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Current regulations on restrictive measures


Regulations on restrictive measures are listed below by state and entity, with links. The lists of persons against whom sanctions were imposed under the aforementioned legal instruments may be found in these instruments. However, it should be noted that Slovenian regulations do not include such lists, but refer to the relevant EU or UN legal instruments. To ensure a better overview of financial sanctions applicable in the EU (these are sanctions introduced by the UNSC), it is recommended that you refer to the updated list of persons subject to financial sanctions compiled by the European Banking Federation. Updated UN lists are also useful with regard to sanctions introduced by the UNSC.

Restrictive measures by state


Restrictive measures by entity



Implementation of restrictive measures in the Republic of Slovenia


Under the Act Relating to Restrictive Measures Introduced or Implemented in Compliance with Legal Instruments and Decisions adopted within International Organisations (Uradni list RS, No. 127/2006, ZOUPAMO), which systemically regulates this field in the Republic of Slovenia, restrictive measures are restrictions and obligations in relations with states, territorial entities, movements, international organisations and persons, the purpose of which is to establish or preserve international peace and security; ensure respect for human rights and fundamental freedoms; develop or consolidate democracy and the rule of law; and achieve other goals in accordance with international law binding on the Republic of Slovenia and identified in legal instruments of the UN, EU and other international organisations; or restrictions and obligations introduced by the Republic of Slovenia for the above purposes in a different manner in accordance with international law and the EU law.


In the Republic of Slovenia, ZOUPAMO grants special powers to the Slovenian Government to introduce or implement sanctions. The Government does this by adopting decrees in which it makes the necessary provisions for the implementation of sanctions. All restrictive measures which are implemented in Slovenia are presently based on UNSC and EU legal instruments; they may also be introduced on the basis of instruments or decisions of other international organisations or associations (e.g. the OSCE).


In Article 3, ZOUPAMO stipulates that decrees implementing UN or EU instruments automatically cease to apply when the instruments of the two international organisations cease to apply. For greater legal certainty, a notification of the termination of such decrees’ validity shall be published in the Official Gazette of the Republic of Slovenia.  


To achieve uniform implementation of restrictive measures and coordination between relevant bodies, ZOUPAMO provides for a permanent coordination group in Article 7, headed by a representative of the Ministry of Foreign Affairs. Inter alia, the group passes, in accordance with Article 8 of ZOUPAMO, opinions to the competent ministries in processing applications of persons based on decrees (see below); pursuant to Article 3 of ZOUPAMO, it may give opinions to the Slovenian Government in adopting sanctions which are not based on Slovenia’s international obligations.


Article 8 of ZOUPAMO stipulates rules for deciding on applications filed under the sanctions’ implementing legal acts, e.g. exceptions to the freezing of funds in bank accounts due to humanitarian needs or the payment of health care services. In these cases, the relevant ministry decides on the application according to the general administrative procedure, and ZOUPAMO stipulates some specific rules aimed at accelerating the decision-makings of the competent bodies. In principle, Slovenian regulations – for each sanction regime separately – specify the competent body to decide on these applications. 


Article 10 of ZOUPAMO stipulates that supervision of the implementation of this act and regulations shall be carried out by public administration bodies, other entities under public law and bearers of public authority responsible for the domains to which the restrictive measures apply, unless otherwise specified by directly applicable EU legal acts. Bodies carry out the supervision in accordance with sector-specific legislation, while their powers may also be stipulated in the decrees in which the competent bodies are designated.


While the regulations issued on the basis of ZOUPAMO define the violations of restrictive measures and corresponding sanctions, particular violations may involve elements of criminal acts (e. g. trade in weapons) as defined in the Criminal Code.  


In addition to the above, in the implementation of restrictive measures, certain sector-specific laws need to be taken into account, such as the Defence Act and Export Control of Dual-Use Goods Act.