Is Crypto Legal in Slovenia?
Cryptocurrency is prohibited in Slovenia. The jurisdiction has an outright ban on crypto activity, and an active legislative process underway. Bank of Slovenia is among the 2 regulators with oversight. Primary legislation: Markets in Crypto-Assets Regulation. The FATF Travel Rule has not been adopted.
Derived from 372 sourced facts for Slovenia · last updated · primary sources
Overview
Slovenia regulates crypto-asset service providers primarily through the Slovenian Prevention of Money Laundering and Terrorist Financing Act (ZPPDFT-2), which defines VASPs and triggers registration obligations for activities involving exchange, transfer, or custody of virtual assets. The Financial Administration of the Republic of Slovenia (FURS) and the Office for Money Laundering Prevention (UPPD) supervise VASPs, imposing concrete duties including Customer Due Diligence, Enhanced Due Diligence, suspicious transaction reporting to UPPD, record-keeping, and fit-and-proper assessments for management and beneficial owners. Slovenia is a MiCA-adopting EU member state, meaning the incoming Markets in Crypto-Assets Regulation will reshape the authorization landscape, and firms whose assets qualify as securities face additional oversight from the Securities Market Agency (ATVP). (eur-lex.europa.eu, fu.gov.si, uppd.gov.si)
Regulatory Bodies
Future under MiCA: Will require a CASP license from a competent authority (which Slovenia will designate, likely Bank of Slovenia or ATVP) for operating an exchange platform.
Competent Authority: The Financial Administration of the Republic of Slovenia (FURS) (Finančna uprava Republike Slovenije) is the primary supervisory authority for AML/CTF compliance, including the registration and supervision of VASPs.
Operating Models
9/9 verdictsCan specific business models operate in Slovenia? Each card answers the operational question for one kind of operator. Curated cells reflect counsel-grade review; AI-generated cells should be confirmed before relying on them.
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AI · UnreviewedPrimary Legislation
| Law / Regulation | Year | Scope |
|---|---|---|
| Slovenian Act on Payment Services and Systems | Slovenian Act on Payment Services and Systems: Classifies cryptocurrencies as virtual currencies, not financial instruments or monetary assets. | |
| Markets in Crypto-Assets Regulation | EU MiCA (Markets in Crypto-Assets Regulation) will introduce harmonized rules for licensing, transparency, and stability once fully applicable, with ZPPDFT-2 as interim national measure. (Note: references Slovakia; EU-wide MiCA context… |
Licensing Requirements
Slovenian Legislation Portal (PIS): https://www.pisrs.si/Pis.web/pregledPredpisa?id=ZAKO5720 (Note: The official text is in Slovenian.
Key relevant articles define VASPs, their obligations, and FURS's powers.
Relevant for Payment Institution/Electronic Money Institution licensing under ZPlaS-1 (transposing PSD2).
AMLD5 (Directive (EU) 2018/843): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2018.156.01.0043.01.ENG
AMLD6 (Directive (EU) 2018/1673): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32018L1673
MiCA Regulation (Regulation (EU) 2023/1114): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114
AML/KYC Requirements
VASP Registration: Entities providing services of safeguarding private cryptographic keys on behalf of clients, or holding, storing, and transferring virtual currencies, are classified as "virtual asset service providers" (VASPs) under ZPPDFT-2.
Obligation to Register: VASPs must register with the Office for Money Laundering Prevention (UPPD). This is a registration requirement, not a full prudential licensing regime akin to banks or investment firms, but it entails strict AML/CFT compliance obligations.
Implementation of robust internal AML/CFT policies, procedures, and controls.
Risk assessment frameworks (customer, product, geographical risks).
Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) measures.
Record-keeping of transactions and customer data.
Reporting of suspicious transactions to UPPD.
Fit and proper assessment for management and beneficial owners (though not as extensive as for licensed financial institutions).
Zakon o preprečevanju pranja denarja in financiranja terorizma (ZPPDFT-2) – Prevention of Money Laundering and Terrorist Financing Act (2017, with subsequent amendments, consolidating 5AMLD and 6AMLD)
Available via the Official Gazette of the Republic of Slovenia: https://www.uradni-list.si/glasilo-uradni-list-rs/vsebina/2022-01-0171/zakon-o-preprecevanju-pranja-denarja-in-financiranja-terorizma-zppdft-2
UPPD Website: Provides guidance and lists of registered VASPs.
Currently (Pre-MiCA): ZPPDFT-2 primarily focuses on AML/CFT compliance, ensuring the identification of asset ownership and preventing illicit finance. It does not explicitly mandate insolvency-remote segregation of client crypto assets from the custodian's own assets in the same way traditional financial regulations (e.g., MiFID II for investment firms, CRD for banks) do.
While best practice for reputable custodians often involves some form of segregation to manage risk, there isn't a specific statutory requirement for pure crypto custodians under current Slovenian AML law to ensure client assets are legally and operationally separate and protected in the event of custodian insolvency.
Currently (Pre-MiCA): There are no specific statutory requirements under ZPPDFT-2 for VASPs (including custodians) to hold professional indemnity insurance or maintain a minimum level of own funds for asset protection, unlike for traditional financial institutions.
Currently (Pre-MiCA): Slovenian law does not explicitly mandate the use of cold storage for crypto assets. However, VASPs are expected to implement robust technical and organizational security measures to protect client assets from loss, theft, or unauthorized access. Good practice dictates that a significant portion of client assets should be held in cold storage. Regulators would assess the overall security framework rather than dictating specific technological solutions.
Currently (Pre-MiCA): Slovenian law (ZPPDFT-2) defines the service of safeguarding private cryptographic keys and the provider as a VASP. There isn't a separate legal definition of a "qualified custodian" that implies a higher prudential standard beyond AML compliance for pure crypto firms. Any VASP registered with UPPD and adhering to AML/CFT rules is currently considered a legitimate provider.
Authorization: CASPs offering custody services will require authorization from a national competent authority (e.g., ATVP in Slovenia). This is a much more stringent licensing process than the current AML registration.
Key Requirements (MiCA Articles 59-64, and specific for custody Articles 65-68)
Legal form: CASPs must be legal persons established in the EU.
Governance: Robust governance arrangements, internal control mechanisms, risk management procedures.
Management body: Members must be of good repute and possess sufficient knowledge, skills, and experience.
Initial capital: Requirement for minimum initial capital or professional indemnity insurance (see below).
Operational reliability: Sound administrative and accounting procedures, adequate IT systems, security protocols, business continuity plans.
Conflict of interest: Measures to prevent and manage conflicts of interest.
Complaints handling: Effective and transparent procedures.
Prudential safeguards: Specific requirements related to safeguarding client assets.
Mandatory Segregation: MiCA explicitly mandates robust client asset segregation. CASPs providing custody services must
Article 66(2): Make adequate arrangements to safeguard the ownership rights of clients over their crypto-assets and, where applicable, their rights over funds, especially in the event of the CASP's insolvency.
Article 66(3): Keep client crypto-assets separate from their own crypto-assets.
Article 66(4): Keep client funds separate from their own funds with credit institutions or central banks.
Article 66(5): Ensure client crypto-assets are held in separate addresses or accounts, clearly identifying the clients.
Professional Indemnity or Own Funds: MiCA Article 60(2) and Article 66(5) require CASPs providing custody services to maintain either
Professional indemnity insurance covering specific risks (e.g., loss of client crypto-assets, operational errors, cyber risks).
Own funds equivalent to the professional indemnity insurance coverage.
The amount will be determined based on the nature, scale, and complexity of the services, and the types of crypto-assets involved.
While MiCA does not explicitly mandate "cold storage," it requires CASPs to implement "adequate organisational arrangements to minimise the risk of loss or theft of crypto-assets" (Article 66(1)). This implicitly demands robust security measures, which for digital assets often includes the use of cold storage for a substantial portion of assets, multi-signature schemes, and strong cryptographic key management.
Under MiCA, a "qualified custodian" will effectively be an authorised Crypto-Asset Service Provider (CASP) that has received a license to provide "custody and administration of crypto-assets on behalf of third parties" from a competent national authority in an EU Member State. Such a CASP will be subject to the full prudential, organizational, and conduct of business requirements of MiCA, elevating it far beyond a simple AML registration.
Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA): This is the cornerstone legislation.
