market conduct on one line, illicit-finance risk on the other. This bifurcated model is the kind of architecture-over-incident finding that merits attention independent of any single enforcement event, because it shapes how compliance obligations, examination cycles and information-sharing duties are structured for every authorised entity in the jurisdiction going forward.

Continue reading Market-structure context accompanying this supervisory finding comes from a National Bank of Slovakia survey dated 8 October 2026, which reports six entities holding Slovak crypto-asset service provider authorisation, with a seventh institution, Tatra banka, reported as a pending applicant. The same survey reports that approximately six percent of Slovak adults hold crypto-assets. These figures describe the current scale of the regulated population and retail exposure rather than any new supervisory development, but they are useful context for assessing how much is actually at stake under the dual-supervision architecture just described: a licensed population in the single digits and a retail adoption rate in the mid-single-digit percentage range, not yet a large-scale segment of the Slovak financial system.

The crypto-asset dimension of this cycle&#x27;s beneficial-ownership tightening is also worth noting from the financial-innovation angle: the goAML mandatory-filing requirement introduced by Act 73/2026 Z.z. explicitly extends to crypto-asset operators among the categories of obliged entity required to register and file through the system, placing crypto-asset service providers under the same centralised reporting-channel requirement as banks and payment companies, even though their supervisory architecture for prudential purposes remains split from the AML/CFT line as described above.

#### Outlook

The near-term question for this domain is whether the seventh pending authorisation (Tatra banka) completes, which would mark the entry of a major incumbent banking group into the directly-licensed crypto-asset service provider population and could shift both the scale and the risk profile described by the NBS survey. Whether the FIU&#x27;s AML/CFT supervisory role over crypto-asset service providers produces visible examination or enforcement activity distinct from the NBS&#x27;s prudential oversight, and how the new goAML filing obligation is operationalised specifically for crypto-asset operators under the split-supervision model, are the two most likely sources of further material findings.

Judgment: SK&#x27;s VASP-to-CASP transition under MiCA closed 30 December 2025 (national discretion, Art. 143); no new SK-specific crypto-integrity development located this window. Probable

#### Compliance Technology & Active Defence

Slovakia&#x27;s compliance-technology posture moved this cycle through a specific legislative lever rather than through enforcement: a March 2026 amendment to the national MiCA-implementing law, effective 1 March 2026, added a mandatory external cybersecurity audit to every crypto-asset service provider application, alongside ESMA-aligned knowledge and competence criteria for crypto-asset advisers. This is a gate placed at the point of market entry rather than a post-authorisation supervisory requirement, which is a structurally different kind of intervention. A cybersecurity-audit requirement attached to the application itself screens for technical control adequacy before a firm is allowed to touch client assets or data, rather than relying on discovering deficiencies after the fact through supervisory examination or incident response.

Continue reading The architecture-over-incident reading of this amendment is that it reflects a judgement by the National Bank of Slovakia that crypto-asset service providers carry a distinct active-defence risk profile relative to traditional financial intermediaries, one that conventional prudential and conduct requirements under the Markets in Crypto-Assets framework do not fully capture on their own. Requiring an external audit, rather than a self-attestation, further indicates the supervisor is not content to rely on applicant-supplied assurance for this particular control.

This development sits alongside, rather than inside, this cycle&#x27;s AML/CTF uplift. MONEYVAL&#x27;s enhanced follow-up closure concerned customer due diligence, correspondent banking, and sanctions-screening controls; the cybersecurity-audit requirement concerns technical and operational resilience of the crypto-asset service providers that, per the same MONEYVAL report, are now brought fully inside the AML/CTF perimeter. The two are adjacent reforms addressing different failure modes within the same expanding regulatory perimeter, both landing within the same reform window.

#### Outlook

Because the cybersecurity-audit requirement attaches to the application stage, its effect will be visible primarily in the character of future authorisations rather than in retrospective findings against already-licensed firms. Whether the requirement extends, in substance or in future amendment, to the ongoing supervisory cycle for the six already-authorised crypto-asset service providers, rather than remaining confined to new applicants, is not evidenced in this cycle&#x27;s material and would be a natural point to track going forward.

Judgment: No SK-specific or cross-cutting RegTech/compliance-technology development located this window. Uncertain

#### AML/CTF Regime

Slovakia&#x27;s standing AML/CTF regime, anchored in Act 297/2008 Z.z., was materially amended this cycle by Zakon c. 73/2026 Z.z., approved by the National Council on 14 April 2026 and published 6 May 2026. The amendment operates on two timelines within the same instrument: general provisions, including the tightened multi-source beneficial-owner verification duty and the extension of identification duties to foreign trusts and asset pools, took effect 1 June 2026, while the narrower provisions restricting public access to beneficial-ownership register data to legitimate-interest requesters took effect 10 July 2026. The amendment states directly that its purpose is to remedy deficiencies previously identified by MONEYVAL, situating this cycle&#x27;s activity within an ongoing national remediation programme rather than a standalone legislative event.

Continue reading A central operational component of the amendment is the mandatory channelling of suspicious- and unusual-transaction reporting through the goAML system. Obliged entities across sectors, including banks, payment companies, and crypto-asset operators, must register with and file exclusively through goAML, subject only to narrow outage exceptions. This represents a centralisation of the reporting channel across what had previously been a more fragmented set of entity-specific arrangements. Secondary commentary disagrees on the precise registration deadline applicable to existing obliged entities, with figures of 30 November 2026 and 31 August 2026 both reported, potentially reflecting different obliged-entity sub-categories with different compliance timelines; the primary legislative text available this cycle supports the later date for entities already obliged as of 1 June 2026, but the discrepancy has not been fully resolved and is logged as an open gap.

The supervisory architecture underlying this regime continues to reflect a sector-specific split: for crypto-asset service providers specifically, the Financial Intelligence Unit holds AML/CFT supervisory authority while the National Bank of Slovakia holds prudential authority, per the FATF/MONEYVAL 2025 follow-up report, meaning the AML/CTF regime for this sector is administered by a different body than the regime&#x27;s prudential counterpart. As an EU-27 member, Slovakia is also bound directly by the AML Regulation (Regulation (EU) 2024/1624) once the EU-level supervisory architecture under AMLA matures; the national amendment functions as an interim tightening occurring ahead of that fuller build-out rather than as implementation of the AMLR itself, and confirmation of Slovakia&#x27;s parallel 6AMLD transposition status was not obtained this cycle.

