Opinion of the European Central Bank of 13 March 2006 at the request of the Slovenian Ministry of Finance on a draft law amending the Law on Banka Slovenije (CON/2006/17)
Date: 2006-03-13
Institutions: European Central Bank
Subjects: Eurosystem, Slovenia, central bank, institutional reform, monetary integration, money, national law

EN 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 13 March 2006 

at the request of the Slovenian Ministry of Finance 

on a draft law amending the Law on Banka Slovenije 

(CON/2006/17) 

Introduction and legal basis 

On 13 February 2006 the European Central Bank (ECB) received a request from the Slovenian Ministry 

of  Finance  for  an  opinion  on  a  draft  law  amending  the  Law  on  Banka  Slovenije  (hereinafter  the  ‘draft 

law’). 

The  ECB’s  competence  to  deliver  an  opinion  is  based  on  Article  105(4)  of  the  Treaty  establishing  the 

European Community and on the first, second, third and fourth indents of Article 2(1) and Article 2(2) of 

Council  Decision  98/415/EC  of  29 June  1998  on  the  consultation  of  the  European  Central  Bank  by 
national  authorities  regarding  draft  legislative  provisions1,  as  the  draft  law  relates  to  currency  matters, 

means of payment, a national central bank (NCB), the collection, compilation and distribution of statistics 

and the instruments of monetary policy. In accordance with the first sentence of Article 17.5 of the Rules 

of Procedure of the European Central Bank, the Governing Council has adopted this opinion. 

1. 

Purpose of the draft law 

The main purpose of the draft law is to bring the Law on Banka Slovenije (hereinafter the ‘Law’) 

into  line  with  the  Treaty  and  the  Statute  of  the  European  System  of  Central  Banks  and  of  the 

European Central Bank, in particular with regard to the legal integration of Banka Slovenije into 

the  Eurosystem.  The  draft  law  amends,  inter  alia,  provisions  relating  to  Banka  Slovenije’s 

independence,  economic  policy  objectives,  monetary  policy 

instruments,  foreign  reserve 

management, the issue and distribution of banknotes and coins and international cooperation, and 

introduces  the  correct  spelling  of  the  word  ‘euro’.  Moreover,  in  view  of  the  inclusion  of  bank 

credits  in  the  single  list  of  eligible  collateral  for  Eurosystem  credit  operations,  the  draft  law 

introduces a register of financial assets. Finally, it also introduces sanctions for breaches of Council 

Regulation (EC) No 2182/2004 of 6 December 2004 concerning medals and tokens similar to euro 

1  

OJ L 189, 3.7.1998, p. 42.  

 
 
 
 
 
                                                      
coins2  and  Council  Regulation  (EC)  No  2183/2004  of  6  December  2004  extending  to  the  non-

participating Member States the application of Regulation (EC) No 2182/2004 concerning medals 
and tokens similar to euro coins3. 

2.  General observations 

Terminological considerations 

2.1. 

In several parts of the draft law, the wording ‘introduction of the euro as the monetary unit of the 

Republic  of  Slovenia’  is  used.  In  order  to  be  consistent  with  the  terminology  used  in  Council 
Regulation (EC) No 974/98 of 3 May 1998 on the introduction of the euro4, the draft law should 
refer to the ‘introduction of the euro as the currency of the Republic of Slovenia’5. 

2.2.  The ECB welcomes Article 1 of the draft law, which provides that in the Law the word ‘evro’ ‘in 

all grammatical cases shall be replaced with the word “euro” in the appropriate case’. As a single 

currency,  the  name  of  the  euro  needs  to  be  identical  in  the  nominative  singular  case  in  all 

Community  languages  to  ensure  that  its  singleness  is  apparent.  The  European  Council  at  its 

meeting in Madrid on 15 and 16 December 1995 concluded that ‘the name given to the European 

currency  shall  be  Euro’  and  that  ‘the  name  of  the  single  currency  must  be  the  same  in  all  the 

official languages of the European Union, taking into account the existence of different alphabets’, 

and  these  conclusions  were  reflected  in  Regulation  (EC)  No  974/98.  The  Community,  as  the 

exclusive  holder  of  competence  in  monetary  matters,  determines  alone  the  name  of  the  single 

currency. On the basis of these legal considerations, and in view of the supremacy of Community 

law, the name of the single currency in the nominative singular case is to be consistently written in 
all national legal acts as ‘euro’6. The ECB expects that the correct spelling of the word ‘euro’ will 

be applied in all national legal acts using the name of the single currency and invites the consulting 

authority to take a proactive approach to ensure this. 