Full text available in the Official Journal of the European Union: https://eur-lex.europa.eu/eli/reg/2023/1114/oj
Relevant articles for custody: Article 3(1)(10) (definition), Articles 59-64 (authorization), Articles 65-68 (custody-specific requirements).
Implementation Dates: Rules for asset-referenced tokens (ARTs) and electronic money tokens (EMTs) apply from 30 June 2024. Rules for other crypto-assets apply from 30 December 2024.
Slovenian National Legislation (relevant prior to MiCA's full effect and for complementary aspects)
Zakon o elektronskem denarju (ZEL) - Electronic Money Act: Transposes the EU E-Money Directive (2009/110/EC). Relevant for fiat-backed stablecoins classified as e-money.
Zakon o trgu finančnih instrumentov (ZTFI) - Financial Instruments Market Act: Transposes MiFID II. Relevant if a crypto-asset were to be classified as a financial instrument.
Bank of Slovenia (Banka Slovenije): The central bank, responsible for monetary policy, financial stability, and oversight of payment systems and e-money institutions.
Agency for Securities Market (Agencija za trg vrednostnih papirjev - ATVP): The national securities regulator, responsible for the oversight of financial markets and instruments.
Electronic Money Tokens (EMTs): These are crypto-assets that purport to maintain a stable value by referencing the value of one single fiat currency (e.g., a EUR-pegged stablecoin).
Regulatory Approach: EMTs are largely treated as "electronic money" under the existing E-Money Directive, with MiCA adapting and extending these rules specifically for crypto-assets.
Asset-Referenced Tokens (ARTs): These are crypto-assets that purport to maintain a stable value by referencing any other value or right, or a combination thereof, including one or several fiat currencies, one or several commodities, or one or several crypto-assets.
Regulatory Approach: ARTs have a bespoke set of rules under MiCA, similar in stringency to those for e-money institutions or banks.
Pre-MiCA Situation: Before MiCA, the classification was ambiguous. A fiat-backed stablecoin could have been considered e-money if it met the criteria of the Slovenian ZEL. Other stablecoins would likely have been treated as "virtual assets" under AML laws, or potentially as securities under ZTFI if they met the characteristics of a transferable security or other financial instrument (e.g., offering rights to profits). MiCA aims to resolve this ambiguity for ARTs and EMTs.
Full Backing: Issuers must maintain reserves that are at all times at least equal to the nominal value of the outstanding stablecoins.
High Liquidity: Reserves must be held in assets with high liquidity and minimal market risk.
Segregation: Reserve assets must be segregated from the issuer's own assets and held in separate accounts or custody by credit institutions or other authorized entities.
Custody: For ARTs, at least 30% of the reserve assets must be deposited with credit institutions. For EMTs, funds received in exchange for e-money are to be held in a segregated account with a credit institution or invested in secure, low-risk assets.
Investment Policy: Issuers must have a clear investment policy for reserve assets, ensuring they are invested safely and prudently.
Mandatory Authorization: Issuers of ARTs and EMTs must be authorized by a competent national authority (in Slovenia, this would likely be the Bank of Slovenia for EMTs/e-money-like institutions, and potentially the ATVP for ARTs, depending on the specifics and national implementation of MiCA).
Credit Institutions: Credit institutions (banks) are exempt from requiring separate MiCA authorization if they issue stablecoins, but they must notify the competent authority.
Authorization Process: Involves submitting a comprehensive white paper, a robust business plan, governance arrangements, operational resilience measures, and demonstrating sufficient capital.
Capital Requirements: Specific minimum capital requirements apply, generally €350,000 or a percentage of the average amount of ARTs/EMTs outstanding.
Clear Redemption Right: Issuers of ARTs and EMTs must grant holders a clear and unambiguous right to redeem their stablecoins at par value (for EMTs) or at the market value of the referenced assets (for ARTs) from the issuer at any time.
Timely Redemption: Redemption must be processed promptly and without undue delay.
No Fees (for EMTs): Issuers of EMTs are generally prohibited from charging fees for redemption.
MiCA's Focus on Backed Stablecoins: MiCA's framework primarily addresses stablecoins that are backed by reserves (EMTs and ARTs).
Exclusion of Pure Algorithmic Stablecoins: Stablecoins that aim to maintain stability solely through algorithms, without substantial backing in fiat, commodities, or other liquid assets, are not explicitly covered as ARTs or EMTs under MiCA.
Implied Disapproval/Lack of Framework: This means such algorithmic stablecoins do not benefit from the specific stability-focused regulations of MiCA. They would likely fall under the general "other crypto-assets" category within MiCA, subject to white paper requirements and general market conduct rules, but not the stringent prudential and reserve rules. This effectively means MiCA does not provide a regulatory path for pure algorithmic stablecoins to operate within its defined stablecoin categories.
No National CBDC: Slovenia, as part of the Eurozone, does not have plans for a national Central Bank Digital Currency (CBDC) separate from a potential digital Euro.
Digital Euro Exploration: The European Central Bank (ECB) is actively exploring the development of a digital Euro. If and when a digital Euro is introduced, it would serve as a public, central bank-issued complement to private stablecoins and traditional cash, aiming to ensure monetary sovereignty and financial stability.
Impact on Stablecoins: A digital Euro would likely act as a strong alternative to private stablecoins, particularly EMTs, potentially reducing their appeal by offering a risk-free, central bank-backed digital currency for payments. Slovenia would adopt the digital Euro as part of its participation in the Eurozone.
Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF): This is the most established area of regulation, requiring virtual asset service providers (VASPs) to comply with stringent obligations.
Taxation: Virtual assets are subject to existing income and corporate tax laws, although a specific crypto tax framework is under discussion.
Consumer Protection and Financial Stability: Regulatory bodies issue warnings about the risks associated with virtual assets.
Future Harmonization with EU Law: The upcoming MiCA regulation will significantly expand the scope of regulation, moving Slovenia towards a comprehensive framework for crypto-assets.
Role: The primary authority for enforcing AML/CTF regulations regarding virtual assets. VASPs must register with UPPD and comply with their obligations.
Role: Regulates the capital markets. Its involvement depends on the classification of a specific crypto-asset. If a crypto-asset (e.g., certain tokens from an ICO) qualifies as a security or financial instrument under Slovenian law, ATVP's regulations apply (e.g., prospectus requirements, investment services rules).
Role: Responsible for financial stability, payment systems, and consumer protection. While not a direct regulator of crypto-assets per se, it issues warnings to the public about the risks of virtual assets and monitors their potential impact on the financial system. It also advises the government on related policies.
Role: Responsible for taxation. Oversees the reporting and payment of taxes related to crypto activities.
Date: The current consolidated version (ZPPDFT-2) was adopted in 2017 and has been amended multiple times to transpose subsequent EU AML directives, including 5AMLD (Directive (EU) 2018/843) and 6AMLD (Directive (EU) 2018/1673). The key provisions concerning virtual assets and VASPs came into effect with the transposition of 5AMLD.
Key Aspects: This act designates virtual asset service providers (VASPs) as obliged entities. It mandates VASPs to
Implement customer due diligence (KYC) procedures.
Monitor transactions for suspicious activities.
Report suspicious transactions to the UPPD.
URL (Official Gazette, Slovenian): https://www.pisrs.si/Pis.web/pregledPredpisa?id=ZAKO5803
Zakon o dohodnini (ZDoh-2) – Income Tax Act (Latest consolidated version, e.g., 2023): Governs personal income tax.
Zakon o davku na dohodke pravnih oseb (ZDDPO-2) – Corporate Income Tax Act (Latest consolidated version, e.g., 2023): Governs corporate income tax.
Individuals: Profits from crypto trading (when converted to fiat) are generally taxed as "other income" or "capital gains" if considered speculative. However, a specific framework is lacking, leading to case-by-case interpretations. There is an ongoing proposal for a specific 10% tax on crypto gains (or 25% for companies involved in crypto mining) when converted to fiat, with an exemption for gains under EUR 10,000 annually. This proposal is currently not yet law.
Companies: Income derived from crypto activities (e.g., mining, trading, services) is subject to corporate income tax.
VAT: Transactions involving traditional cryptocurrencies (like Bitcoin) are generally exempt from VAT, following EU case law.
EU Markets in Crypto-Assets Regulation (MiCA Regulation (EU) 2023/1114)
Date: Entered into force on June 29, 2023. Rules relating to asset-referenced tokens (ARTs) and e-money tokens (EMTs) will apply from 30 June 2024. Rules relating to other crypto-assets and crypto-asset service providers (CASPs) will apply from 30 December 2024.
