The amendment to Act No. 297/2008 Coll. on protection against the legalisation of proceeds of criminal activity and on protection against the financing of terrorism (the AML Act), effective from 1 June 2026, fundamentally changes the compliance obligations applicable to obliged entities. It tightens customer due diligence requirements, the identification and verification of beneficial owners (BOs), and introduces mandatory registration in the goAML system.

The obligation to register in the goAML system applies to every obliged entity. Registration must be completed in the information system of the Financial Intelligence Unit (hereinafter referred to as the “FIU”) at: https://stork.minv.sk/goAMLWeb_PRD/Home, no later than 30 November 2026.

Registration in the goAML system also means that an obliged entity must be prepared to fulfil its AML obligations in practice. It is therefore not sufficient to have internal rules and procedures in place merely as a formality; the AML system must be properly configured, functional and applied in the company’s day-to-day activities. An obliged entity must be able to demonstrate that the measures adopted are also implemented in practice.

The most important practical step for business owners is therefore to verify as soon as possible whether you qualify as an obliged entity. If you do, registration in goAML is unavoidable.

Who qualifies as an obliged entity?

Obliged entities are exhaustively listed in Section 5 of the AML Act. They primarily include entities that, in the course of their activities, handle funds or assets, or arrange transactions that carry a risk of money laundering or terrorist financing.

These include, in particular, banks and other financial institutions, life insurance companies, pension and supplementary pension management companies, securities dealers, payment institutions and crypto-asset service providers. Obliged entities also include lawyers, notaries, auditors, accountants, tax advisers, insolvency administrators, companies engaged in real estate activities, particularly the brokerage of property sales, rentals and purchases, operators of gambling activities and auction houses, as well as traders in works of art, precious metals and precious stones, to the extent specified by the AML Act.

Under certain conditions, an entrepreneur who accepts or carries out a cash transaction worth at least EUR 10,000 may also qualify as an obliged entity.

Under the AML Act, obliged entities are required, in particular, to:

• identify and verify customers,
• identify beneficial owners (BOs),
• assess risks, and
• report unusual business transactions to the competent authorities.

Stricter identification and verification of BOs

The amendment addresses shortcomings in the identification and verification of BOs by:

• expanding the definition of a BO in relation to asset arrangements and foreign trusts;
• introducing an obligation to obtain the first and last names of persons serving on the governing body of a legal entity and an asset arrangement;
• requiring obliged entities to verify BO information against reliable sources (the Register of Public Sector Partners (RPVS), constitutional documents and foreign BO registers), including for customers who do not fall into a “higher-risk category”.

In practice, this means greater emphasis on actually verifying the customer’s ownership and management structure, rather than merely accepting information from a single register or document. An obliged entity should be able to demonstrate which sources it relied on when determining the identity and status of a BO. Since the Business Register Act was also amended with effect from 17 August 2026, obtaining this information will be easier than before under the conditions laid down by law.

New rules for suspicious/unusual transactions

The amendment also changes the rules governing suspicious and unusual business transactions:

• obliged entities are granted the right (but not the obligation) to discontinue the performance of customer due diligence if they suspect that continuing the process could lead to the disclosure of their suspicion.

What does this mean in practice?

• the company must have internal criteria in place for identifying unusual transactions;
• an internal process must determine whether to continue or discontinue customer due diligence when a suspicion arises;
• a clear procedure must be established for submitting reports through goAML.

Until now, obliged entities were required to have a system in place for communicating with the FIU, but reports could also be submitted outside goAML. This is changing, and from 1 June 2026:

• reports of unusual business transactions must be submitted through the goAML system; if the system is unavailable, the law allows the reporting obligation to be fulfilled by another electronic means that ensures the confidentiality of the reported information;
• the FIU can use goAML to communicate efficiently with obliged entities and send them messages and information.

The amendment to the AML Act also introduces the Register of Foreign Trusts,

which is intended to ensure that foreign trusts connected to the territory of the Slovak Republic are recorded. The registration obligation arises in particular where the trustee resides, has a place of business or has its registered office in Slovakia, where the trust intends to establish a business relationship with an obliged entity in the Slovak Republic, or where it intends to acquire real estate in Slovakia. However, the registration obligation does not apply if the foreign trust is registered in a register corresponding to the Slovak Register of Foreign Trusts in another Member State.