Update of the structure of the Law 

2.3.  The current structure of the Law would benefit from updating and consolidation in view of the fact 

that  Slovenia  has  been  a  member  of  the  EU  since  May  2004.  The  provisions  applying  today  to 

Banka  Slovenije  are  dispersed  in  various  parts  of  the  Law,  and  in  particular  in  Chapter  10  (on 

Slovenian EU membership), whilst the text still contains obsolete provisions. For reasons of legal 

2  
3  
4  
5  

6  

OJ L 373, 21.12.2004, p. 1. 
OJ L 373, 21.12.2004, p. 7. 
OJ L 139, 11.5.1998, p. 1. Regulation as last amended by Regulation (EC) No 2169/2005 (OJ L 346, 29.12.2005, p. 1). 
In addition to being the currency of the ‘participating Member States’. See paragraph 1.1 of ECB Opinion CON/2006/10 
of 23 February 2006 at the request of the Central Bank of Malta on a draft law on the adoption of the euro. 
See the following ECB Opinions: CON/2005/21 of 14 June 2005 at the request of Lietuvos bankas on a draft law on the 
adoption  of  the  euro;  CON/2005/51  of  1  December  2005  on  a  proposal  for  a  Council  Regulation  amending 
Regulation (EC) No 974/98 on the introduction of the euro; and CON/2005/57 of 16 December 2005 at the request of the 
Slovene Ministry of Economic Affairs on the provisions of the draft Companies Act concerning redenomination resulting 
from the introduction of the euro. 

2 

 
                                                      
clarity,  it  would  be  advisable  to  consolidate  and  update  the  Law  by  deleting  provisions  that  are 

obsolete and/or completing them with rights and obligations that came into force as a consequence 

of Slovenia’s accession to the EU. 

Banka Slovenije’s independence and integration into the Eurosystem 

2.4.  The draft law addresses most of the issues that the ECB raised in its Convergence Report 20047. 

The ECB welcomes those elements of the draft law that will contribute to achieving the required 

level of legal convergence. 

2.5.  Concerning  institutional  independence,  the  draft  law8  amends  Article  27  of  the  Law  to  expressly 

exclude the management of foreign reserves from the scope of Banka Slovenije’s contract with the 

Ministry of Finance, which will foster Banka Slovenije’s independence in this respect.  

2.6.  Concerning personal independence, the draft law9 partially aligns the wording of Article 39 of the 

Law (removal from office of Governing Board members) with Article 14.2 of the Statute. It deletes 

the third ground for dismissal, namely that the Governor has been found guilty of a criminal office 

and sentenced to imprisonment, which has no equivalent in the Statute. However, the ECB would 

welcome further amendments to this Article to bring the grounds for dismissal of the Governor of 

Banka  Slovenije  fully  into  line  with  the  wording  of  Article  14.2  of  the  Statute.  In  particular,  the 

Law  should  specify,  without  supplementary  conditions,  that  a  Governor  may  be  relieved  from 

office if they no longer fulfil the conditions required for the performance of their duties or if they 

have been guilty of serious misconduct. 

2.7.  The draft law10 also introduces a new Article 39.a into the Law exempting the members of Banka 

Slovenije’s Governing Board from those provisions of the Law on the prevention of corruption that 

relate to the sanction of early termination of the term of office. 

2.8. 

In  relation  to  the  legal  integration  of  Banka  Slovenije  into  the  Eurosystem,  the  amendment 
proposed in the draft law11 to Article 58(2) of the Law specifies which of Banka Slovenije’s tasks 

will be performed in accordance with the Treaty and the Statute from the day the euro is introduced 

in Slovenia. 

2.9.  The ECB would also advise aligning the wording of the second and third paragraphs of Article 2 of 

the  draft  law  concerning  Banka  Slovenije’s  objectives  with  the  wording  of  Article  105(1)  of  the 

Treaty. Indeed, it is without prejudice to the objective of price stability that  NCBs must support the 

general economic policies in the Community with a view to contributing to the achievement of the 

objectives of the Community as laid down in Article 2 of the Treaty. 

7  
8  
9  
10  
11  

Convergence Report 2004, pp. 232-234. 
Article 8 of the draft law. 
Ibid., Article 15. 
Ibid., Article 16. 
Ibid., Article 28. 