#### Outlook

Resolution of the goAML registration-deadline discrepancy across obliged-entity sub-categories is the most concrete near-term item to watch. More broadly, whether Slovakia&#x27;s national legislative remediation under Act 73/2026 Z.z. is judged sufficient by MONEYVAL in subsequent follow-up reporting, and how the national regime continues to interact with the maturing EU-level AMLR/AMLA architecture, will determine whether further national amendments are required or whether Slovakia&#x27;s remediation programme is considered substantially complete.

Judgment: Slovakia&#x27;s AML/CTF regime stands as strengthened per MONEYVAL&#x27;s 23 March 2026 follow-up report, with the country released from the 5th-round enhanced follow-up process ahead of a 6th-round onsite scheduled October 2028; no new development within this window. Probable

#### Commercial Activity

The single dated development for Slovakia this cycle is the legal merger of 365.bank into CSOB, completing 1 November 2026. 365.bank is the Bratislava-based retail bank in which KBC Group, through CSOB, holds a 98.45 percent stake; the reported consideration for the transaction is EUR 708 million. The merger consolidates two previously separate Slovak-licensed obliged entities under one legal structure, which from an integrity standpoint matters less for the commercial logic of the deal and more for what it does to the compliance perimeter: two institutions that each carried independent AML/CTF programmes, independent reporting lines to the Financial Intelligence Unit, and independent customer due-diligence populations now sit under a single legal entity.

Continue reading This is an architecture-level event rather than an incident, and it is read that way here. A bank consolidation of this kind typically brings two customer bases, two sets of historical due-diligence files, and potentially two different risk-appetite postures into a single compliance function. Whether that consolidation is executed cleanly is not yet knowable from the material available this cycle; what can be said is that the obliged-entity count in Slovakia&#x27;s banking sector has, as of the completion date, reduced by one, with the surviving entity inheriting the combined book.

The quality of the sourcing behind this finding is itself worth flagging plainly rather than glossing over. The only source located and read this cycle is a tertiary account that in turn cites the acquirer&#x27;s own newsroom; no primary release from CSOB or from KBC Group&#x27;s own investor or press channels was opened directly during this pass. The substance of the finding — that the merger is structured as described, dated as described, and valued as described — is accordingly treated as probable rather than settled, and a primary-source confirmation remains an open item rather than a completed step.

No enforcement action, supervisory finding, or sanctions nexus attaches to either 365.bank or CSOB in the material reviewed this cycle. The development is commercial and structural, not punitive, and nothing here should be read as implying wrongdoing by either institution. The analytical interest is purely in what a consolidation of this scale does to the shape of Slovakia&#x27;s obliged-entity population and to where supervisory and reporting attention should concentrate going forward, given that compliance architecture built for two separate institutions must now function as one.

#### Outlook

The immediate item to watch is whether a primary-source account of the merger — from CSOB, KBC Group, or Slovakia&#x27;s National Bank in its supervisory capacity — becomes available, which would allow this finding to move beyond its current probable standing. Beyond that, the more durable question is how the combined institution&#x27;s AML/CTF governance performs post-completion, particularly given that brand coexistence between 365.bank and CSOB is understood to continue for a period before full migration. No other Slovakia-specific commercial development is in view this cycle, and the broader obliged-entity landscape otherwise remains as previously recorded.

Judgment: 365.bank, fully KBC-controlled since a €708m transaction completed January 2026, legally merges into ČSOB on 1 November 2026, consolidating two previously separate Slovak obliged entities under one legal and compliance perimeter. Probable

Regulatory horizon

Adopted 10 Jul 2027 · ±quarter

### AMLR / AMLD6 application and transposition deadline

AMLR becomes directly applicable in Slovakia without transposition; AMLD6 governs national supervisors, FIU powers and BO-register interconnection and must be transposed by the same date.

[Source](https://www.checkmarble.com/blog/eu-amlr)

Proposed 2027-Q3 · ±year

### AMLD6 full transposition (remaining provisions)

SK&#x27;s AML supervisory architecture, FIU structure and sanctions regime will need to meet AMLD6 minimum standards.

[European Union (national transposition by SK) Source](https://accountancyeurope.eu/wp-content/uploads/2026/03/6AMLD-Factsheet.pdf?v1=)

Proposed 2028-Q4 · ±multi_year

### Slovak Republic 6th Round MONEYVAL Mutual Evaluation

A new full mutual-evaluation onsite visit scheduled October 2028, resetting Slovakia&#x27;s FATF Recommendation ratings.

[Source](https://www.fatf-gafi.org/en/countries/global-network/committee-of-experts-on-the-evaluation-of-anti-money-laundering-.html)

3 dated · 3 pending date · baseline financial-integrity-2026-07-05

Role action cards

MLRO

### Two Slovak obliged entities consolidate into one legal and compliance perimeter.

The legal merger of 365.bank into CSOB narrows the number of distinct Slovak reporting entities under common group control, which may consolidate suspicious-activity reporting lines previously run separately. No new AML/CTF obligation or enforcement signal attaches to either entity this cycle.

1 evidence refs

Compliance

### CSOB absorbs 365.bank&#x27;s compliance programme as the legal merger takes effect.

A previously separate obliged entity&#x27;s control framework is now subject to integration into CSOB&#x27;s existing programme, with brand coexistence continuing into 2027 while systems migrate. No control-framework gap has been evidenced this cycle.

1 evidence refs

Legal

### No sanctions, enforcement, or liability signal attaches to the 365.bank-CSOB merger this cycle.

The merger is a corporate-structure event completed 1 November 2026, following a reported January 2026 acquisition. No regulatory-review detail or enforcement nexus has been located in the material reviewed.

1 evidence refs

Board

### KBC Group completes consolidation of its two Slovak retail banking entities.

The legal merger of 365.bank into CSOB, following a roughly EUR 708 million acquisition completed in January 2026, simplifies KBC&#x27;s Slovak corporate structure. This is a scale and structural consolidation with no evidenced reputational or enforcement implication this cycle.

1 evidence refs

CTO

### No material change for this persona this cycle.

No material change for this persona this cycle

Risk

### Obliged-entity concentration increases as two Slovak banks consolidate under one legal perimeter.

The merger reduces the number of distinct compliance and monitoring environments within KBC&#x27;s Slovak footprint, concentrating exposure that was previously distributed across two entities. No new risk-typology signal has been evidenced this cycle.