The Ministry of the Interior of the Slovak Republic is responsible for administering and operating the register, while applications for registration must be submitted to any district office located in the seat of a region. The register records, in particular, the trust’s identification details and information about its BOs. However, only the name (or other designation) of the trust and the unique identifier assigned by the register are publicly accessible.

The amendment also adds Section 24b to the AML Act, under which a trustee of a foreign trust residing, having a place of business or having its registered office in the Slovak Republic is required to maintain and update records of the assets under administration for a period of at least five years.

Registration in the register is not constitutive and does not change the legal status of a foreign trust. The existence of the register therefore does not, in itself, constitute a condition for the establishment of a trust or its entitlement to acquire assets. However, when acquiring real estate, the law introduces an obligation to register before entering into the agreement for its acquisition.

New administrative offences and fines

The range of other administrative offences is being expanded:

Failure to fulfil the registration obligation in goAML is considered an administrative offence for which the FIU may impose a fine of up to EUR 1 million. For obliged entities, this means that registration must not be postponed or treated as a mere “formality”.

Registration deadlines

The amendment to the AML Act introduces a transitional period for fulfilling the registration obligation:

• obliged entities existing as of 1 June 2026:

must register in the FIU’s goAML system by 30 November 2026;

• trustees of foreign trusts meeting the relevant conditions as of 1 June 2026:

must register the trust in the Register of Foreign Trusts by 30 November 2026.

Entities that acquire the status of an obliged entity after 1 June 2026 are subject to an ongoing obligation to register in goAML within 30 days of acquiring that status.

Practical checklist for business owners and managers

For a company that may qualify as an obliged entity, it is advisable to take at least the following steps:

Verify whether the company qualifies as an obliged entity

Analyse the company’s business activities (e.g. accounting, tax advisory services, real estate, financial services).

Register in goAML

Prepare the details of the obliged entity and the person authorised to act on its behalf, and appoint a system administrator.

Register by 30 November 2026 (if you qualify as an obliged entity as of 1 June 2026), or within 30 days of acquiring that status, at: https://stork.minv.sk/goAMLWeb_PRD/Home.

Update the internal AML system

• policies on identifying BOs and members of governing bodies;
• customer risk assessment processes;
• procedures for reporting unusual business transactions through goAML.

Ensure access to reliable information sources

Ensure access to the RPVS, clients’ corporate documents and, where applicable, foreign BO registers.

Address trusts and cross-border structures

If foreign trusts form part of your structures (or those of your clients), verify whether registration is required and whether records must be maintained for at least five years.

Prepare for an FIU inspection

Keep records demonstrating how the AML system operates in practice so that you can prove during an inspection that it is not merely a set of formal documents.

What does this mean for companies?

The amendment to the AML Act introduces a significant change in the registration of obliged entities in the goAML system. The key criterion remains whether a particular entity meets the statutory definition of an obliged entity. If it does, it becomes subject not only to registration obligations vis-à-vis the FIU, but also to the obligation to ensure that its AML system functions properly and that all other obligations under the AML Act are fulfilled. Registration should therefore not be viewed as a purely formal administrative requirement. It forms part of a broader framework of measures designed to prevent money laundering and terrorist financing. Failure to comply with obligations under the AML Act may result in substantial fines, of up to EUR 1 million depending on the nature and severity of the breach.

Article author: JUDr. Miroslava Kanuščáková – in-house corporate lawyer, who has been working at KAMI PROFIT for 10 years.

KAMI PROFIT is an established company in the construction, property development and project management sectors in Slovakia and the Czech Republic. It has been operating on the market for more than 20 years, during which time it has participated in the delivery of hundreds of projects in residential construction, education, healthcare and public amenities.

KAMI PROFIT places emphasis on the quality of execution, modern technologies, functional architecture and sustainable solutions. It applies its experience and know-how not only to construction delivery, but also to the preparation and management of property development projects.

In recent years, the company has continued to grow and gradually expand its operations beyond the Slovak market. It is currently carrying out construction and property development projects in Slovakia, the Czech Republic and Croatia, further developing its activities across the Central European region.