Presently, it is obligatory that a company which is not registered in the Register of Public Sector Partners (RPSP) identifies its advantage end user (hereafter only as AEU).
Having amended Act no. 297/2008 Coll. on the Prevention of Legalization of Proceeds of Criminal Activity and Terrorist Financing, as amended, (hereafter only as the “AML Act”) on 15 March 2018, this obligation is now extended to include also advisors entering into a business relation. Pursuant to Art. 10 of the AML Act the advisor is, inter alia, obliged to identify also the advantage end user of his or her client as part of the general services.
Another new obligation is (1) to identify one’s own advantage end user (Art. 10a of the AML Act) and (2) to revise the program of the line of business of the obliged person in accordance with the new requirements of the AML Act (Art. 20 of the AML Act).
As of 1 November 2018, the obligation emerges to register the advantage end user also to the Business Register of the Slovak Republic (Art. 2, par. 3 of the Act on Business Register). The legal persons who are registered in the Business Register until 31 October 2018 will be obliged to submit a proposal to record the data about the advantage end user (Art. 15e of the Act on Business Register) until 31 December 2019.