1 evidence refs

Operations

### Transaction-monitoring and screening environments for two Slovak banks begin consolidation.

With 365.bank&#x27;s legal entity merged into CSOB, operational integration of monitoring and screening workflows is expected to proceed through the brand-coexistence period running into 2027. No operational timeline beyond the legal merger date has been confirmed.

1 evidence refs

Audit

### Audit trail continuity across the merged 365.bank-CSOB perimeter warrants tracking through the migration period.

As two previously separate obliged entities&#x27; records and controls are combined, continuity of documented evidence through the systems-migration period running into 2027 is a natural area of audit interest. No gap has been evidenced this cycle.

1 evidence refs

Standing trackers (T1–T6)

Tracker Status Note

T1 · Russian Sanctions-Evasion Architecture no_change No material SK-specific movement identified this window.

T2 · EU AML Package / AMLA no_change AMLA&#x27;s 2027 direct-supervision selection groundwork (data collection by 15 Aug 2026; provisional eligible-entity list end-Sept 2026) and AMLR 10 July 2027 application date remain standing; nothing SK-specific dated this window.

T3 · FATF Grey List no_change Slovakia not grey-listed; MONEYVAL 23 March 2026 follow-up recorded significant strengthening, released from 5th-round enhanced follow-up ahead of October 2028 6th-round onsite.

T4 · Beneficial-Ownership Register Status no_change No SK-specific BO-registry development located this window.

T5 · Crypto & Digital-Asset Integrity no_change SK&#x27;s VASP-to-CASP transition under MiCA closed 30 December 2025 (national discretion); no new SK-specific enforcement or evasion signal this window.

T6 · Sanctions Regime Divergence no_change No SK-specific EU/US/UK sanctions-divergence development located this window.

Registers

### Enforcement actions

- 28 Jan 2025

- 23 Mar 2026

- 10 Feb 2026

- 18 Dec 2025

- 30 Jun 2026

- 1 Apr 2026

- 15 Apr 2026

- MONEYVAL/FATF Follow-Up Report re-rated Slovakia&#x27;s Recommendation 26 from Partially Compliant to Largely Compliant but kept R.8, R.15 and R.19 at Partially Compliant, and placed Slovakia into compliance-enhancing procedures (step 1) over the persistent &#x27;big six&#x27; R.10 (customer due diligence) deficiency. 28 Jan 2025

- A further Follow-Up Report analysing Slovakia&#x27;s progress addressing outstanding technical-compliance deficiencies from its 2020 Mutual Evaluation Report was adopted, continuing the enhanced follow-up and compliance-enhancing procedure track. 23 Mar 2026

- The European Commission held plenary debates and issued formal remarks (Sept 2025, Feb 2026) on the rule-of-law situation and management of EU funds in Slovakia, continuing intensive dialogue over the abolition of the Special Prosecutor&#x27;s Office and penal code changes lowering corruption sentences. 10 Feb 2026

- Slovakia&#x27;s Constitutional Court blocked government-proposed laws tightening rules on NGOs (mandatory disclosure of funding, donors and personnel) and loosening whistleblower protections, ruling the NGO provisions unconstitutional as disproportionate interference with privacy rights. 18 Dec 2025

### Sanctions changes

- 18 Jul 2025

- 23 Feb 2026

- 23 Apr 2026

- 1 Sep 2026

- Slovakia joined Hungary in delaying the EU&#x27;s 18th Russia sanctions package for weeks, seeking removal of specific Russian names and guarantees on continued Russian energy imports before allowing adoption on 18 July 2025. 18 Jul 2025

- Hungary vetoed the EU&#x27;s proposed 20th Russia sanctions package, tying its position to resumption of Russian oil transit via the Druzhba pipeline to both Hungarian and Slovak refineries after flows were cut following reported strikes in western Ukraine. 23 Feb 2026

### Regulatory horizon (register)

- AMLA Work Programme / build-out

- 6AMLD beneficial-ownership register-content transposition (Arts 11-13, 15)

- AMLA Work Programme / build-out

- AMLD6 beneficial-ownership-register provisions transposition

- AMLD6 full transposition (remaining provisions)

- Slovak Republic 6th Round MONEYVAL Mutual Evaluation

- AMLR / AMLD6 application and transposition deadline

- EU AML Regulation (AMLR, 2024/1624) direct application in Slovakia

- 6th AML Directive transposition into Slovak national law

- AMLA direct/indirect supervisory perimeter activation affecting Slovak obliged entities

- Next MONEYVAL/FATF follow-up report on Slovakia

### Active schemes

- [HIGH] Slovak-Hungarian obstruction of EU Russia sanctions renewal

- Slovak corporate registry used in Wagner-linked shipping structure

- VAT carousel fraud using Slovak front companies

- Unsupervised Slovak VASP sector as latent laundering channel

Sources

- [https://www.coe.int/en/web/moneyval/-/slovakia-has-significantly-strengthened-its-framework-against-money-laundering-and-terrorist-financing-council-of-europe%C2%B4s-moneyval-committee-report](https://www.coe.int/en/web/moneyval/-/slovakia-has-significantly-strengthened-its-framework-against-money-laundering-and-terrorist-financing-council-of-europe%C2%B4s-moneyval-committee-report)

- [https://www.fatf-gafi.org/en/countries/detail/Slovakia.html](https://www.fatf-gafi.org/en/countries/detail/Slovakia.html)

- [https://www.step.org/industry-news/several-eu-member-states-miss-deadline-public-access-beneficial-ownership-registers](https://www.step.org/industry-news/several-eu-member-states-miss-deadline-public-access-beneficial-ownership-registers)

- [https://easternherald.com/2026/09/03/slovakia-blocks-eu-sanctions-russia-12-month-extension/](https://easternherald.com/2026/09/03/slovakia-blocks-eu-sanctions-russia-12-month-extension/)

- [https://ezine.eversheds-sutherland.com/global-sanctions-guide/slovakia](https://ezine.eversheds-sutherland.com/global-sanctions-guide/slovakia)

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- [Council of Europe MONEYVAL](https://www.coe.int/en/web/moneyval/-/slovakia-has-significantly-strengthened-its-framework-against-money-laundering-and-terrorist-financing-council-of-europe%C2%B4s-moneyval-committee-report)

- [eucrim (Max Planck / EU criminal law portal)](https://eucrim.eu/news/moneyval-fifth-round-evaluation-report-slovakia/)