Key Aspects: As an EU Member State, MiCA will be directly applicable in Slovenia. It introduces a comprehensive regulatory framework for
Issuers of crypto-assets (requiring whitepapers, disclosure obligations).
Crypto-asset service providers (CASPs), including exchanges, custodians, and brokers, which will require authorization/licensing to operate across the EU.
Legality: Crypto trading and the operation of crypto exchanges are legal in Slovenia.
AML/CTF: Currently, the primary regulatory requirement for crypto exchanges and other VASPs (e.g., custodians, wallet providers, providers of fiat-to-crypto/crypto-to-fiat exchange services) is compliance with the ZPPDFT-2. This means they must register with the UPPD and implement robust AML/KYC procedures.
Licensing (Pre-MiCA): There is no specific separate licensing regime for operating a crypto exchange in Slovenia beyond the AML registration with UPPD, unless the activities fall under existing financial services laws (e.g., if a crypto-asset is classified as a security, requiring an ATVP license, or if it involves traditional payment services requiring a Banka Slovenije license).
MiCA Impact: From December 2024, MiCA will introduce a harmonized licensing regime for crypto-asset service providers (CASPs) across the EU, including Slovenia. Exchanges will need to obtain authorization from their national competent authority (likely ATVP in Slovenia, in coordination with Banka Slovenije) to offer services within the EU. This will significantly professionalize and standardize the industry.
Consumer Protection: Banka Slovenije and ATVP frequently issue warnings to the public about the high risks associated with investing in crypto-assets, emphasizing volatility, lack of regulatory oversight (pre-MiCA), and potential for fraud.
National Legislation: Slovenia's primary AML/CTF law is the Zakon o preprečevanju pranja denarja in financiranja terorizma (ZPPDFT-2) (Prevention of Money Laundering and Terrorist Financing Act). This act defines virtual currencies and service providers and imposes general AML/CTF obligations.
EU Regulation (Directly Applicable): The crucial piece of legislation that specifically codifies the Travel Rule for crypto assets across the EU (including Slovenia) is
Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Regulation (EU) 2015/847. This regulation directly applies in Slovenia without the need for national transposition for its core provisions.
Initial obligations for VASPs under ZPPDFT-2 (transposing 5AMLD) have been in effect since around late 2019 / early 2020.
However, the specific and comprehensive implementation of the FATF Travel Rule for crypto assets, as defined by Regulation (EU) 2023/1113, becomes applicable much later: 30 December 2024. This is the key date for the full Travel Rule requirements for crypto assets.
Between Crypto-Asset Service Providers (CASPs): There is no de minimis threshold for transfers between CASPs. This means all transfers, regardless of amount, must be accompanied by the required information.
For transfers to or from a self-hosted wallet equal to or above €1,000, the CASP facilitating the transfer for its customer must collect and verify the identity of the customer and, where technically feasible, also verify that the self-hosted wallet is owned or controlled by that customer.
Providers of transfer services for crypto-assets
Other entities performing services for or on behalf of another natural or legal person that involves crypto-assets.
Originator Information: CASPs must obtain and hold the following information on the originator of a crypto-asset transfer
Originator's distributed ledger address (or equivalent)
Originator's crypto-asset account number (if applicable)
Originator's physical address, national identity number, or customer identification number (where issued), or date and place of birth.
Beneficiary Information: CASPs must obtain and hold the following information on the beneficiary of a crypto-asset transfer
Beneficiary's distributed ledger address (or equivalent)
Beneficiary's crypto-asset account number (if applicable)
Concurrent Transfer: This information must be transmitted by the originating CASP to the beneficiary CASP concurrently with the crypto-asset transfer, and in a secure manner.
Data Handling: CASPs must have policies and procedures in place for the collection, retention, and secure transfer of this data. This generally requires integration with Travel Rule solution providers (e.g., TRISA, TRAVEL, Sygna, VerifyVASP) or direct secure API connections between CASPs.
Administrative fines: Substantial monetary penalties can be imposed on legal entities and responsible persons within them for various violations, including failure to comply with data collection, verification, record-keeping, and reporting requirements.
Revocation of licenses/registrations: Repeated or severe non-compliance can lead to the revocation of a VASP's operating license or removal from the registry, effectively preventing them from operating in Slovenia.
Other supervisory measures: The supervisory authority (primarily the Financial Administration of the Republic of Slovenia (FURS) and potentially the Bank of Slovenia for certain financial entities) can impose other corrective measures and orders.
Travel Rule
Slovenia is an EU member state subject to EU anti-money laundering directives, but the provided source materials contain no Slovenia-specific legislation, licensing regime, or regulatory authority for cryptocurrency or digital assets Money laundering - EUR-Lex
The EU framework, including Directive (EU) 2018/843 (5AMLD), applies to all member states and addresses virtual currency exchanges and custodian wallet providers as obliged entities, but no Slovenia-specific implementation details are present in the available sources Money laundering - EUR-Lex
No evidence exists in the provided source text that any Slovenian entity has been licensed or registered for cryptocurrency activities, nor is there any mention of the Slovenian regulator responsible for such licensing EU law - EUR-Lex
The practical reality is that Slovenia must implement EU AML directives domestically, but the specific Slovenian legal instruments, license categories, and capital thresholds cannot be verified from the sources provided Money laundering: prevention through customs cooperation | EUR-Lex
Slovenia, as an EU member state, is bound by EU anti-money laundering legislation, and the key instrument is Directive (EU) 2015/849 (4AMLD), as amended by Directive (EU) 2018/843 (5AMLD), which aims to combat money laundering and terrorist financing by preventing the financial market from being misused for these purposes Money laundering - EUR-Lex
The legal basis for EU AML measures is found in the Treaty on the Functioning of the European Union (TFEU) under Title VII (approximation of laws for the internal market), which requires that rules be implemented throughout the EU to effectively prevent money laundering and the financing of terrorism Money laundering - EUR-Lex
Under Title V of the TFEU (police and judicial cooperation in criminal matters), the EU focuses on defining offences and strengthening mutual assistance between member states, including Slovenia Money laundering - EUR-Lex
EU financial crime rules, which Slovenia must implement, are based primarily on international standards adopted by the Financial Action Task Force (FATF) Money laundering - EUR-Lex
The EU commitments include the obligation that financial and certain non-financial operators must identify their clients (including beneficial owners of companies and trusts), monitor transactions, and report any suspicions of money laundering to Financial Intelligence Units Money laundering - EUR-Lex
The EU adopted an action plan in 2020 on preventing money laundering and terrorist financing, which includes measures to better enforce, supervise, and coordinate the relevant EU rules across member states including Slovenia Money laundering - EUR-Lex
Directive (EU) 2018/1673 aims to criminalise money laundering when it is intentional and with the knowledge that the property came from criminal activity, and it defines criminal offences and sanctions; member states, including Slovenia, may also criminalise money laundering where the offender suspected or ought to have known the property came from criminal activity Money laundering - EUR-Lex
The EU published a method to identify high-risk non-EU countries with deficient anti-money laundering and countering terrorist financing regimes that pose significant threats to the EU's financial system Money laundering - EUR-Lex
The Official Journal of the European Union, accessible through EUR-Lex, is the official publication for EU legal acts and contains legislation binding on Slovenia; it is published from Monday to Friday, and in urgent cases on weekends and public holidays, in the 24 official languages of the EU Access the Official Journal - EUR-Lex
As of July 2013, only the electronic edition of the Official Journal published on EUR-Lex is authentic and produces legal effects, meaning Slovenia must treat the e-OJ as the authoritative legal source Access the Official Journal - EUR-Lex
From 01 October 2023, the Official Journal is no longer a collation of acts with a table of contents; each act is published individually as an authentic Official Journal in its PDF format Access the Official Journal - EUR-Lex
No Slovenian authority with responsibility for licensing digital asset service providers, such as a securities market agency, central bank, or financial intelligence unit, is mentioned anywhere in the source text EUR-Lex — Access to European Union law — choose your language
The source material references "competent authorities" generally in the context of EU member states, noting that these may be customs authorities or "any other authorities empowered by EU countries," but does not name the Slovenian competent authority for AML purposes Money laundering: prevention through customs cooperation | EUR-Lex
The source text states that EU financial crime rules are mostly based on international standards adopted by the Financial Action Task Force, and it provides a link to the FATF website, but it does not mention Slovenia's specific FATF or Moneyval status or evaluation results Money laundering - EUR-Lex
No information is provided in the source materials regarding Moneyval evaluations, FATF mutual evaluation reports, or Slovenia's compliance ratings Money laundering - EUR-Lex
