In accordance with the above guidelines, the NBS expects financial institutions, primarily banks, to:

• have policies for managing the ML/TF risks to which they are exposed,
• set out in the policies the distinguishing criteria between risks within the group and risks associated with individual clients belonging to the group,
• the application of risk management policies would not lead to blanket rejection of clients,
• have established criteria that they will use to determine the reasons WHY they will refuse/terminate cooperation with a client,
• consider whether they have used all other AML measures before deciding to refuse/terminate cooperation with a client,
• document each refusal to terminate a business relationship so that the NBS will be able to demonstrate such refusal or termination of a business relationship during supervision.

  As follows from the above principles, before making a decision to refuse or terminate a business relationship with a client, financial institutions should ensure that they have considered and implemented all possible mitigating measures that could be reasonably applied in the given case and communicate this decision to clients, informing them of their right to contact the National Bank of Slovakia for a review of this procedure.