Even an unused registered business activity may trigger AML obligations. What should you review before 30 November 2026?

Even an unused registered business activity may trigger AML obligations. What should you review before 30 November 2026?

Your company may have bookkeeping services listed among its registered business activities, even though it does not provide such services to anyone. Alternatively, when incorporating your company, you may have registered financial leasing or trading in receivables as potential business activities that you might wish to pursue in the future.

Such registrations often remain unchanged for years. However, under the new interpretation issued by the Slovak Financial Intelligence Unit (FSJ), they may have significant implications for your company's obligations under anti-money laundering legislation.

 

What has changed?

On 14 October 2026, the FSJ issued new guidance on the mandatory registration of obliged entities in the goAML system.

Under this guidance, the FSJ takes the position that, for certain categories of activities, a person or entity acquires the status of an obliged entity merely by obtaining the relevant authorisation, regardless of whether the activity is actually carried out.

In practice, this means that the argument “we have this activity registered, but we do not actually engage in it” may not be sufficient, in the FSJ's view, to exclude the application of AML obligations.

Importantly, this is the supervisory authority's interpretation of the existing legislation, rather than a new statutory definition of an obliged entity.

 

Which registered business activities should you review?

Particular attention should be paid to the following activities:

• Bookkeeping services – accountants fall within the scope of Section 5(1)(h) of the Slovak AML Act.
  Trading in receivables – this activity is covered by Section 5(1)(b), point 12, of the AML Act. Depending on the particular business model, this may also include factoring and forfaiting.
  Financial leasing and auctions outside enforcement proceedings – these activities fall within Section 5(1)(b), point 13, of the AML Act.
  Real estate brokerage involving the purchase and sale of property – this activity is covered by Section 5(1)(i) of the AML Act.

A specific rule applies to brokerage services relating to property rentals: the amount of the monthly rent is also relevant, with a statutory threshold of at least EUR 10,000. Consequently, not every activity connected with property rentals automatically gives rise to obliged-entity status under AML legislation.

 

What should you do before 30 November?

Start by reviewing your current extract from the Commercial Register or Trade Register. For each registered activity, consider whether it may give rise to obliged-entity status and whether you actually carry out, or intend to carry out, that activity.

If you have registered a business activity that you no longer need, consider having it removed from the relevant register.

If you qualify as an obliged entity, you should also review your existing AML procedures and registration obligations. Registration in the goAML system is only one of several requirements. Other obligations may include maintaining an internal AML compliance programme, conducting risk assessments and carrying out customer due diligence.

Entities that acquired obliged-entity status before 1 June 2026 must register in the goAML system by 30 November 2026 at the latest (Section 36d(1) of the AML Act).

Where obliged-entity status arose on or after 1 June 2026, registration must generally be completed within 30 days of acquiring that status (Section 21(2) of the AML Act).

It is important to emphasise that 30 November 2026 is not a statutory deadline for removing business activities from the relevant register.

 

When might removing a registered business activity not be the right solution?

Removing an activity from the register may not be appropriate if your company is currently engaged in that activity or genuinely intends to pursue it in the future.

Nor will removing a particular activity necessarily resolve the issue if your company qualifies as an obliged entity on another statutory basis.

Furthermore, removing a registered activity does not automatically extinguish obligations that arose in the past. Even after an activity has ceased, the FSJ may, subject to the applicable statutory requirements, review compliance with previous AML obligations (Section 29(2) of the AML Act).

The most sensible first step is therefore not to remove all potentially relevant business activities automatically, but to assess which of them actually give rise to AML obligations.

If you have any questions about how these requirements apply to your business, please feel free to contact us.