Under the EU AML framework applicable in Slovenia, financial and certain non-financial operators must identify their clients, monitor transactions, and report suspicions of money laundering to Financial Intelligence Units, but the source text does not specify which categories of crypto-asset service providers require licensing Money laundering - EUR-Lex
The source text references Directive (EU) 2018/843 (5AMLD) as amending Directive (EU) 2015/849 (4AMLD) to combat money laundering and terrorist financing, but it does not enumerate the specific categories of virtual asset service providers that fall within the scope of these directives, such as virtual currency exchanges or custodian wallet providers Money laundering - EUR-Lex
No Slovenian licensing regime, application process, or competent authority for issuing licenses to digital asset businesses is described in any of the provided sources EU law - EUR-Lex
No minimum capital requirements, whether in EUR or USD, are specified in the source materials for cryptocurrency businesses in Slovenia or at the EU level Money laundering - EUR-Lex
No application process, procedural timeline, or documentation requirements for obtaining a license to operate a cryptocurrency business in Slovenia are described in the source text EU law - EUR-Lex
At least one entity licensed in Slovenia: the source materials do not contain any reference to any entity that has been granted a cryptocurrency or digital asset license in Slovenia Access the Official Journal - EUR-Lex
The absence of any such reference in the source text means that, based solely on the provided information, there is no evidence that any Slovenian entity has obtained a license to operate a crypto business EUR-Lex — Access to European Union law — choose your language
Under the EU framework applicable in Slovenia, financial and certain non-financial operators must identify their clients, and this obligation explicitly extends to identifying beneficial owners of companies and trusts Money laundering - EUR-Lex
The identification obligations under the EU framework require that transactions can be fully traced and monitored, meaning that obliged entities in Slovenia must maintain clear visibility of transaction flows Money laundering - EUR-Lex
Under the EU framework, financial and certain non-financial operators must report any suspicions of money laundering to Financial Intelligence Units, establishing a mandatory STR regime applicable in Slovenia Money laundering - EUR-Lex
The source materials require that information obtained from cash declarations or as a result of customs controls must be recorded and processed, and this information is made available to the authorities responsible for combating money laundering or terrorist financing in the EU country of entry or exit Money laundering: prevention through customs cooperation | EUR-Lex
Professional secrecy covers all information which is by nature confidential or provided on a confidential basis, and it must not be disclosed without the express permission of the person or authority providing it, though competent authorities may be obliged by law to disclose information in connection with legal proceedings Money laundering: prevention through customs cooperation | EUR-Lex
The source materials describe a specific EU obligation under Regulation (EC) No 1889/2005: any individual entering or leaving the EU carrying cash of a value of €10,000 or more must declare that sum to the competent authorities, and the information provided must be correct and complete, otherwise the declaration is invalid Money laundering: prevention through customs cooperation | EUR-Lex
The cash declaration must contain information on the declarant (full name, date and place of birth, nationality), the owner, the amount and nature of the cash, the intended recipient, and the provenance and intended use of the cash Money laundering: prevention through customs cooperation | EUR-Lex
The definition of "cash" under this regulation covers currency (banknotes and coins) and other monetary instruments such as cheques, promissory notes, and money orders Money laundering: prevention through customs cooperation | EUR-Lex
Officials of competent authorities may check compliance with the obligation to declare by carrying out controls on individuals, including their baggage and means of transport, and all controls must comply with national legislation Money laundering: prevention through customs cooperation | EUR-Lex
In the event of failure to comply with the declaration obligation, cash may be detained by administrative decision in accordance with national legislation Money laundering: prevention through customs cooperation | EUR-Lex
Where an individual is entering or leaving the EU with sums of cash lower than €10,000 but there is evidence of illegal activities associated with the movement of cash, that information may also be recorded and processed Money laundering: prevention through customs cooperation | EUR-Lex
The source text explicitly requires that financial and non-financial operators identify beneficial owners of companies and trusts, but it does not mention any specific requirements for politically exposed persons (PEP) screening in the context of cryptocurrency businesses Money laundering - EUR-Lex
The provided source materials do not contain any specific reference to the FATF Travel Rule, Article 9 of the FATF Recommendations, the EU Transfer of Funds Regulation, or any provisions requiring the sharing of originator and beneficiary information for virtual asset transfers Money laundering - EUR-Lex
No threshold amounts for travel-rule information sharing, implementation dates, or technical standards for compliance are provided in the source text EU law - EUR-Lex
The source materials contain no descriptions of any enforcement actions taken against cryptocurrency businesses or individuals in Slovenia, including no names of sanctioned entities, penalty amounts, violation descriptions, or case outcomes Money laundering - EUR-Lex
The source text provides no information on penalties imposed by Slovenian regulators for AML violations in the digital asset sector Access the Official Journal - EUR-Lex
No Slovenian court cases, administrative proceedings, or regulatory sanctions involving cryptocurrency businesses are mentioned in any of the provided sources EU law - EUR-Lex
The source text notes that EU countries were required to introduce effective and proportionate penalties constituting a deterrent in the event of failure to comply with the cash declaration obligation by 15 June 2007, but it does not specify the penalties Slovenia has actually adopted Money laundering: prevention through customs cooperation | EUR-Lex
No tax guidance has been issued for virtual assets in any of the source materials provided; there is no mention of how crypto gains are treated in Slovenia for income tax, capital gains tax, corporate tax, or any other tax purpose EU law - EUR-Lex
No distinction between the tax treatment of hobby versus business crypto trading for Slovenian residents is addressed in the provided sources Access the Official Journal - EUR-Lex
The most significant gap is the complete absence of Slovenia-specific legal information in the provided source materials, meaning that a business cannot determine its Slovenian licensing obligations, applicable regulator, or compliance requirements from these sources EU law - EUR-Lex
The source text does not specify how Slovenia has transposed Directive (EU) 2018/843 into national law, including which Slovenian statute, article numbers, or license categories apply to virtual asset service providers Money laundering - EUR-Lex
No information is provided on whether Slovenia has implemented the EU Travel Rule provisions from the Transfer of Funds Regulation for virtual assets, and no deadline or compliance date is mentioned Money laundering: prevention through customs cooperation | EUR-Lex
A cryptocurrency business operating in Slovenia faces the risk of regulatory uncertainty because the specific Slovenian statutes, registration requirements, and supervisory expectations cannot be identified from the available sources EU law - EUR-Lex
The lack of any named Slovenian competent authority for crypto AML supervision creates a risk that a business may submit filings to the wrong entity, miss statutory deadlines, or fail to meet national requirements that are not visible in EU-level sources EUR-Lex — Access to European Union law — choose your language
Businesses face potential exposure for failing to comply with the EU cash declaration threshold of €10,000 when crossing Slovenian borders with cash, as this obligation applies to all individuals entering or leaving the EU Money laundering: prevention through customs cooperation | EUR-Lex
The requirement that obliged entities report suspicions to Financial Intelligence Units means that a Slovenian crypto business must establish a national STR reporting mechanism, but the identity, contact details, and reporting format of the Slovenian FIU are not provided in the source text Money laundering - EUR-Lex
While the EU AML directives create obligations for crypto businesses across member states, the practical enforcement environment in Slovenia cannot be assessed from the provided sources that contain no evidence of licensing activity, enforcement actions, or supervisory communications Access the Official Journal - EUR-Lex
The absence of any named licensed Slovenian crypto entity may indicate either a pre-licensing phase, a market that has not yet engaged with the formal regime, or limited publicly available information, but the sources do not allow a definitive conclusion EU law - EUR-Lex
The EU framework is evolving, as evidenced by the 2020 EU action plan on preventing money laundering and terrorist financing that includes measures to better enforce, supervise, and coordinate EU rules; a business should monitor for updates to the EU regime that will also affect Slovenia Money laundering - EUR-Lex
EUR-Lex — Access to European Union law — choose your language
Access the Official Journal - EUR-Lex
Money laundering: prevention through customs cooperation | EUR-Lex
Tax Reporting
Rationale: FURS considers that profits from the sale of virtual currencies by individuals (who are not engaged in a registered business activity) are generally not subject to personal income tax (dohodnina) as they do not fall under any defined category of taxable income (e.g., capital gains, business income, income from other activities).