- [Accountancy Europe](https://accountancyeurope.eu/wp-content/uploads/2026/03/6AMLD-Factsheet.pdf?v1=)

- [NBS](https://nbs.sk/en/before-preparation-of-a-request/)

- [U.S. Treasury / OFAC](https://home.treasury.gov/news/press-releases/sb0469)

- [Indoneo](https://www.indoneo.com/capital/cambodia-sinaloa-cartel-crypto-7-million-seizure/)

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- [Národná banka Slovenska](https://nbs.sk/aktuality/kryptoaktiva-po-mica-na-slovensku-posobi-sest-licencovanych-poskytovatelov-investicne-riziko-zostava/)

- [Wikipedia](https://en.wikipedia.org/wiki/Anti-Money_Laundering_Authority)

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- [https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html)

- [https://nbs.sk/aktuality/nbs-odobrala-povolenie-obchodnikovi-s-cennymi-papiermi-u-p-o-c-p-a-s/](https://nbs.sk/aktuality/nbs-odobrala-povolenie-obchodnikovi-s-cennymi-papiermi-u-p-o-c-p-a-s/)

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- [https://amlko.sk/](https://amlko.sk/)

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- [Fincrime Central](https://fincrimecentral.com/moneyval-georgia-montenegro-poland-slovakia/)

- [European Banking Authority](https://www.eba.europa.eu/information-administrative-sanctions-or-measures-under-article-62-directive-eu-2015849-amld4)

- [KnowYourCountry](https://www.knowyourcountry.com/country-aml-intelligence/country/slovakia/)

- [AMLA](https://www.amla.europa.eu/amla-takes-next-step-toward-2027-selection-entities-direct-supervision_en)

- [Vantegris](https://vantegris.com/blog/slovakia-vasp-to-casp-transition/)

- [Wikimedia Foundation](https://en.wikipedia.org/wiki/365.bank)

- [https://www.amla.europa.eu/amla-takes-next-step-toward-2027-selection-entities-direct-supervision_en](https://www.amla.europa.eu/amla-takes-next-step-toward-2027-selection-entities-direct-supervision_en)

- [https://vantegris.com/blog/slovakia-vasp-to-casp-transition/](https://vantegris.com/blog/slovakia-vasp-to-casp-transition/)

- [https://en.wikipedia.org/wiki/365.bank](https://en.wikipedia.org/wiki/365.bank)

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- [Mutual Evaluation of the Slovak Republic](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftheslovakrepublic.html)

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- [The Slovak Republic&#x27;s progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Slovak-Republic-Dec-2024.html)

- [Slovakia](https://www.fatf-gafi.org/en/countries/detail/Slovakia.html)

- [Documents - Financial Action Task Force (FATF)](https://www.fatf-gafi.org/documents/documents/mutualevaluationoftheslovakrepublic.html)

- [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html)

- [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html)

- [Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Universal-procedures.html)

- [Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL)](https://www.fatf-gafi.org/en/countries/global-network/committee-of-experts-on-the-evaluation-of-anti-money-laundering-.html)

- [Follow-Up Report to the Slovak Republic&#x27;s progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-slovak-republic-2022.html)

- [The Slovak Republic&#x27;s measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-slovak-republic-2020.html)

- [Page 1 of 167 Country Review Report of Slovak Republic](https://www.unodc.org/documents/treaties/UNCAC/CountryVisitFinalReports/2013_07_11_Slovakia_Final_Country_Report.pdf)

- [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html)

- [Slovakia Economic and Financial Affairs ISSN 2443-8014 (online)](https://economy-finance.ec.europa.eu/document/download/3b96b0d4-2c4a-4e13-80a9-45a9e4fc9083_en?filename=ip276_en.pdf&prefLang=ga)

- [FIN-NET members in Slovakia - Finance - European Commission](https://finance.ec.europa.eu/consumer-finance-and-payments/retail-financial-services/financial-dispute-resolution-network-fin-net/members-fin-net-country/fin-net-members-slovakia_en)

- [National Bank of Slovakia | EU Digital Finance Platform](https://digital-finance-platform.ec.europa.eu/cross-border-services/cross-border-testing/participants/national-bank-slovakia)

- [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/)

- [Shadowy Oil Trader With Kremlin, Orbán Ties Supplied Billions in Russian Crude to Europe | OCCRP](https://www.occrp.org/en/news/shadowy-oil-trader-with-kremlin-orban-ties-supplied-billions-in-russian-crude-to-europe)

- [EU Plans Massive 21st Sanctions Package to Target Russian Banks and Crypto | OCCRP](https://www.occrp.org/en/news/eu-plans-massive-21st-sanctions-package-to-target-russian-banks-and-crypto)

- [Hotline to the Kremlin: How Hungary Colluded With Russia to Weaken EU Sanctions | OCCRP](https://www.occrp.org/en/scoop/hotline-to-the-kremlin-how-hungary-colluded-with-russia-to-weaken-eu-sanctions)

- [Hungary to Veto New EU Russia Sanctions Over Druzhba Oil Transit | OCCRP](https://www.occrp.org/en/news/hungary-to-veto-new-eu-russia-sanctions-over-druzhba-oil-transit)

- [Prigozhin’s Unsanctioned Offshore Companies Linked to the UK and the EU | OCCRP](https://www.occrp.org/en/daily/17385-preghozin-s-unsanctioned-offshore-companies-linked-to-the-uk-and-the-eu)

- [All News | OCCRP](https://www.occrp.org/en/daily)

- [Expert: Italian Mafia has Mastered Complex Economic Schemes | OCCRP](https://www.occrp.org/en/news/expert-italian-mafia-has-mastered-complex-economic-schemes)

- [Exclusive: Top Trump Adviser Sergio Gor Was Born in the Soviet Union | OCCRP](https://www.occrp.org/en/news/exclusive-top-trump-advisor-sergio-gor-was-born-in-the-soviet-union)

- [Ecuador Arrests Judges, Lawyers and Police Officers for Helping Criminals | OCCRP](https://www.occrp.org/en/news/ecuador-arrests-judges-lawyers-and-police-officers-for-helping-criminals)

- [Spain Losses Millions in a ‘Carousel Fraud’ Case | OCCRP](https://www.occrp.org/en/daily/14433-spain-losses-millions-in-a-carousel-fraud-case)

- [Slovakia Public Sector Partners Register](https://aleph.occrp.org/datasets/4873)

