Every company that is an obliged entity under the Slovak anti-money laundering act must register in the goAML system. This can include a company that has, for example, accounting services among its registered business activities but does not provide them, or one that has carried out a cash transaction of EUR 10,000 or more. Entities that were already obliged entities before 1 June 2026 must register by 30 November 2026.

Who must register

The obligation can arise in four ways. For some activities, the authorisation alone is enough; for others, what matters is whether the activity is actually carried out, or the value of the transaction.

Authorisation for specified activities. A company must register if it is authorised to carry out a specified activity, even if it does not actually carry it out. This applies in particular to banking and financial services, including financial leasing and trading in receivables, accounting, auditing, tax advisory services, brokering the sale and purchase of real estate, freight forwarding, and postal and courier services. The authorisation is usually evident from the company's registered business activities.

Provision of certain services. For organisational and economic consultancy and for services to companies, what matters is whether the company actually provides them. This covers, in particular, incorporating companies, acting as the statutory body, or a member of the statutory body, of other companies, providing a registered office or correspondence address, and advising on the purchase and sale of real estate or businesses. This also applies to services provided within a group. The registered business activity "activities of business, organisational and economic consultants" does not in itself require registration.

Transactions of EUR 10,000 or more. A letting agent must register if the monthly rent reaches at least EUR 10,000. Dealers in works of art, antiques, precious metals and precious stones, auction houses and pawnshops must register if they carry out a transaction worth at least EUR 10,000, regardless of the method of payment. Linked transactions are counted together.

Cash payments. Any company must register if it carries out a cash transaction of at least EUR 10,000, including through a series of linked payments. For businesses, cash payments above EUR 5,000 are prohibited in Slovakia. If such a transaction nevertheless takes place, the obligation arises.

Who does not need to register. A company that does not fall within any of the categories described above does not need to register. Being a holding company or having ownership links with other companies does not in itself trigger the obligation.

This classification is based on the interpretation of the Slovak Financial Intelligence Unit (FIU), which approves registrations.

Deadlines and how to register

Deadlines. Entities that were obliged entities before 1 June 2026 must register by 30 November 2026. Others have 30 days from the day they became obliged entities.

What goAML is. goAML is an information system of the Slovak Police Force through which obliged entities report unusual transactions and communicate with the FIU. Registration is mandatory even for companies that have never filed a report and do not intend to do so.

Procedure. The application is filed electronically via the goAML portal. It must designate an account administrator and include proof of authorisation appropriate to the applicant, such as an extract from the Commercial Register, a trade licence or a decision of the regulator. Confirmation of filing does not mean approval. The FIU approves the application and assigns a goAML identifier.

One registration. A company that falls into several categories registers only once. In the form, it states its main category and adds the others in the notes.

What registration entails

Further obligations. In addition to registering, an obliged entity must have an internal AML programme and a risk assessment in place. This obligation already applied before the amendment.

Sanctions. For a breach of the registration obligation, the FIU may impose a fine of up to EUR 1,000,000 or up to twice the unlawful benefit, whichever is higher. For banks and financial institutions, the upper limit is EUR 5,000,000 or 10% of total annual turnover, whichever is higher; for an institution that is part of a consolidated group, the consolidated turnover is used. These are maximum amounts; the FIU takes into account in particular the seriousness and duration of the breach. A fine may also be imposed on a member of the statutory body.

Narrowing the scope of registered business activities. If a company does not carry out a specified activity and has no plans to do so, the FIU recommends narrowing the scope of its registered business activities. The registration obligation on that ground ceases when the relevant authorisation ends. Until then, we recommend submitting an application for registration.

What we recommend

Review authorisations and services. We recommend reviewing the registered business activities of all Slovak companies and Slovak branches of foreign companies in the group. We also recommend reviewing the services they actually provide, including within the group.

Register or narrow the scope of business activities. For authorisations that are not used, we recommend deciding whether to keep them and register the company, or to narrow the scope of the registered business activities.

File in good time. We recommend filing the application without delay once the obligation has been confirmed, and monitoring its approval and the assignment of the goAML identifier.

Internal procedures. We recommend reviewing the internal AML programme and the risk assessment and designating who in the company manages the goAML registration.

How we can help

We assess whether the registration obligation applies to your company or group. We submit the application for registration on your behalf under a power of attorney and, on request, act as account administrator. We prepare the internal AML programme and the risk assessment and arrange the change of registered business activities in the Commercial Register.

Pavol Blahušiak, Managing Partner
Bronislava Ratkovská, Senior Associate

Legal sources and references