3 

                                                      
2.10.  Two further provisions adequately address integration into the Eurosystem: from the day the euro 

is introduced, Banka Slovenije will participate in the ECB’s sanctions regime and will only be able 
to participate in international monetary organisations after prior ECB approval12. 

3. 

Specific observations 

Collection and processing of statistical data 

3.1.  Under the new point 11 of Article 12(1) of the Law13, Banka Slovenije must also perform financial 

statistics tasks, as a minimum within the parameters required for the functioning of the European 

System  of  Central  Banks  (ESCB).  The  proposed  definition  of  this  task,  limiting  it  to  financial 

statistics,  could  be  too  narrow.  For  this  reason,  the  ECB  recommends  slightly  amending  the 

provision  to  make  it  clear  that  Banka  Slovenije  must  as  a  minimum  perform  the  statistical  tasks 

which are required for the functioning of the ESCB, but may also perform other financial statistics 

tasks. 

3.2.  The draft law14 amends Article 13 of the Law to extend Banka Slovenije’s responsibility to collect 

and manage statistical data and information. This is indeed of importance for the implementation of 

its tasks and consequently for the functioning of the ESCB, as is also specified in Article 55 of the 

Law  (concerning  Banka  Slovenije’s  information  system).  However,  the  ECB  would  recommend 

refining the existing reference to ‘statistical data and information’ in the draft law by including an 

explicit reference to Article 5 of the Statute. 

Payment and settlement systems 

3.3. 

In its assessment carried out in 2003 concerning securities settlement systems (SSSs) of accession 
countries15, the ECB noted that Banka Slovenije’s oversight role in relation to the foreign exchange 

bills  settlement  system  that  it  operates  had  not  yet  been  established.  The  draft  law’s  proposed 
amendment16 to Article 12(1) of the Law explicitly inserts point 15 on Banka Slovenije’s oversight 

of  the  operation  of  payment  and  settlement  systems.  Pursuant  to  Article  14  of  the  Law,  Banka 

Slovenije is already entitled to manage payment systems. The ECB would in addition suggest that 

the  Law  explicitly  states  that  Banka  Slovenije  may  operate  a  settlement  system,  as  this  would 

reflect the existing situation.  

Definitions of ‘banks’ and ‘savings banks’  

12  
13  
14  
15 

16  

Article 34 of the draft law, inserting new Articles 67.b and 67.a into the Law.  
Inserted by Article 3 of the draft law. 
Article 4 of the draft law. 
Presented in  the  report  entitled  ‘Assessment  of  accession countries’  securities  settlement  systems  against  the  standards 
for the use of EU securities settlement systems in Eurosystem credit operations’, January 2004; available on the ECB’s 
website at www.ecb.int.  
Article 3 of the draft law. 

4 

 
                                                      
3.4.  The  draft  law17  inserts  a  new  Article  14.a  into  the  Law  containing  definitions  of  ‘banks’  and 

‘savings banks’. The ECB questions the scope of these definitions since they could be interpreted 
as being narrower than the Community concept of ‘credit institutions’18. 

3.5.  A  broader  definition  of  ‘banks’  and  ‘savings banks’ would  also be  compatible  with  certain other 

provisions of the draft law that already include references to entities other than banks and savings 
banks.  The  draft  law’s  proposed  amendment19  of  Article 43(1)  of  the  Law  extends  Banka 

Slovenije’s supervision from banks and savings banks also to include ‘other persons pursuant to the 
law’.  In  the  draft  law’s  proposed  amendment20  to  Article  44  of  the  Law,  the  deletion  of  specific 

references  to  ‘banks’  and  ‘savings  banks’  means  the  provision  is  extended  to  all  relevant 

participants. For reasons of consistency, the ECB would suggest amending all other provisions of 

the Law referring to ‘banks’ and ‘savings banks’ accordingly. 

Immunity of foreign reserve assets 

3.6.  The ECB welcomes the proposed21 new Article 22.a of the Law, which exempts the official foreign 

reserve assets of other countries and central banks deposited at Banka Slovenije from any judicial 

or extra-judicial enforcement.  