- [Directory of Open-Source Registries: Slovakia](https://globenetwork.unodc.org/globenetwork/en/directory-of-open-source-registries/slovakia.html)

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- [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html)

- [1 Information on Czech Republic national BOR](https://webgate.ec.europa.eu/e-justice/fileDownload.do?id=f6f66702-e280-4f4f-b87f-308fbcdaf2cf)

- [European e-Justice Portal - Beneficial Ownership Registers – search for beneficial ownership information](https://webgate.ec.europa.eu/e-justice/38576/EN/beneficial_ownership_registers__search_for_beneficial_ownership_information?init=true&idSubpage=1)

- [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports)

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- [About AMLA - Authority for Anti-Money Laundering and Countering the Financing of Terrorism](https://finance.ec.europa.eu/financial-crime/amla/about-amla_en)

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- [Council of the EU PRESS EN PRESS RELEASE 468/24 30/05/2024](https://www.consilium.europa.eu/en/press/press-releases/2024/05/30/anti-money-laundering-council-adopts-package-of-rules/pdf)

- [Anti-money laundering and countering the financing of terrorism overview - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-overview_en)

- [10802/26 ADD 2 JAI.2 EN Council of the European Union Brussels, 18 June 2026](https://data.consilium.europa.eu/doc/document/ST-10802-2026-ADD-2/en/pdf)

- [Slovakia Gov’t to Disband Police Agency Investigating Corruption | OCCRP](https://www.occrp.org/en/news/slovakia-govt-to-disband-police-agency-investigating-corruption)

- [Slovakia’s Judicial Overhaul Sets Up Potential Fight With EU - Bloomberg](https://www.bloomberg.com/news/articles/2024-02-08/slovakia-provokes-fight-with-eu-with-latest-judicial-overhaul)

- [Slovakia: President Pellegrini Urges Cabinet to Act to Avoid EU Sanctions - Bloomberg](https://www.bloomberg.com/news/articles/2024-09-11/slovak-president-urges-cabinet-to-act-to-avoid-eu-aid-sanctions)

- [Slovakia to Scrap Special Prosecutor in Rule-of-Law Dispute - Bloomberg](https://www.bloomberg.com/news/articles/2023-12-06/slovakia-to-abolish-special-prosecutor-s-office-fico-says)

- [Slovakia Dissolves Department in Charge of Kuciak Case; Prosecutors Resign | OCCRP](https://www.occrp.org/en/news/slovakia-dissolves-department-in-charge-of-kuciak-case-prosecutors-resign)

- [Slovakia Dissolves Department in Charge of Kuciak Case; Prosecutors Resign](https://www.occrp.org/en/daily/18685-slovakia-dissolves-department-in-charge-of-kuciak-case-prosecutors-resign)

- [Slovakia Protests: Demonstrators Rally Against Fico’s Judiciary Overhaul Plan - Bloomberg](https://www.bloomberg.com/news/articles/2024-01-18/thousands-protest-in-slovakia-to-stop-premier-s-judiciary-revamp)

- [EU Weighs Blocking Slovakia Funds for Democratic Backsliding - Bloomberg](https://www.bloomberg.com/news/articles/2024-09-08/eu-weighs-blocking-slovakia-funds-over-democratic-backsliding)

- [Presidential Race in Slovakia May Place a Check on Fico’s Power - Bloomberg](https://www.bloomberg.com/news/newsletters/2024-04-05/presidential-race-in-slovakia-may-place-a-check-on-fico-s-power)

- [Slovak Court Blocks Fico’s Crackdown on Whistleblower Protection - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-18/slovak-court-blocks-fico-s-crackdown-on-whistleblower-protection)

- [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/)

- [The Blockchain Data Platform - Chainalysis](https://www.chainalysis.com/)

- [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp)

- [DAC8 - Taxation and Customs Union - European Commission](https://taxation-customs.ec.europa.eu/taxation/tax-transparency-cooperation/administrative-co-operation-and-mutual-assistance/directive-administrative-cooperation-dac/dac8_en)

- [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26)

- [Crypto Adoption in Europe: The World’s Largest Crypto Market](https://www.chainalysis.com/blog/europe-crypto-adoption-2025/)

- [Crypto-assets - Finance - European Commission](https://finance.ec.europa.eu/digital-finance/crypto-assets_en)

- [Virtual Assets](https://www.fatf-gafi.org/en/publications/Virtualassets/Virtual-assets.html)

- [EU&#x27;s 20th Russia Sanctions Package](https://www.chainalysis.com/blog/eu-russia-sactions-package-april-2026/)

- [Markets in Crypto-assets Regulation - Finance - European Commission](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/markets-crypto-assets-regulation_en)

- [EUROPEAN COMMISSION DG Competition Case M.10378 - VUB / SLOVENSKA SPORITELNA](https://ec.europa.eu/competition/mergers/cases1/202230/M_10378_8422567_438_3.pdf)

- [Slovakia and the euro - Economy and Finance - European Commission](https://economy-finance.ec.europa.eu/euro/eu-countries-and-euro/slovakia-and-euro_en)

- [Tackling Fraud and Corruption Risks in the Slovak Republic - A Strategy with Key Actions for the European Structural and Investment Funds - Anti-Fraud Knowledge Centre](https://antifraud-knowledge-centre.ec.europa.eu/library-good-practices-and-case-studies/good-practices/tackling-fraud-and-corruption-risks-slovak_en)

- [08/09/2023 1 Group of States against Corruption (GRECO)](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/ImplementationReviewGroup/4-8September2023/presentation/res.14th_IRG_panel_1_GRECO_presentation_.pdf)

- [THEMATIC COMPILATION OF RELEVANT INFORMATION SUBMITTED BY SLOVENIA](https://www.unodc.org/documents/corruption/WG-Prevention/Art_6_Preventive_anti-corruption_bodies/Slovenia.pdf)

- [Country Profile: Slovakia](https://www.unodc.org/corruption/en/country-profiles/data/SVK.html)

- [11/11/2024 1 Group of States against Corruption (GRECO)](https://track.unodc.org/uploads/documents/UNCAC/WorkingGroups/ImplementationReviewGroup/4-8November2024/presentations/IRG15_2nd_res_Panel_3_GRECO.pdf)

- [Corruption Threatens Democracies Worldwide, Transparency International Warns | OCCRP](https://www.occrp.org/en/news/corruption-threatens-democracies-worldwide-transparency-international-warns)