Important Caveat: This exemption only applies if the activity is not considered a regular economic activity or a business. If an individual regularly and systematically trades cryptocurrencies with the intention of making a profit, FURS could reclassify this as a business activity, which would then be subject to income tax rules for self-employment. This assessment is made on a case-by-case basis, considering factors like frequency, volume, and intent.
Hobbyist/Sporadic Mining: If mining is done occasionally and does not involve significant resources or a profit-making intention, the proceeds might not be considered taxable income. However, FURS typically views any activity generating income as potentially taxable.
Professional/Regular Mining: If an individual engages in mining as a regular, profit-oriented activity (e.g., investing in significant hardware, electricity, time), FURS will likely consider this an economic activity. The individual would then be required to register as a sole proprietor (s.p.) and would be taxed on the profits as income from self-employment.
Tax Rate: Progressive personal income tax rates (dohodnina), ranging from 16% to 50%, plus social security contributions.
Income generated from these activities (e.g., staking rewards, interest from lending, fees from liquidity provision) is generally treated as "other income" (drugi dohodki) once it is converted into fiat currency or used to acquire goods/services.
Tax Rate: Subject to progressive personal income tax rates (dohodnina) and social contributions if it meets certain thresholds or criteria for "other income."
If an individual receives a salary or payment for services in cryptocurrency, this is treated the same as income received in fiat currency. It is subject to personal income tax (dohodnina) and social security contributions.
The value of the crypto is determined at its fair market value at the time of receipt.
NFTs: Sales of NFTs by individuals are generally treated under the same principles. If it's a sporadic sale of a personal item, it might not be taxed. If it's part of an artistic or business activity, it would be taxed as income from that activity.
Businesses holding or transacting in cryptocurrencies are subject to corporate income tax on any profits derived from these activities.
Tax Rate: The standard corporate income tax rate in Slovenia is 19%.
Accounting Treatment: Cryptocurrencies are treated as assets on the company's balance sheet. Profits or losses from their sale, exchange, or use in business operations are included in the company's taxable profit.
Mining/Trading as a Business: If a company's core business involves crypto mining, trading, or providing crypto-related services, all profits from these activities are subject to corporate income tax.
Exchange of traditional currency for cryptocurrency and vice-versa (and crypto for crypto) is generally EXEMPT from VAT. This is because virtual currencies are treated as equivalent to traditional currencies in that they are a means of payment and are thus analogous to financial services involving "currency, bank notes and coins used as legal tender."
Goods and Services Paid With Crypto: When cryptocurrencies are used to purchase goods or services, the underlying transaction for the goods or services is subject to VAT if it would normally be subject to VAT if paid with fiat currency. The crypto merely acts as a means of payment.
Mining: The VAT treatment of mining can be complex. If a miner provides "mining services" to a third party (e.g., a mining pool operator) for a fee, this could potentially be considered a VAT-taxable service. However, if the miner simply adds blocks to the blockchain and receives newly minted coins as a reward, FURS guidance has often implied this is not a service in the traditional VAT sense.
Initial Coin Offerings (ICOs)/Token Sales: The VAT treatment depends on whether the token grants rights to goods/services (potentially subject to VAT) or is purely speculative/investment (potentially exempt).
Annual Income Tax Return (Dohodeknina napoved): If an individual generates taxable income from crypto activities (e.g., professional mining income, staking rewards, salary in crypto), this income must be declared in their annual personal income tax return.
Declaration of Accounts Held Abroad: This is a crucial requirement. Individuals must report to FURS any foreign bank accounts, payment accounts, or financial accounts (including accounts on foreign cryptocurrency exchanges) if the balance exceeds a certain threshold (often EUR 10,000 equivalent at any point during the year). This is done via the form "Poročilo o stanju sredstev na računih v tujini" (Report on the status of funds in accounts abroad).
Purpose: This requirement is for general tax oversight and anti-money laundering purposes, not specifically for taxing crypto gains. However, FURS can use this information to identify potential undeclared income from crypto.
No Specific Capital Gains Reporting: Given that capital gains from crypto are generally not taxed for individuals, there is no specific form for reporting such gains.
Corporate Income Tax Return (Obrazec DDPO): All crypto-related transactions, profits, and losses must be accurately recorded in the company's accounting books and declared in the annual corporate income tax return.
Financial Statements: Crypto holdings must be properly accounted for in the company's balance sheet and income statement according to Slovenian accounting standards.
VAT Returns (Obrazec DDV): Businesses engaged in VAT-taxable crypto-related activities must report these in their regular VAT returns.
Zakon o dohodnini (ZDoh-2): Personal Income Tax Act
Zakon o davku na dobiček pravnih oseb (ZDDPO-2): Corporate Income Tax Act
Zakon o davku na dodano vrednost (ZDDV-1): Value Added Tax Act
Zakon o davčnem postopku (ZDavP-2): Tax Procedure Act (governs reporting, audits, etc.)
FURS Interpretations and Guidance: FURS has issued several opinions, clarifications, and frequently asked questions (FAQs) over the years to guide taxpayers on how existing laws apply to virtual assets. These interpretations serve as the primary source of crypto-specific tax guidance in Slovenia. They reflect FURS's official position on various scenarios.
FURS Guidance on Virtual Currencies (Davčna obravnava virtualnih valut)
FURS has a dedicated section or document explaining its stance on virtual currencies. While specific URLs can change, the general page about "virtualne valute" or "kriptovalute" is the most relevant.
A common type of document is a "pojasnilo" (explanation) or "mnenje" (opinion).
A historical but foundational FURS explanation (search FURS site for the latest version): https://www.fu.gov.si/davki_in_druge_dajatve/podrocja/davki/dohodnina/pojasnila_dohodnina/virtualne_valute/
(Note: This specific URL links to older guidance. Always use the search function on fu.gov.si for the most up-to-date information, e.g., by searching for "kriptovalute" or "virtualne valute".)
Custody Requirements
Custody regulation data collection in progress.
Stablecoin Regulation
Stablecoin regulation data collection in progress.