Register of financial assets 

3.7.  The ECB notes with interest the provisions of the proposed new Chapter 4.2.a of the Law22, which 

establishes a register of bank credits and other financial assets by means of which Banka Slovenije 

intends  to  secure  liabilities  to  itself,  the  ECB  and  the  NCBs  of  Member  States.  This  proposal 

supports  the  ECB  Governing  Council’s  decision  published  on  18  February  2005  to  include  bank 
credits in the Single List of assets eligible as collateral for Eurosystem credit operations23. The new 

register  of  financial  assets  which  will  be  established  and  administered  by  Banka  Slovenije  will 

contribute to ensuring that a valid security interest may be created over bank credits in a simple and 

certain manner and that the collateral can be swiftly realised in the event of counterparty default. 

3.8.  The ECB understands that the creation of collateral rights over registered assets by way of entry in 

the  abovementioned  register,  in  accordance  with  the  new  Article  22.c  of  the  Law,  is  without 

prejudice to any other method of creating collateral in favour of Banka Slovenije, the ECB and the 

NCBs of Member States. In particular, it should not affect the provision of book-entry securities as 

collateral either by way of an entry in the accounts maintained by an SSS operator or by a similar 

method. It might be advisable to clarify the relationship between the different methods of creating 

17  
18  

19  
20  
21  
22  
23  

Ibid., Article 5. 
Directive  2000/12/EC  of  the  European  Parliament  and  of  the  Council  of  20  March  2000  relating  to  the  taking  up  and 
pursuit  of  the  business  of  credit  institutions  (OJ  L  126,  26.5.2000,  p.  1).  Directive  as  last  amended  by 
Directive 2005/1/EC (OJ L 79, 24.3.2005, p. 9). 
Article 19 of the draft law. 
Ibid., Article 20. 
Ibid., Article 6. 
Inserted by Article 6 of the draft law.  
Available on the ECB’s website at www.ecb.int. 

5 

                                                      
collateral  rights.  In  this  respect,  the  ECB  suggests  removing  the  reference  to  point  8  of  Article 

12(1) which is contained in the proposed new Article 22.b of the Law.  

3.9.  As regards the creation of collateral rights over bank credits in accordance with the proposed new 

Article 22.c of the Law, the ECB’s view is that the position of Banka Slovenije, the ECB and the 

NCBs  of  Member  States  as  takers  of  collateral  would  be  considerably  improved  if  the  first 

paragraph  of  the  proposed  Article  22.c  were  complemented  by  a  provision  prohibiting  set-off 

against opposing claims by the debtor of a bank credit for the duration of the existence of collateral 

rights over such bank credit by way of registration. 

3.10.  Furthermore,  the  ECB  understands  that  the  proposed  new  Article  22.f  is  intended  to  protect 

collateral  rights  of  Banka  Slovenije,  the  ECB  and  the  NCBs  of  Member  States  that  have  been 

established  in  good  faith  against  conflicting  third-party  rights.  However,  the  current  wording  of 

Article  22.f  may  not  fully  convey  this  meaning.  The  ECB  suggests  considering  rewording  this 

provision,  to  make  it  clear  that  collateral  rights  of  Banka  Slovenije,  the  ECB  and  the  NCBs  of 

Member States which have been acquired in good faith have priority over any third-party claims. 

Prohibition on monetary financing 

3.11.  Under Article 24 of the Law, Banka Slovenije may not grant overdrafts or any other type of credit 

facility  in  favour  of  ‘bodies  of  the  Republic  of  Slovenia,  of  the  European  Union  or  of  European 

Union Member States, or in favour of their regional and local authorities, and other public entities’. 

In order to ensure that this provision covers all categories of entities covered by Article 101 of the 

Treaty, thus avoiding any risk of discrepancy, the ECB recommends either using the exact wording 

of  Article  101  of  the  Treaty  in  Article  24  of  the  Law  or  inserting  an  explicit  reference  to  the 

prohibition under Article 101 of the Treaty. 

Reporting of Banka Slovenije  

3.12.  The  draft  law24  amends  Article  26,  concerning  Banka  Slovenije’s  obligation  to  report  on  its 

activities.  It  specifies  that  Banka  Slovenije  reports  exclusively  to  the  National  Assembly  of  the 

Republic  of  Slovenia  at  least  biannually.  This  provision  does  not  seem  fully  to  recognise  Banka 

Slovenije’s specific position as an ESCB member and, after the euro is introduced, a Eurosystem 

member,  subject  to  and  reporting  to  its  decision-making  bodies,  and  the  ECB  recommends 

rewording it to this end.  