- [Group of States against Corruption (GRECO)](https://www.unodc.org/documents/commissions/CCPCJ/CCPCJ_Sessions/CCPCJ_32/ISM_TD_Kyoto/Statements/7_Laura_Sanz-Levia_GRECO_slides_Theme_2_LSL_2023.pdf)

- [EU network against corruption - European Commission](https://home-affairs.ec.europa.eu/networks/eu-network-against-corruption_en)

- [Criminal Office of the Financial Administration of the Slovak Republic - European Anti-Fraud Office](https://anti-fraud.ec.europa.eu/organisations/criminal-office-financial-administration-slovak-republic_en)

- [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information)

- [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service)

- [Where is OFAC&#x27;s Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions)

- [Sanctions List Search Tool | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-search-tool)

- [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/)

- [Program Tag Definitions for OFAC Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/program-tag-definitions-for-ofac-sanctions-lists)

- [Office of Foreign Assets Control - Sanctions Programs and Information | Office of Foreign Assets Control](https://ofac.treasury.gov/office-of-foreign-assets-control-sanctions-programs-and-information)

- [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions)

- [United Nations Security Council Consolidated List | Security Council](https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list)

- [OFAC - Sanctions List Site](https://ofac.treasury.gov/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists)

- [EN EN EUROPEAN COMMISSION Brussels, 25.11.2025 C(2025) 9068 final](https://economy-finance.ec.europa.eu/document/download/defca827-de09-4075-a5d0-a5a78c5a917a_en?filename=C_2025_9068_EN_Slovakia.pdf)

- [EU Releases Funds to Slovakia after Standoff on Law Changes - Bloomberg](https://www.bloomberg.com/news/articles/2024-10-23/eu-releases-funds-to-slovakia-after-standoff-on-law-changes)

- [Article 7 procedures - consilium.europa.eu - European Union](https://www.consilium.europa.eu/en/policies/article-7-procedures/)

- [Timeline - Article 7: the story so far - consilium.europa.eu](https://www.consilium.europa.eu/en/policies/article-7-procedures/timeline-the-story-of-article-7/)

- [November infringements package: key decisions](https://ec.europa.eu/commission/presscorner/detail/en/inf_25_2481)

- [Remarks by Commissioner McGrath at the plenary debate on the Rule of Law and management of funds in Slovakia](https://ec.europa.eu/commission/presscorner/detail/en/speech_25_2080)

- [Council Recommendation of 21 January 2025 endorsing the ...](https://economy-finance.ec.europa.eu/document/download/a68d515f-2c88-451d-9348-a9252b853623_en?filename=MTFSP_2025_SK.pdf&prefLang=sl)

- [2025 Rule of Law Report: the importance of the rule of law for Europe&#x27;s democracy, security and economy - European Commission](https://cyprus.representation.ec.europa.eu/news/2025-rule-law-report-importance-rule-law-europes-democracy-security-and-economy-2025-07-08_en)

- [Remarks by Commissioner McGrath at the plenary debate on the rule of law, fundamental rights, and misuse of EU funds in Slovakia](https://ec.europa.eu/commission/presscorner/detail/en/speech_26_393)

- [July infringements package: key decisions](https://ec.europa.eu/commission/presscorner/detail/en/inf_25_1628)

- [FATF / MONEYVAL](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Slovak-Republic-Dec-2024.html)

- [FATF / MONEYVAL](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Slovakia-FUR-2024.pdf.coredownload.inline.pdf)

- [FATF](https://www.fatf-gafi.org/en/countries/detail/Slovakia.html)

- [European Commission](https://cyprus.representation.ec.europa.eu/news/2025-rule-law-report-importance-rule-law-europes-democracy-security-and-economy-2025-07-08_en)

- [European Commission](https://ec.europa.eu/commission/presscorner/detail/en/speech_26_393)

- [Council of the European Union](https://www.consilium.europa.eu/en/policies/article-7-procedures/)

- [Council of the European Union](https://www.consilium.europa.eu/en/press/press-releases/2024/05/30/anti-money-laundering-council-adopts-package-of-rules/)

- [European Commission / AMLA](https://finance.ec.europa.eu/financial-crime/amla/about-amla_en)

- [OCCRP / VSquare / ICJK](https://www.occrp.org/en/scoop/hotline-to-the-kremlin-how-hungary-colluded-with-russia-to-weaken-eu-sanctions)

- [OCCRP](https://www.occrp.org/en/news/hungary-to-veto-new-eu-russia-sanctions-over-druzhba-oil-transit)

- [OCCRP / iStories](https://www.occrp.org/en/news/shadowy-oil-trader-with-kremlin-orban-ties-supplied-billions-in-russian-crude-to-europe)

- [OCCRP](https://www.occrp.org/en/daily/17385-preghozin-s-unsanctioned-offshore-companies-linked-to-the-uk-and-the-eu)

- [OCCRP](https://www.occrp.org/en/daily/14433-spain-losses-millions-in-a-carousel-fraud-case)

- [OCCRP / ICJK](https://www.occrp.org/en/news/slovakia-govt-to-disband-police-agency-investigating-corruption)

- [Bloomberg](https://www.bloomberg.com/news/articles/2025-12-18/slovak-court-blocks-fico-s-crackdown-on-whistleblower-protection)

- [OCCRP / Transparency International](https://www.occrp.org/en/news/corruption-threatens-democracies-worldwide-transparency-international-warns)

- [European Commission e-Justice Portal / Slovak national contribution](https://webgate.ec.europa.eu/e-justice/fileDownload.do?id=d65869c3-820c-4052-af6f-7e5abbf169d4)

- [UNODC / Slovak national submission](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2022-November-7-11/contributions_to_CAC-COSP-WG.2-2022-CRP.1/SLOVAKIA_EN.pdf)

- [Chainalysis](https://www.chainalysis.com/blog/europe-crypto-adoption-2025/)