Securities Classification
Slovenia permits cryptocurrency and digital asset activities as legal undertakings, though specific national implementing legislation for MiCA had not been published in the Official Journal of the European Union as of the source material, meaning the EU-level framework directly governs digital asset securities matters. EUR-Lex - Official Journal of the European Union
Authorisation to operate as an investment firm, including for crypto-asset securities services, is granted under Directive 2014/65/EU (MiFID 2), which Slovenia has transposed into its national legal order. Prudential supervision of investment firms | EUR-Lex
The prudential supervision regime for investment firms operating in Slovenia is governed by Directive (EU) 2019/2034 and Regulation (EU) 2019/2033, which are directly applicable obligations supplemented by Slovenian transposition measures. Prudential supervision of investment firms | EUR-Lex
No Slovenian-specific licensing decisions for crypto-asset service providers were identifiable from the source text; the practical reality is that entities must look to EU-level frameworks and ATVP guidance for authorisation matters until national MiCA implementation is published in the Official Journal. EUR-Lex — Access to European Union law — choose your language
Slovenia is an EU Member State whose legal order is bound by EU regulations and directives; EU secondary law, including regulations on digital asset securities, is published in the Official Journal of the European Union and is accessible via EUR-Lex. Access the Official Journal - EUR-Lex
The Official Journal of the European Union is the official gazette for EU legal acts, and since July 2013 only the electronic edition published on EUR-Lex is authentic and produces legal effects — this is the authoritative source for EU securities legislation applicable in Slovenia. Access the Official Journal - EUR-Lex
The legal basis for publication of EU legal acts, which bind Slovenia, is set out in Article 191 of the Treaty establishing the European Economic Community and Council Regulation (EU) No 216/2013 of 7 March 2013 on the electronic publication of the Official Journal of the European Union. Access the Official Journal - EUR-Lex
The Official Journal comprises two series: L (Legislation) containing regulations, directives, decisions and international agreements, and C (Information and Notices) containing preparatory acts and announcements — digital asset securities rules applicable to Slovenia appear in the L series. Access the Official Journal - EUR-Lex
The Securities Market Agency (ATVP) is the relevant national authority in Slovenia responsible for supervising investment firms, exercising the supervisory and investigatory powers conferred under Directive (EU) 2019/2034. Prudential supervision of investment firms | EUR-Lex
Directive (EU) 2019/2034 of 27 November 2019 on the prudential supervision of investment firms, published in OJ L 314 of 5 December 2019 (pp. 64–114), is the primary EU legal instrument governing prudential supervision of investment firms operating in Slovenia. Prudential supervision of investment firms | EUR-Lex
Slovenia's securities market framework is built on Directive 2014/65/EU (MiFID 2), which provides the legal framework for securities markets, investment intermediaries and trading venues, and under which investment firms are authorised and supervised. Prudential supervision of investment firms | EUR-Lex
Directive (EU) 2019/2034 applies to investment firms authorised under MiFID 2 and requires that national authorities supervise investment firms operating in Slovenia, including those dealing in crypto-asset securities. Prudential supervision of investment firms | EUR-Lex
The directive does not apply entirely to investment firms whose consolidated assets equal or exceed €15 billion; these class 1 firms are supervised under Titles VII and VIII of Directive 2013/36/EU instead of Titles IV and V of the investment firms directive. Prudential supervision of investment firms | EUR-Lex
The European Banking Authority (EBA) draws up draft regulatory technical standards in consultation with the European Securities and Markets Authority (ESMA) and reports to the European Parliament and Council on convergence under the review process, meaning Slovenia's regulators participate in EU-wide supervisory convergence for investment firms. Prudential supervision of investment firms | EUR-Lex
Amending Directive (EU) 2023/2864 inserts an article in Directive (EU) 2019/2034 requiring that from 10 January 2030, Member States ensure investment firms submit regulated information to the collection body and notify ESMA for the purposes of the European single access point established under Regulation (EU) 2023/2859. Prudential supervision of investment firms | EUR-Lex
The European Commission has the power to adopt delegated acts for 5 years from 25 December 2019, and has adopted several delegated regulations supplementing Directive (EU) 2019/2034, including Delegated Regulations (EU) 2021/2153, 2021/2154, 2021/2155, 2022/2579, 2023/1117, 2023/1118, 2023/1651 and 2023/1668. Prudential supervision of investment firms | EUR-Lex
Slovenia, as an EU Member State, participates in the European System of Financial Supervision and the European Systemic Risk Board, and national authorities must cooperate closely with these bodies on investment firm supervision. Prudential supervision of investment firms | EUR-Lex
Slovenian authorities may conclude cooperation agreements with non-EU-country supervisors, facilitating cross-border oversight of investment firms and digital asset securities activities. Prudential supervision of investment firms | EUR-Lex
EU law is accessible through EUR-Lex, which contains the electronic version of all Official Journals going back to 30 December 1952, when the first Official Journal of the European Coal and Steel Community was published. Access the Official Journal - EUR-Lex
The Official Journal is published from Monday to Friday, and in urgent cases on weekends and public holidays, in the official languages of the EU at the time of publication, numbering 24 languages. Access the Official Journal - EUR-Lex
From 1 October 2023, the Official Journal is no longer a collation of acts with a table of contents; each act is published individually as an authentic Official Journal in its PDF format. Access the Official Journal - EUR-Lex
The relevant Slovenian legislation must be transposed from EU directives; Directive (EU) 2019/2034 had to be transposed into national law by 26 June 2021, with rules applying from that date except for client-initiated services rules which applied since 26 March 2020. Prudential supervision of investment firms | EUR-Lex
Regulatory technical standards under the delegated acts adopted by the European Commission include specifications on criteria for subjecting investment firms to Regulation (EU) No 575/2013 requirements, staff identification criteria, classes of instruments for variable payments, authorisation application information, and information exchange between home and host Member State authorities. Prudential supervision of investment firms | EUR-Lex
The Directive also includes Delegated Regulation (EU) 2023/1651 on technical standards for specific liquidity measurement of investment firms under Article 42(6), and Delegated Regulation (EU) 2023/1668 on technical standards specifying measurement of risks not covered by own funds requirements under Regulation (EU) 2019/2033. Prudential supervision of investment firms | EUR-Lex
The European Commission is tasked by the directive's review clause to prepare, in close cooperation with EBA and ESMA, a report on various aspects of the directive for the European Parliament and the Council. Prudential supervision of investment firms | EUR-Lex
EU legislation summaries, including that for prudential supervision of investment firms, are available on EUR-Lex and provide a comprehensive overview of the rules applicable to Slovenia as an EU Member State. Prudential supervision of investment firms | EUR-Lex
EUR-Lex serves as the official access point for EU law and contains the electronic version of all Official Journals, making it the authoritative resource for determining the legal framework applicable in Slovenia. EU law - EUR-Lex
Investment firms in Slovenia, including those dealing in digital asset securities, must obtain authorisation under Directive 2014/65/EU (MiFID 2), which provides the legal framework for securities markets, investment intermediaries and trading venues. Prudential supervision of investment firms | EUR-Lex
The authorisation process requires that Directive (EU) 2019/2034 rules on prudential supervision apply to investment firms authorised and supervised under MiFID 2, setting out initial capital requirements. Prudential supervision of investment firms | EUR-Lex
Capital requirements for investment firms are set out by Regulation (EU) 2019/2033, and the investment firms directive grants relevant national authorities in Slovenia the right to add to these requirements. Prudential supervision of investment firms | EUR-Lex
The relevant national authority in Slovenia is the Securities Market Agency (ATVP), which supervises the activities of investment firms and, where applicable, of investment holding companies and mixed financial holding companies. Prudential supervision of investment firms | EUR-Lex
The ATVP has all necessary information-gathering and investigatory powers, including the ability to carry out on-the-spot checks, to verify compliance with licensing obligations. Prudential supervision of investment firms | EUR-Lex
Investment firms must record all their transactions and document their systems and processes subject to the directive and Regulation (EU) 2019/2033, allowing for effective supervision by relevant authorities. Prudential supervision of investment firms | EUR-Lex
The relevant authority may intervene in the activity of investment firms in an effective and proportionate way by increasing the amount of own funds they must have, for instance, in order to be appropriate to their risk profile. Prudential supervision of investment firms | EUR-Lex
The relevant authority must make publicly available information including the applicable legislation, criteria and methodologies they use for supervision and statistical data they have collected. Prudential supervision of investment firms | EUR-Lex
An undertaking must provide information in its application for authorisation in accordance with Article 8a of Directive 2013/36/EU, as specified in Commission Delegated Regulation (EU) 2022/2579. Prudential supervision of investment firms | EUR-Lex
Competent authorities of home and host Member States must exchange information under conditions specified in Commission Delegated Regulation (EU) 2023/1117, and colleges of supervisors exercise their tasks under conditions in Commission Delegated Regulation (EU) 2023/1118. Prudential supervision of investment firms | EUR-Lex
The specific liquidity measurement of investment firms is governed by technical standards in Commission Delegated Regulation (EU) 2023/1651 under Article 42(6) of the directive. Prudential supervision of investment firms | EUR-Lex
Risks not covered or not sufficiently covered by the own funds requirements set out in Regulation (EU) 2019/2033 are measured according to technical standards in Commission Delegated Regulation (EU) 2023/1668, with indicative qualitative metrics for the amounts of additional own funds. Prudential supervision of investment firms | EUR-Lex
No monetary thresholds specific to Slovenia for licensing of crypto-asset service providers could be identified in the source text beyond the €15 billion consolidated assets threshold for class 1 investment firms. Prudential supervision of investment firms | EUR-Lex
