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AML and KYC for Crypto Businesses

AML and KYC for Crypto Businesses in practice

Under Slovak anti-money laundering law, a crypto exchange, broker or custodian is an obliged entity just like a bank. Act No. 297/2008 Coll. requires it to know its clients, identify beneficial owners, assess risk and monitor transactions. The Travel Rule adds a duty to pass on details of the sender and recipient with every transfer. These rules have to be turned into procedures your team can actually follow day to day.

We draft the internal AML programme so that it fits your business model and client base. We set up KYC forms for individuals and companies, with procedures for simplified, standard and enhanced due diligence. We train your compliance officer and support them when a decision on reporting an unusual transaction has to be made. The AML package is also a mandatory part of a MiCA licence application.

What we help with

  • Internal AML programme under Slovak Act No. 297/2008 Coll.
  • KYC forms and procedures for simplified, standard and enhanced due diligence
  • Procedures for identifying beneficial owners
  • Travel Rule implementation, including choice of protocol
  • Transaction monitoring rules and thresholds
  • Training for the compliance officer and template reports to the FIU
  • Support with a specific unusual transaction report

Worth knowing

Beneficial owner

Under Section 6a of Act No. 297/2008 Coll., this is mainly an individual who directly or indirectly holds more than 25% of shares or voting rights, or otherwise controls the company.

Travel Rule

Regulation (EU) 2023/1113 requires crypto-asset service providers to collect and pass on information about the sender and recipient of a transfer. If the information is missing, the receiving provider must suspend or return the transfer.

Reporting through goAML

Since 1 June 2026 unusual transactions are reported to the Slovak Financial Intelligence Unit through the goAML system (Section 17(2) of Act No. 297/2008 Coll.). Another electronic form is allowed only if the system is down.

goAML registration

An obliged entity must register in goAML within 30 days of becoming one. Entities that were already obliged on 1 June 2026 have until 30 November 2026 (Section 21(2) and Section 36d(1)).

Common questions

  • Yes. Crypto-asset service providers under MiCA are obliged entities under Slovak Act No. 297/2008 Coll. They must identify clients, assess risk, monitor transactions and report unusual transactions to the Financial Intelligence Unit.

  • A rule under Regulation (EU) 2023/1113 requiring sender and recipient details to be collected and passed on with each crypto-asset transfer. Between two providers the data travels with the transfer; special rules apply to transfers involving self-hosted wallets.

  • An internal AML policy, a risk assessment of clients and products, a KYC procedure with forms, monitoring scenarios, an FIU reporting procedure, a staff training plan and internal controls. These are mandatory annexes to the application.

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This page is for general information, reflects Slovak law at the time of writing and is not a substitute for advice on your particular matter.