1. Applicable Financial Sanctions laws: Which national laws bring EU Russia sanctions laws into effect? If EU sanctions laws do not apply, which do?
  2. Does the same framework apply to Financial Sanctions against other countries (e.g. Iran?) If so, please provide link to relevant government website listing these.
  3. Which agency issues “licences” permitting certain activities which would otherwise be prohibited by Financial Sanctions laws?
  4. Link to Consolidated List of individuals and companies subject to Financial Sanctions
  5. Can a breach of Financial Sanctions laws be treated as a criminal offence? Please indicate the relevant law. 
  6. What are the penalties for a criminal breach of Financial Sanctions?
  7. Who investigates criminal breaches of Financial Sanctions laws?
  8. Are there non-criminal (e.g. administrative or civil) penalties and/or fines for a breach of Financial Sanctions?
  9. What are the penalties for a non-criminal breach of Financial Sanctions?
  10. Who investigates non-criminal breaches of Financial Sanctions laws?
  11. Key government guidance relating to the implementation of Financial Sanctions (e.g. FAQs)

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1. Applicable Financial Sanctions laws: Which national laws bring EU Russia sanctions laws into effect? If EU sanctions laws do not apply, which do?

The sanctions are primarily brought into effect by Act No. 289/2016 Coll. on the implementation of international sanctions, which was recently amended to address the existing shortcomings in the implementation of sanctions and MONEYVAL's reservations about the existing framework. The amendment is awaiting signature by the President and publication in the Collection of Laws. The amendment will come into force on 15 January 2025.

The framework is not limited to EU sanctions and implements international sanctions as such. The Slovak government does not maintain an up-to-date website on sanctioned persons or countries. In this respect, it is advisable to consult the annexes to the UN and EU regulations directly applicable to Slovakia.

3. Which agency issues “licences” permitting certain activities which would otherwise be prohibited by Financial Sanctions laws?

Under the existing framework there is no one agency able to give exemption. The power to do so is granted to multiple central bodies pursuant to Act 575/2001 Coll. Competent central body for the financial sector is the Ministry of Finance. The indicative list of bodies and their contact details can be found on the following link (available in English): https://www.mfsr.sk/en/finance/financial-market/eu-un-sanctions/international-eu-un-sanctions/contact-data-competent-public-authorities/

The Slovak government does not maintain an up-to-date website on sanctioned persons. For indicative lists, please see the useful link attached to the answer to the last question.

5. Can a breach of Financial Sanctions laws be treated as a criminal offence? Please indicate the relevant law. 

No. However, an amendment to the Criminal Code, Act No. 300/2005 Coll., is in the legislative process and will introduce provisions on criminal penalties in connection with breaches of international sanctions. Moreover, the amendment implements Directive 2024/1226. It is planned that this amendment will come into force on the 20 May 2025.

6. What are the penalties for a criminal breach of Financial Sanctions?

None at the time of writing. Under the proposed amendment, imprisonment of up to 8 years may be imposed.

7. Who investigates criminal breaches of Financial Sanctions laws?

Under the existing framework in the Slovak Republic, it is currently not possible to punish violations of international sanctions following the norms of criminal law, except for those that overlap with other criminal offences.

8. Are there non-criminal (e.g. administrative or civil) penalties and/or fines for a breach of Financial Sanctions?

Yes, pursuant to Act No. 289/2016 Coll.

9. What are the penalties for a non-criminal breach of Financial Sanctions?

Fines of up to EUR 1 659 700 can be imposed. Alternatively, forfeiture of property either on its own or in combination with a fine.

10. Who investigates non-criminal breaches of Financial Sanctions laws?

Central bodies under Act 575/2001 Coll. are responsible for investigations and fines. A list of these bodies can be found in the section on licences. Competent central body for the financial sector is the Ministry of Finance.

11. Key government guidance relating to the implementation of Financial Sanctions (e.g. FAQs)

Guidance (available in English): Competent public government authority for the financial sector - Processes | Ministry of Finance of the Slovak Republic 

Useful links (available in English): https://www.mfsr.sk/en/finance/financial-market/eu-un-sanctions/international-eu-un-sanctions/important-websites-on-sanctions/