The directive requires that relevant authorities have the necessary expertise, resources, operational capacity, powers and independence to do their work, ensuring adequate supervision of licensed entities. Prudential supervision of investment firms | EUR-Lex
Relevant authorities in Slovenia must receive all the information they require from investment firms, forming the basis for ongoing supervision after authorisation. Prudential supervision of investment firms | EUR-Lex
The EBA assesses information from relevant authorities on their review and evaluation processes in order to develop consistency across the EU, meaning Slovenian licensing and supervision practices are benchmarked at EU level. Prudential supervision of investment firms | EUR-Lex
Investment firms in Slovenia providing services on the client's initiative have been subject to rules applying since 26 March 2020. Prudential supervision of investment firms | EUR-Lex
Investment firms must implement adequate internal control mechanisms, including sound administration and accounting procedures, supporting KYC and customer due diligence requirements. Prudential supervision of investment firms | EUR-Lex
Investment firms must apply appropriate internal procedures that enable employees to report any breaches of the directive, its transposition under national law, or Regulation (EU) 2019/2033 — this whistleblowing mechanism is relevant to AML/CTF compliance processes. Prudential supervision of investment firms | EUR-Lex
Investment firms in Slovenia must record all their transactions and document their systems and processes, which includes maintaining records for AML/CTF compliance purposes. Prudential supervision of investment firms | EUR-Lex
The relevant authority in Slovenia must cooperate closely with other public authorities or bodies supervising credit institutions and financial institutions within the EU Member State, which facilitates AML/CTF information sharing and oversight. Prudential supervision of investment firms | EUR-Lex
National authorities in Slovenia must exchange information, particularly on potential problems and risks, and collaborate with counterparts in other Member States, supporting cross-border AML investigations. Prudential supervision of investment firms | EUR-Lex
The relevant authority must have all necessary information-gathering and investigatory powers, including the ability to carry out on-the-spot checks, which enables verification of AML/KYC compliance. Prudential supervision of investment firms | EUR-Lex
Under the directive, administrative sanctions apply to breaches including failure to report correct information to the relevant authorities, which extends to AML reporting obligations. Prudential supervision of investment firms | EUR-Lex
The directive provides that administrative sanctions and other administrative measures apply to breaches of the directive, its national transposition and Regulation (EU) 2019/2033, such as failure to report the correct information to the relevant authorities. Prudential supervision of investment firms | EUR-Lex
Administrative sanctions imposed in Slovenia must be effective, proportionate and dissuasive, and take into account all relevant circumstances such as the seriousness and duration of the breach. Prudential supervision of investment firms | EUR-Lex
Fines for firms can be up to 10 percent of a firm's total annual net turnover or twice the amount of profits gained or losses avoided due to the breach. Prudential supervision of investment firms | EUR-Lex
Fines for individuals can be up to €5 million (approximately $5.9 million USD based on the EUR/USD exchange rate). Prudential supervision of investment firms | EUR-Lex
When administrative sanctions are applied, they must be published on the relevant authority's website, with details of the breach and the perpetrator, and reported to the European Banking Authority. Prudential supervision of investment firms | EUR-Lex
Investment firms that do not comply with the directive and Regulation (EU) 2019/2033, or that are likely to breach national provisions, may be required to take necessary measures at an early stage as determined by the relevant authority. Prudential supervision of investment firms | EUR-Lex
Investment firms that benefit from special public financial support may not make any variable payments to members of the management body — a restriction subject to enforcement. Prudential supervision of investment firms | EUR-Lex
The EUR-Lex portal provides access to EU legal acts which may include tax-related directives applicable to Slovenia, but no specific tax guidance for virtual assets appears in the provided source material. EUR-Lex — Access to European Union law — choose your language
No tax guidance has been issued for virtual assets in the source text provided; the EUR-Lex sources focus on prudential supervision and regulatory frameworks rather than taxation matters. Prudential supervision of investment firms | EUR-Lex
No licensing entities for crypto-asset service providers in Slovenia could be identified from the source text, creating practical uncertainty for businesses regarding the authorisation process at national level. Prudential supervision of investment firms | EUR-Lex
There is a gap between the EU-level regulatory framework described in the source text and specific Slovenian national implementation measures for the crypto-asset sector that were not identifiable from the provided materials. EUR-Lex — Access to European Union law — choose your language
The prudential supervision regime applies to investment firms but the classification of various crypto-assets as securities, financial instruments, or other categories under MiFID 2 is not addressed in the source text, creating legal classification risks. Prudential supervision of investment firms | EUR-Lex
Investment firms operating in Slovenia face the risk of fines up to 10 percent of total annual net turnover or twice the amount of profits gained for breaches, which is a significant financial risk for non-compliance in the digital asset securities space. Prudential supervision of investment firms | EUR-Lex
Individuals face fines up to €5 million for breaches of the directive or regulation, creating personal liability risks for management and compliance officers in crypto-asset firms. Prudential supervision of investment firms | EUR-Lex
The publication requirement for administrative sanctions on the relevant authority's website (ATVP) creates reputational risk for entities sanctioned for breaches. Prudential supervision of investment firms | EUR-Lex
Since the source text contains no national tax guidance for virtual assets in Slovenia, businesses face uncertainty regarding their tax obligations for digital asset securities transactions. EUR-Lex - Official Journal of the European Union
The absence of specific Slovenian licensing decisions or granted authorisations for crypto-asset service providers in the source text suggests that market entry clarity may be limited, though the ATVP must exercise its supervisory powers under the EU framework. Prudential supervision of investment firms | EUR-Lex
The review clause in the directive tasks the Commission to prepare reports on the directive's various aspects, meaning the regulatory framework applicable in Slovenia for investment firms and potentially digital asset securities is subject to ongoing evaluation and potential change. Prudential supervision of investment firms | EUR-Lex
The delegated acts adopted by the Commission (specifically Delegated Regulations 2021/2153, 2021/2154, 2021/2155, 2022/2579, 2023/1117, 2023/1118, 2023/1651 and 2023/1668) add technical complexity for compliance, and the source text does not indicate whether Slovenia has issued supplementary national guidance. Prudential supervision of investment firms | EUR-Lex
Businesses operating in Slovenia must monitor regulatory changes from 10 January 2030 when the requirement to submit regulated information to the collection body and notify ESMA for the European single access point takes effect. Prudential supervision of investment firms | EUR-Lex
EUR-Lex - Official Journal of the European Union
Opinion on markets in financial instruments (CON/2018/3)
Prudential supervision of investment firms | EUR-Lex
EUR-Lex — Access to European Union law — choose your language
Access the Official Journal - EUR-Lex
Sanctions & Restrictions
Asset freezes: Prohibiting the making available of funds or economic resources, directly or indirectly, to designated persons, entities, or bodies. This explicitly includes virtual assets.
Travel bans: For designated individuals.
Sectoral restrictions: E.g., on specific industries, financial services, dual-use goods, or technology transfers.
Sanctioned Entity Screening: VASPs must conduct robust and ongoing screening of their customers (including beneficial owners), counterparties, and transactions against the EU Consolidated Sanctions List. This screening must occur at onboarding, during ongoing monitoring, and prior to processing transactions.
Prohibition on Making Funds Available: VASPs are prohibited from facilitating any transactions that would directly or indirectly make funds (including virtual assets) or economic resources available to sanctioned individuals or entities.
Reporting Obligations: In case of a hit or suspicion of a sanctions violation, VASPs are generally required to freeze the relevant assets and report the incident immediately to the Slovenian Office for Money Laundering Prevention (UPPD) and potentially other relevant authorities.
Internal Controls: VASPs must establish and maintain appropriate internal policies, controls, and procedures for sanctions compliance, integrated with their broader Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) framework.
Definition of Funds/Economic Resources: The relevant EU regulations define "funds" and "economic resources" broadly, encompassing all forms of assets. With the implementation of the 5th and 6th Anti-Money Laundering Directives (AMLD5/6), virtual assets are unequivocally covered by AML/CFT obligations, and by extension, financial sanctions.
EU Consolidated Sanctions List: The most up-to-date list of all individuals, groups, and entities subject to EU financial sanctions.
EUR-Lex: Consolidated list of persons, groups and entities subject to EU financial sanctions (This link points to the latest consolidated version, which is updated frequently).
Council Regulation (EU) No 269/2014: Concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. This regulation explicitly covers "funds" and "economic resources."
EUR-Lex: Council Regulation (EU) No 269/2014
Council Regulation (EC) No 2580/2001: On specific restrictive measures directed against certain persons and entities with a view to combating terrorism. This is another foundational regulation for asset freezes.
EUR-Lex: Council Regulation (EC) No 2580/2001
VASP Compliance: The same obligations as for EU sanctions apply. VASPs must screen against the UN Sanctions List (which is integrated into the EU Consolidated Sanctions List) and report any matches or suspicions.
UN Sanctions Committees: Provides consolidated lists for various regimes (e.g., ISIL (Da'esh) and Al-Qaida, Taliban, DPRK, Iran).
United Nations Security Council Sanctions Committees
The specific EU regulations implementing UN sanctions vary by regime (e.g., DPRK, Iran, terrorism lists).
US Nexus: If a Slovenian VASP uses US-based blockchain analytics tools, USD stablecoins, interacts with US financial institutions, or has US customers/employees, it can fall under OFAC's jurisdiction.