Application of provisions of the Law on banking 

3.13.  The proposed new Article 42.a of the Law25 stipulates that the provisions of the Law on banking 

shall apply mutatis mutandis to Banka Slovenije’s procedure. The ECB understands this provision 

only to apply to the use of the provisions of Chapter XV (entitled ‘Procedure for adopting decisions 

24  
25  

Article 7 of the draft law. 
Inserted by Article 18 of the draft law. 

6 

                                                      
in  individual  matters’)  of  the  Law  on  banking26  in  individual  matters  falling  within  Banka 

Slovenije’s  fields  of  competence.  For  reasons  of  clarity,  the  ECB  recommends  making  it  clearer 

which provisions of the Law on banking will apply to Banka Slovenije. 

Creation of provisions and assets in the valuation accounts 

3.14.  The ECB welcomes the two new articles27 in Chapter 9 (entitled ‘Income, expenditure and assets of 

Banka Slovenije’) that refer to Banka Slovenije’s position after the euro is introduced.  

3.15.  The  proposed  new  Article  49.a  of  the  Law  makes  it  possible  to  create  provisions  for  anticipated 

exchange rate, interest rate and price risks, in order to maintain the real value of assets. However, 

such provisions may not be created if, together with unrealised exchange rate differences, securities 

valuation effects and gold valuation effects, they would exceed 20 % of established net profit. 

3.16.  Under  the  proposed  new  Article  50.a  of  the  Law,  the  unrealised  income  deriving  from  exchange 

rate and price changes must be allocated in its entirety to the valuation accounts, and it may only be 

used to cover unrealised expenditure deriving from the same types of change. After the allocation 

of the assets to the valuation accounts, the net profit must be allocated to general reserves and the 

Slovenian budget. 

Issue and distribution of banknotes and coins after introduction of the euro 

3.17.  The  following  provisions  of  the  Law  govern  the  issue  and  distribution  of  banknotes  and  coins: 
Article  59;  Article  60  (containing  the  amendment  proposed  in  the  draft  law28);  and  the  proposed 
new Article 60.a29.  

3.18.  In Article 59, the reference to Article 7 of the Law, which historically concerns the issue of tolars 

as legal tender in Slovenia, should be deleted. This would reflect the fact that Banka Slovenije will 

no longer have the right to authorise the issue of banknotes with the status of legal tender. After the 

euro  is  introduced,  such  authorisation  will  derive  from  the  Treaty  and  the  Statute  and  will  be 

closely  linked  to  the  exclusive  right  of  the  ECB’s  Governing  Council  to  authorise  the  issue  of 

banknotes within the Eurosystem. The ECB therefore suggests also inserting an explicit reference 

to Article 106(1) of the Treaty and Article 16 of the Statute. 

3.19.  Article 60 of the Law should be further amended to reflect the fact that the ECB’s competence with 

respect to coin issue is limited to authorising the volume. 

3.20.  The ECB suggests reconsidering Article 60.a, which appears to be obsolete due to the existence of 

Articles  59  and  60  of  the  Law.  It  should  at  the  very  least  be  amended  to  ensure  that  the 

predistribution of banknotes and coins denominated in euro is subject to the rules and conditions 

that will be set out in the relevant ECB legal acts. 

26  
27  
28  
29  

Zakon o bančništvu; published in the Official Gazette of the Republic of Slovenia, Nos 7/99, 59/01, 55/03 and 42/04. 
Proposed new Articles 49.a and 50.a of the Law, inserted by Articles 24 and 25 of the draft law. 
Article 29 of the draft law. 
Inserted by Article 30 of the draft law. 

7 

                                                      
3.21.  Also,  for  reasons  of  legal  clarity  and  certainty,  and  in  order  to  avoid  duplication,  it  would  be 

advisable for the draft law specifically to repeal the entirety of Chapter 3, which will be obsolete 

once the euro is introduced. 

Banka Slovenije tasks in the implementation of monetary policy 

3.22.  The wording of the proposed amendment30 to Article 58(2) of the Law (on Banka Slovenije’s tasks 

after  the  euro  is  introduced)  should  be  amended  to  state  that  Banka  Slovenije  ‘implements 

monetary  policy’,  without  any  reference  to  ‘defining’  monetary  policy.  Indeed,  pursuant  to 

Article 12.1  of  the  Statute,  the  Community’s  monetary  policy  is  exclusively  formulated  by  the 
Governing Council31. 