Coverage gaps

fim-int-2026-07-07-G001: Slovak-language National Bank of Sl… fim-int-2026-07-07-G001: Slovak-language National Bank of Slovakia enforcement bulletins have not been directly accessed, limiting confidence in domestic AML supervisory fine/enforcement-statistics coverage. [resolved]

fim-int-2026-07-07-G002: Statistical and supervisory data un… fim-int-2026-07-07-G002: Statistical and supervisory data underlying the Slovak FIU&#x27;s VASP sectorial risk assessment is incomplete, limiting independent verification of the scale of unsupervised crypto-to-fiat flow. [resolved]

fim-int-2026-07-07-G003: The specific Slovak implementing le… fim-int-2026-07-07-G003: The specific Slovak implementing legislation and its transposition timeline for 6AMLD has not been independently confirmed this baseline. [resolved]

fim-int-2026-07-07-G004: Quantitative remediation progress o… fim-int-2026-07-07-G004: Quantitative remediation progress on the R.10 CDD deficiency (e.g., STR volumes, CDD enforcement fines) is not available beyond MONEYVAL narrative ratings. [resolved]

fim-int-2026-07-07-G005: Primary Slovak corporate-registry e… fim-int-2026-07-07-G005: Primary Slovak corporate-registry extracts for the Flash Asia/Beijing Flash Asia filings have not been independently verified beyond OCCRP secondary reporting. [resolved]

fim-int-2026-08-05-G001: No direct Slov-Lex or europa.eu pri… fim-int-2026-08-05-G001: No direct Slov-Lex or europa.eu primary citation located for AMLR/AMLD6/AMLA texts this cycle; reliance on Tier-3/4 secondary sources caps confidence below High. [resolved]

fim-int-2026-08-05-G002: No direct consilium.europa.eu prima… fim-int-2026-08-05-G002: No direct consilium.europa.eu primary text located for the EU 20th sanctions package this cycle. [resolved]

fim-int-2026-08-05-G003: Slovakia-specific National Risk Ass… fim-int-2026-08-05-G003: Slovakia-specific National Risk Assessment not located this cycle; UK NRA and EU SNRA refresh windows tracked instead. [resolved]

fim-int-2026-08-05-G004: D6 (Compliance Technology and Activ… fim-int-2026-08-05-G004: D6 (Compliance Technology and Active Defence) coverage thin this cycle for Slovakia; no RegTech/AI-monitoring development identified. [resolved]

fim-int-2026-08-05-G005: D3 (Enabler Jurisdictions) coverage… fim-int-2026-08-05-G005: D3 (Enabler Jurisdictions) coverage thin specifically for Slovakia this cycle; Tier D enabler findings (Cambodia, Laos) sourced instead. [resolved]

fim-int-2026-09-05-G001: Tier D (KH/LA/MX/CO) jurisdiction w… fim-int-2026-09-05-G001: Tier D (KH/LA/MX/CO) jurisdiction watch not reached this cycle; pooled union research budget allocated to establishing SK baseline. [resolved]

fim-int-2026-09-05-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-05-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): No T1 European Commission infringement-proceedings source retrieved this cycle to corroborate Slovakia&#x27;s inclusion among the 11 states missing the 6AMLD deadline. [resolved]

fim-int-2026-09-05-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-05-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D1&#x27;}): No T1 Council press release retrieved this cycle to corroborate Slovakia&#x27;s sanctions-renewal-cycle veto directly; sourced from T3 wire report only. [resolved]

fim-int-2026-09-05-G004 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-05-G004 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D3&#x27;}): D3 enabler-jurisdiction and D4 conflict-finance SK-specific findings not reached this cycle within pooled research budget. [resolved]

fim-int-2026-09-28-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D2&#x27;}): No SK national AMLD6 transposition instrument was located this cycle for the beneficial-ownership-register deadline of 10 July 2026. [resolved]

fim-int-2026-09-28-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D1&#x27;}): No SK-specific corridor or evasion signal was located this cycle in the Russian sanctions-evasion, sanctions-regime-divergence, or enabler-jurisdiction domains. [resolved]

fim-int-2026-09-28-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-09-28-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D5&#x27;}): The precise domestic mechanics and closing date of Slovakia&#x27;s own MiCA transitional window rest on secondary (T3) commentary and were not confirmed against an NBS primary notice this cycle. [resolved]

fim-int-2026-10-04-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-04-G001 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D1&#x27;}): D1 (sanctions) and D4 (conflict finance) could not be substantively searched this cycle because the pooled union web-search budget was directed at SK-bound modules per single-JID dispatch scope. [resolved]

fim-int-2026-10-04-G002: Tier D watch jurisdictions (Cambodi… fim-int-2026-10-04-G002: Tier D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) were not queried this cycle due to the single-JID dispatch scope. [resolved]

fim-int-2026-10-04-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-10-04-G003 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D7&#x27;}): No SK-specific national transposition instrument for 6AMLD or AMLR was located this cycle; status not established with T1-T3 certainty. [resolved]

fim-int-2026-10-11-G001: No SK-specific 6AMLD transposition … fim-int-2026-10-11-G001: No SK-specific 6AMLD transposition delta located this cycle. [resolved]

fim-int-2026-10-11-G002: No AMLA direct-supervision selectio… fim-int-2026-10-11-G002: No AMLA direct-supervision selection status for SK obliged entities located this cycle. [resolved]

fim-int-2026-10-11-G003: No SK-specific sanctions regime div… fim-int-2026-10-11-G003: No SK-specific sanctions regime divergence posture located this cycle. [resolved]

fim-int-2026-10-18-G001: Secondary sources disagree on the g… fim-int-2026-10-18-G001: Secondary sources disagree on the goAML mandatory-registration deadline for existing obliged entities (30 November 2026 vs 31 August 2026); primary instrument confirms 30 November 2026 for entities obliged as of 1 June 2026 but the discrepancy is not fully resolved. [resolved]

fim-int-2026-10-18-G002: No Slovakia-specific D1 (sanctions)… fim-int-2026-10-18-G002: No Slovakia-specific D1 (sanctions), D3 (enabler jurisdiction), D4 (conflict finance) or D6 (compliance technology) development was located this cycle despite a general search sweep. [resolved]

fim-int-2026-10-25-G001: Tier D jurisdiction coverage (Cambo… fim-int-2026-10-25-G001: Tier D jurisdiction coverage (Cambodia, Laos, Mexico, Colombia) was not actively re-swept this cycle given the single-JID SK binding of this dispatch. [resolved]

fim-int-2026-10-25-G002: No SK-specific enforcement actions … fim-int-2026-10-25-G002: No SK-specific enforcement actions or sanctions designations were located for this window; absence recorded rather than silently absorbed. [resolved]

fim-int-2026-11-01-G001: No SK-linked Tier D sweep run this … fim-int-2026-11-01-G001: No SK-linked Tier D sweep run this cycle; no D1-D4, D6 SK-specific signal located within the 2026-10-25 to 2026-11-01 window beyond standing MONEYVAL/AMLA context. [open]

fim-int-2026-11-01-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;… fim-int-2026-11-01-G002 ({&#x27;scheme&#x27;: &#x27;financial_integrity&#x27;, &#x27;value&#x27;: &#x27;D8&#x27;}): 365.bank-ČSOB merger reported only via tertiary source (Wikipedia citing KBC newsroom); no primary KBC/ČSOB release opened directly. [open]

FIM-GAP-001 (D5): The Slovak FIU is legally responsible for … FIM-GAP-001 (D5): The Slovak FIU is legally responsible for VASP AML/CFT compliance but conducts no risk-based supervision of the sector, and its own VA/VASP sectorial risk assessment was assessed by MONEYVAL/FATF as of limited usefulness due to supervisory and statistical-data deficiencies.

