The new Prevention of Money Laundering and Terrorist Financing Act (Zakon o preprečevanju pranja denarja in financiranja terorizma (»ZPPDFT-1«) which transposes the 4th Anti-Money-Laundering Directive (Directive EU 2015/849 of 20 May 2015) to the legislation of Slovenia entered into force on 19. November 2016.

The business entities are obliged to:

  • identify the information on their beneficial ownership,
  • establish and manage an accurate record of information on their beneficial ownership,
  • keep the information on their beneficial ownership for a period of five years and
  • enter the information on their beneficial ownership in to the register of beneficiary owners.

The following information on the beneficial ownership are entered in to the register of beneficiary owners:

  • personal name,
  • address of permanent and temporary residence,
  • date of birth,
  • tax number,
  • nationality,
  • amount of ownership or other means of supervision and
  • the date of registration and deletion of the actual owner from the register.

Business entities shall determine information on their beneficial ownership within one year after the ZPPDFT-1 entered into force (which means until 19. November 2017) and shall enter these information into the registry of beneficial ownership within 14 months after the ZPPDFT-1 entered into force (which means until 19. January 2018).

Obliged entities shall determine information on their clients’ beneficial ownership within two years after the ZPPDFT-1 entered into force (which means until 19. November 2018).

Information on personal name, address of permanent and temporary residence, amount of ownership or other means of supervision and the date of registration and deletion of the actual owner from the register will be publicly available on the website of the registry administrator.

The entities who prove a legitimate interest in money laundering, terrorist financing and related criminal offenses will have the right to access also all the other data. Note that the tax number is not listed neither as publically available information nor as restricted information thus it is unclear whether it will be publically available.

The register of beneficiary owners has not yet been established and publically available. The Rules on establishing, maintenance and keeping the Register of beneficial owners (Rules) have not yet been adopted. The public debate regarding the Rules was concluded on 9. June 2017. Currently the Rules are in the interdepartmental coordination and shall be adopted shortly. In the proposal the Rules define that the registry administrator shall enable the entries into the registry within one year after the ZPPDFT-1 entered into force (which means at the latest on 19. November 2017) and establish the registry of beneficial ownership within 14 months after the ZPPDFT-1 entered into force (which means at the latest on 19. January 2018).