3.23.  Moreover, the proposed amendment32 to Article 61(2) of the Law (on Banka Slovenije’s tasks in 

the implementation of monetary policy after the euro is introduced) should also include a reference 

to Banka Slovenije’s responsibility for the general liquidity of the banking system, as specified in 

point 3 of Article 11 of the Law (which sets out the ESCB’s scope of competence), and not refer 

only to the tasks under point 1 of Article 11 of the Law. In addition, the proposed amendment to 

Article 61(2) of the Law should include a specific abrogation of Article 45 of the Law; the latter 

relates  to  Banka  Slovenije’s  supervisory  measures  in  connection  with  the  implementation  of 

monetary policy and does not sufficiently recognise the ECB’s powers in this field. 

Asset management after introduction of the euro 

3.24.  Pursuant to the amendment to Article 62 proposed in the draft law33, Banka Slovenije will from the 

introduction of the euro manage: (i) the official foreign reserves that it has  not transferred to the 

management of the ECB; (ii) its other assets; and (iii) any other assets entrusted to it. This does not 

sufficiently  recognise  the  ECB’s  powers  in  this  field  and  could  create  the  misleading  impression 

that Banka Slovenije is autonomous as regards the management of foreign reserve assets. The ECB 

would  therefore  like  to  draw  attention  to  Article  31.2  of  the  Statute  concerning  foreign  reserve 

assets held by NCBs: this provides that all operations in foreign reserve assets remaining with the 

NCBs after the transfer of foreign reserve assets to the ECB under Article 30 of the Statute must, 

above  a  certain  limit  to  be  established  within  the  framework  of  Article  31.3  of  the  Statute,  be 

subject to approval by the ECB in order to ensure consistency with the exchange rate and monetary 

policies of the Community. To this end, an explicit reference to Article 31 of the Statute and the 

legal framework adopted on the basis thereof should be added. 

Exchange rate list of Banka Slovenije  

30  
31  

32  
33  

Article 28 of the draft law. 
See paragraph 11 of ECB Opinion CON/2005/60 of 30 December 2005 at the request of Lietuvos bankas on a draft law 
amending the Lietuvos bankas Act. 
Article 31 of the draft law. 
Ibid., Article 32. 

8 

                                                      
3.25.  Under  the  proposed  amendment  to  Article  67  of  the  Law34,  after  the  euro  is  introduced  Banka 

Slovenije ‘shall publish an exchange rate list on the basis of the reference exchange rates of foreign 

currencies  determined  and  published  by  the  European  Central  Bank,  and  shall  determine  and 

publish exchange rates of foreign currencies that are not on the exchange rate list of the European 

Central  Bank’.  The  ECB  suggests  rewording  Article  67  to  provide  for  the  possibility  of  Banka 

Slovenije publishing euro foreign exchange reference rates set by the ECB and any other exchange 

rates that are not on the list published by the ECB. Otherwise this provision could be misinterpreted 

as a mandatory requirement to publish exchange rates. 

International cooperation of Banka Slovenije 

3.26.  The proposed new Article 67.a of the law35 provides that from the day of the introduction of the 

euro Banka Slovenije ‘shall participate in international monetary organisations after prior approval 

by the ECB’. The ECB suggests bringing this wording closer to that of Article 6.2 of the Statute, 

under which the NCBs may participate in international monetary institutions ‘subject to’ the ECB’s 

approval. 

Infringements by banks, savings banks and other entities 

3.27.  Point 1 of both Article 68(1) and Article 69(1) of the Law36 could be slightly amended to specify 

more clearly that the imposition of a fine for an infringement of the obligation to submit data and 

information required by Banka Slovenije in performing its tasks is without prejudice to the broader 

requirement to impose a sanction for an infringement of the obligation to submit the statistical data 

and  information  which  Banka  Slovenije  needs  to  perform  its  tasks  as  an  ESCB  member.  The 
relevant  sanctions  are  already  laid  down  in  the  proposed  new  Article  67.b  of  the  Law37,  which 

concerns the ECB’s sanctions regime. 

This opinion will be published on the ECB’s website. 

Done at Frankfurt am Main, 13 March 2006. 

[signed] 

The President of the ECB 

Jean-Claude TRICHET 

34  
35  
36  
37  

Ibid., Article 33. 
Inserted by Article 34 of the draft law. 
Containing the amendments proposed in Articles 35 and 36, respectively, of the draft law. 
Inserted by Article 34 of the draft law. 

9