Yes - any single transaction below EUR 15,000 does not require any customer due diligence unless it is a:
a) suspicious transaction;
b) an agreement to enter into a business relationship;
c) an agreement to establish an account, to make a deposit into a deposit passbook or a deposit certificate, or to make any other
type of deposit;
d) an agreement to use a safety deposit box or an agreement on custody;
e) transaction with a Politically Exposed Person ('PEP'); and
f) as part of the business relationship.
Also in the case of life insurance, the customer due diligence is not required if insurance premium payable per year does not exceed EUR
1,000 or if payable in lump-sum does not exceed EUR 2,500 and in certain situations related to pension scheme agreements (no amount
set by law).
An ordinary transaction below EUR 2,000 does not need customer due diligence.
Name, surname, birth identification number or date of birth, place of birth, gender, address and citizenship. These would
normally be verified by an identity card or passport.
the full name, residency/seat, identification (or similar identification received from foreign offices) showing evidence of the
company’s existence (i.e. certificate of incorporation, trade register statement or other). The same principles for 'Individuals' apply for the
identification of individuals in the company’s statutory body. If the company’s statutory body or the owner is another legal entity,
identification documentation must also be collected for that entity. The way of acting of the statutory representatives, acting on behalf of the
legal must be proven, e.g. visible from the certificate of incorporation, trade register statement or other similar document, or power of
attorney must be provided by the client.
The shareholders of a legal entity (with more than 25% holding and/or voting rights) must be ascertained up to the level of the ultimate beneficiary of the transaction, if there are suspicions. Direct and indirect ownership identification requirements are the same as for the relevant legal entity and/or individual.
Enhanced customer due diligence is applicable for: a) a remote financial services agreement; b) a transaction and business relationship with a Politically Exposed Person ('PEP'); and c) a correspondent bank relationship with a foreign credit or similar institution ('Correspondent Institution')
All transactions with PEPs are subject to due diligence including the provision of information and supporting documentation relating to:
a) the purpose and intended nature of the transactions or business relationship;
b) the beneficial owner, if the client is a legal entity;
c) the information required for continuous monitoring of the business relationship; and
d) a review of the income source.
Prior to the creation of a correspondent banking relationship, the following is required: a) sufficient information on the relevant correspondent institution and the nature of its operations; b) publically sourced information to establish the quality of supervision overseeing the correspondent institution; c) an evaluation of measures applied by the correspondent institution against the legitimisation of proceeds of crime and financing terrorism; d) understanding if approval of relevant lead employee to open the corresponding bank relationship was granted, and e) in case of wire transfer, confirmation from the correspondent bank that it has identified the account holder
In the case of a remote financial services agreement:
a) the first payment under this agreement shall be made via an account kept in the customer's name held at a credit institution or a
foreign credit institution operating in the EU or EEA;
b) the customer shall submit to the entity a copy of a document verifying the existence of this account together with copies of the
relevant parts of his identity card and at least one more identification document to validate the customer's identification data of this
card i.e. the type, serial number, issuing country or institution and validity.
Financial analytical department (FAU) of the Police, the Ministry of Interior of the Slovak Republic
The suspicious transaction are identified based on various criteria such as unusual transactions, cash transactions above a certain threshold, international wire transfers etc. But no special report is required.
Potential cash penalties up to EUR 332,000 (depending on the seriousness of the breach) or a suspension of business license for conscious non-compliance within a 12- month period.
No, however, transaction monitoring should be performed by using adequate means which assumes the use of some automated technology.
Yes - in general a transaction that is identified/reported as suspicious can be continued after 48 hours from when it has to be notified to the FAU, unless the FAU requires the transaction to be postponed further and FAU has passed the notification to criminal police (in which case an additional 24hour delay is anticipated by law).
first payment made in an account kept in costumer's name held at credit institution/foreign credit institutioncopy of document verifying the existence of the accountcopy of relevant parts of identity card
Yes - National bank issued a guidelines in this respect for the banking sector
These should be certified by an appropriate person e.g. a notary, local authorities etc. Specific rules apply to credit and financial institutions,
where certain employees are authorized to verify these when opening account, concluding contract, etc