FIM-GAP-002 (D2): The Fico government&#x27;s abolition of the Off… FIM-GAP-002 (D2): The Fico government&#x27;s abolition of the Office of the Special Prosecutor, penal code amendments reducing corruption sentences, and pressure on anti-corruption police (NAKA) have weakened the institutional capacity to investigate and prosecute high-level corruption and money-laundering-adjacent offences, prompting sustained EU rule-of-law scrutiny.

FIM-GAP-003 (D2): FATF Recommendation 10 (customer due dilig… FIM-GAP-003 (D2): FATF Recommendation 10 (customer due diligence), one of the &#x27;big six&#x27; recommendations, remains rated Partially Compliant, triggering placement of Slovakia into compliance-enhancing procedures under FATF/MONEYVAL Rule of Procedure 23.

FIM-GAP-004 (D6): Granular data on National Bank of Slovakia… FIM-GAP-004 (D6): Granular data on National Bank of Slovakia AML supervisory fines, individual bank sanctions, or enforcement statistics for the 18-month baseline window was not independently locatable in English-language primary sources during this research pass; Slovak-language NBS enforcement bulletins were not directly accessed.

## Evidence

#### Confidence-tiered claims

7 Compliant / 29 Largely Compliant / 4 Partially Compliant following 4th Enhanced FUR; 5th-round follow-up process closed [[Source 1]](#sec-sources)

Probable · 1 source

DNFBP supervision (casinos, lawyers, notaries, accountants, TCSPs) remains insufficient per R.28 [[Source 1]](#sec-sources)

Probable · 1 source

National transitional VASP regime expired 1 July 2026; six CASPs licensed by NBS [[Source 1]](#sec-sources)

Probable · 1 source

EBA completed transfer of AML/CFT mandates to AMLA on 1 January 2026; AMLA expects full operability by 2028 [[Source 1]](#sec-sources)

Probable · 1 source

No SK-specific national transposition instrument for 6AMLD or implementing legislation for AMLR was located this cycle; EU-wide 6AMLD transposition deadline remains 10 July 2027 (earlier 10 July 2026 for specific supervisory-college articles) [[Source 1]](#sec-sources)

Uncertain · 1 source

7 Compliant, 29 Largely Compliant, 4 Partially Compliant out of 40 FATF Recommendations; 5th-round enhanced follow-up process ended [[Source 1]](#sec-sources)

Probable · 1 source

Six Slovak-headquartered firms hold CASP authorisation as of NBS&#x27;s 29 July 2026 stocktake, out of 312 EU-wide [[Source 1]](#sec-sources)

Probable · 1 source

NBS revoked the investment-services authorisation on 15 April 2026 following a record €250,000 fine; petitioned for a court-appointed liquidator [[Source 1]](#sec-sources)

Probable · 1 source

Not on the FATF grey or black list as of the 19 June 2026 Plenary [[Source 1]](#sec-sources)

Probable · 1 source

No international sanctions currently in force against Slovakia [[Source 1]](#sec-sources)

Uncertain · 1 source

A March 2026 amendment (effective 1.3.2026) added a mandatory external cybersecurity audit to the CASP application and ESMA knowledge/competence criteria for crypto-asset advisers [[Source 1]](#sec-sources)

Probable · 1 source

Tightens KÚV identification/verification from multiple independent sources, extends scope to foreign trusts and asset pools, mandates goAML filing, restricts public UBO data access to legitimate-interest requesters [[Source 1]](#sec-sources)

Probable · 1 source

Obliged entities must register and file suspicious/unusual-transaction reports exclusively through the goAML system, subject to narrow outage exceptions [[Source 1]](#sec-sources)

Probable · 1 source

NBS is prudential supervisor of CASPs and ART issuers under Act 248/2024 Coll.; FIU is AML/CFT supervisor of the same firms [[Source 1]](#sec-sources)

Probable · 1 source

Six MiCA-licensed CASP entities as of 8 October 2026 survey, with a seventh (Tatra banka) pending; approximately 6% of Slovak adults hold crypto-assets [[Source 1]](#sec-sources)

Probable · 1 source

UBO data continues to be held in a non-public section of the Commercial Register rather than a freestanding public register, flagged by MONEYVAL/IDFI as a continuing adequacy concern [[Source 1]](#sec-sources)

Probable · 1 source

MONEYVAL 4th Enhanced Follow-up Report (December 2025) maintained Slovakia&#x27;s overall rating at Partially Compliant, upgrading 8 Recommendations including PEPs and VASPs, while declining to upgrade R.8 (NPOs) and R.28 (DNFBP supervision) [[Source 1]](#sec-sources)

Probable · 1 source

AMLR (Reg (EU) 2024/1624) applies directly from 10 July 2027; AMLD6 (Dir (EU) 2024/1640) must be transposed by the same date; neither is yet in force for Slovakia [[Source 1]](#sec-sources)

Probable · 1 source

Slovakia closed its national VASP-to-CASP transition early, on 30 December 2025, ahead of the EU-wide MiCA Article 143(3) backstop of 1 July 2026 [[Source 1]](#sec-sources)

Probable · 1 source

Not on the FATF list of jurisdictions under increased monitoring [[Source 1]](#sec-sources)

Probable · 1 source

Národná Banka Slovenska supervises financial-market obliged entities; the Police Force FIU is the designated reporting authority [[Source 1]](#sec-sources)

Probable · 1 source

365.bank merges into ČSOB on 1 November 2026 [[Source 1]](#sec-sources)

Probable · 1 source

365.bank legally merges into ČSOB on 1 November 2026; brand coexistence continues to 2027. [[Source 1]](#sec-sources)

Probable · 1 source
