On 1 June 2026, an amendment to the AML Act will come into force. Its object is especially to specify the definition of a beneficial owner with respect to asset pools and foreign trust funds, changes to the identification of beneficial owners, adjusting the procedure in cases of suspected unusual business transactions, mandatory communication with the Financial Intelligence Unit via the GoAML system, and the establishment of the Register of Foreign Trust Funds.

The most significant changes are listed below:

Definition of a beneficial owner in asset pools and foreign trust funds

A person who exercises effective control over the assets of an asset pool through direct or indirect ownership or by other means will also be considered a beneficial owner of the asset pool, provided they do not meet the other definitions of a beneficial owner of an asset pool.

For foreign trust funds, the definition of a beneficial owner has been refined to include cases of beneficiaries designated by characteristics, whereas such persons shall become beneficial owners only at the moment of their identification or designation.

Identification of beneficial owners

In all cases, and therefore not only in the case of increased risk, obliged entities will not be able to rely solely on the register of legal entities when verifying information concerning beneficial owners, but will also have to draw on other reliable sources. Reliable sources of information may include, for example, articles of association and documents submitted by clients, or searches of foreign UBO registers.

When identifying a legal entity or an asset pool, obliged entities will now be expressly required to ascertain the first name and surname of the persons holding positions in the governing body of the legal entity or asset pool.

Modification to the regime in the event of suspicion of an execution of an unusual business transaction

The previous wording of the Act required obliged entities not to carry out basic due diligence in relation to a client if doing so could frustrate or jeopardise the execution of an unusual business transaction. The new legislation

gives obliged entities the option whether to continue performing due diligence, even if they believe that doing so could lead to the disclosure of the obliged entity’s suspicions.

Mandatory communication via the GoAML system

The amendment introduces an obligation to use exclusively the GoAML system, which is already in use, for reporting unusual business transactions. In addition to reporting, the GoAML system also enables further communication with the Financial Intelligence Unit.

For this reason, obliged entities are required to register in the GoAML system within 30 days from the date on which day become an obliged entity. For entities that have already become obliged entities, the deadline for registration is set until 30 November 2026.

This obligation therefore also applies, for example, to a wide range of advisers, real estate agencies, or entrepreneurs providing financial services.

Establishment of the Register of Foreign Trust Funds

Foreign trust funds must be entered in this register if their trustees have their place of residence, place of business or registered office within the territory of the Slovak Republic, plan to establish a business relationship with an obliged entity, or plan to acquire real estate within the territory of the Slovak Republic for the benefit of a foreign trust fund. The competent authority for registration will be the district office in the regional capital.

Funds are not entered in the register if they are registered in a equivalent register of another Member State.

Managers of foreign trust funds with their residence, registered office or place of business within the territory of the Slovak Republic are also now required to maintain and update records of the assets under management for a period of at least five years.

The condition of good repute of the beneficial owner as an obstacle to the operation of certain trades

A legal entity whose beneficial owner is not of good repute will not be able to carry out real estate activities or provide accounting services. Likewise, it will not be able to carry out a trade under which it can provide a person acting, for example, as a statutory body for commercial companies, nor a trade under which it can provide a registered office for legal entities and special-purpose asset pools.

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This material is for general information on current topics only, it is not advice. It does not take into account any special circumstances, financial situations or special requirements of the addressees. Recipients should therefore always seek appropriate professional services for the information provided. Notwithstanding the careful compilation of this material, bpv Braun Partners s.r.o. advokáti, its partners, associates or co-operating solicitors and tax advisers cannot guarantee the accuracy or completeness of the information contained herein and accepts no responsibility for acting or refraining from acting on the basis of the information contained in this material.