Secondary Sanctions: Certain OFAC programs impose "secondary sanctions" on non-US persons for engaging in specific transactions with sanctioned entities, even without a direct US nexus. This is particularly relevant for entities dealing with countries like Iran or North Korea.
Global Best Practice: Given the global nature of cryptocurrencies, many international VASPs choose to comply with OFAC sanctions as a best practice to avoid potential penalties, reputational damage, or loss of access to global financial infrastructure.
VASP Compliance: Global VASPs typically screen against OFAC's Specially Designated Nationals (SDN) and Blocked Persons List, as well as other relevant OFAC lists (e.g., sectoral sanctions identifications list).
OFAC Website: Provides comprehensive information on sanctions programs and lists.
SDN List: The primary list for designated individuals and entities.
OFAC Guidance on Virtual Currency: Provides insights into OFAC's expectations for virtual currency businesses.
Key National Law: The primary legislation is the Zakon o preprečevanju pranja denarja in financiranja terorizma (ZPPDFT-1) – Act on the Prevention of Money Laundering and Terrorist Financing. This act incorporates the requirements of EU AML Directives and establishes the framework for implementing financial sanctions.
Obligations for VASPs: Article 4 of ZPPDFT-1 explicitly lists "providers of services for the exchange between virtual currencies and fiat currencies" and "providers of custodial wallet services" as obliged entities, subject to full AML/CFT requirements, including customer due diligence (CDD), beneficial ownership identification, ongoing monitoring, transaction monitoring, and, crucially, sanctions screening.
Reporting Authority: The main supervisory and reporting authority in Slovenia for AML/CFT and financial sanctions is the Urad RS za preprečevanje pranja denarja (UPPD) – Office for Money Laundering Prevention.
Urad RS za preprečevanje pranja denarja (UPPD)
Country-Specific Sanctions Lists: Slovenia does not maintain a separate national sanctions list for financial sanctions distinct from the EU/UN lists. Its obligations are to directly enforce the EU Regulations which incorporate UN and autonomous EU measures. Therefore, VASPs in Slovenia primarily need to screen against the EU Consolidated Sanctions List.
Geographic Restrictions: These are directly derived from the targets of UN and EU sanctions regimes. VASPs must restrict transactions involving sanctioned countries, territories (e.g., Crimea), or regions, as well as any individuals or entities located within or operating from these areas, if they are subject to sanctions. Examples include prohibitions related to Russia, Belarus, North Korea, Iran, Syria, etc.
Zakon o preprečevanju pranja denarja in financiranja terorizma (ZPPDFT-1): (Act on the Prevention of Money Laundering and Terrorist Financing - consolidated official text).
Pravno-informacijski sistem Republike Slovenije (Legal Information System of the Republic of Slovenia) (This links to an interpretation, but the official law can be found via a search on pisrs.si for "ZPPDFT-1").
Legal Persons (VASPs/Companies): ZPPDFT-1 (Articles 140-143) prescribes substantial administrative fines for legal persons that fail to comply with their obligations, including sanctions screening and reporting. These can range from €10,000 to €200,000, with higher amounts for repeat offenses or particularly serious breaches.
Responsible Persons (Management/Directors): Individuals responsible for the violations within the VASP can also face fines ranging from €1,000 to €40,000.
Reputational Damage: Beyond financial penalties, violations can lead to severe reputational damage, loss of trust, and potential revocation of licenses or operating permits.
Criminal Penalties: In cases of severe and intentional breaches, especially those related to terrorist financing or proliferation, criminal charges could be pursued under Slovenian criminal law, which carries penalties including imprisonment.
Robust Screening: Continuously screening all customers, beneficial owners, and transactions against the EU Consolidated Sanctions List (which integrates UN lists).
Prohibition: Preventing any funds (including virtual assets) or economic resources from being made available to sanctioned individuals or entities.
Reporting: Immediately reporting any sanctions hits or suspicious activities to the Slovenian UPPD.
Internal Controls: Implementing comprehensive internal sanctions compliance policies, procedures, and training as part of their broader AML/CFT framework.
OFAC Consideration: For global VASPs, or those with any US nexus, adherence to OFAC sanctions remains a critical best practice to mitigate broader international risks.
Enforcement Actions
Issuing warnings and guidance: Educating the public about risks and informing businesses about compliance requirements, especially in anticipation of EU-wide regulations like MiCA (Markets in Crypto-Assets).
Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) supervision: The Office for Money Laundering Prevention (UPPD - Urad RS za preprečevanje pranja denarja) is the primary authority here. While they conduct supervision and impose measures, details of individual enforcement actions against specific companies (with fine amounts and outcomes) are not usually made public in the same way as in some other jurisdictions.
Criminal investigations: Police and the State Prosecutor's Office handle cases of fraud, scams, or money laundering involving cryptocurrencies, but these often target individuals or criminal groups, and details about convictions and penalties might emerge later in the legal process.
Regulator: Bank of Slovenia (Banka Slovenije), Securities Market Agency (Agencija za trg vrednostnih papirjev - ATVP), Office for Money Laundering Prevention (Urad RS za preprečevanje pranja denarja - UPPD).
Entity Targeted: The general public and virtual asset service providers (VASPs). Violation Type: Warnings against unregulated crypto assets, scam projects, risks of investing in virtual assets, and emphasis on AML/CFT compliance. While not "enforcement actions" in the sense of fines, these communications serve to guide behavior and deter non-compliant activities. Penalty Amount: N/A (warnings, not fines). Outcome: Increased public awareness and regulatory guidance.
Source: Bank of Slovenia often publishes warnings on its official website
Bank of Slovenia - Warnings (English section may be less comprehensive than Slovene)
Example warning from 2021 about virtual currencies (relevant to the period): Bank of Slovenia - Virtual currencies and investor protection (Slovenian)
Source: ATVP issues warnings regarding unregistered entities or potentially fraudulent schemes.
Regulator: Office for Money Laundering Prevention (UPPD)
Entity Targeted: Virtual Asset Service Providers (VASPs) operating in Slovenia. Violation Type: Non-compliance with AML/CFT obligations (e.g., inadequate customer due diligence, suspicious transaction reporting failures, internal control deficiencies). Penalty Amount: Details are not typically made public for individual administrative measures, but can range from warnings to fines.
Outcome: Improved compliance within the sector. The UPPD regularly publishes annual reports detailing their activities, including the number of suspicious transaction reports related to virtual currencies and general supervision efforts, but without identifying specific companies subject to enforcement.
Source: UPPD Annual Reports (available in Slovenian, with English summaries sometimes)
Research & Articles
Regulatory Forecast
high confidenceLikely enforcement action expected around 2026-05-20
Based on 38 historical regulatory events for Slovenia, averaging every 28 days, with increasing regulatory activity.
Recent Updates
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Rationale: FURS considers that profits from the sale of virtual currencies by individuals (who are not engaged in a registered business activity) are generally not subject to personal income tax (dohodnina) as they do not fall under any defined category of taxable income (e.g., capital gains, business income, income from other activities).
Exchange of traditional currency for cryptocurrency and vice-versa (and crypto for crypto) is generally EXEMPT from...
Exchange of traditional currency for cryptocurrency and vice-versa (and crypto for crypto) is generally EXEMPT from VAT. This is because virtual currencies are treated as equivalent to traditional currencies in that they are a means of payment and are thus analogous to financial services involving "currency, bank notes and coins used as legal tender."
Declaration of Accounts Held Abroad: This is a crucial requirement. Individuals must report to FURS any foreign b...
Declaration of Accounts Held Abroad: This is a crucial requirement. Individuals must report to FURS any foreign bank accounts, payment accounts, or financial accounts (including accounts on foreign cryptocurrency exchanges) if the balance exceeds a certain threshold (often EUR 10,000 equivalent at any point during the year). This is done via the form "Poročilo o stanju sredstev na računih v tujini" (Report on the status of funds in accounts abroad).
FURS Interpretations and Guidance: FURS has issued several opinions, clarifications, and frequently asked questio...
FURS Interpretations and Guidance: FURS has issued several opinions, clarifications, and frequently asked questions (FAQs) over the years to guide taxpayers on how existing laws apply to virtual assets. These interpretations serve as the primary source of crypto-specific tax guidance in Slovenia. They reflect FURS's official position on various scenarios.
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