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11 February 2020

Bulgaria: Deadline for Update of AML Internal Rules

Under Bulgarian anti-money laundering law, all obliged entities must adapt their internal rules in accordance with Article 101 of the Bulgarian Anti-Money Laundering Act ("AMLA") within six months following the publication of a national assessment of the risks related to money laundering and terrorism financing ("National Risk Assessment") on the website of the State Agency for National Security ("SANS").

The National Risk Assessment was published on 9 January 2020, triggering the start of the six-month deadline.

Who is concerned?

  • Entities obliged under Article 4 of the AMLA to apply anti-money laundering measures, e.g. wholesalers, banks, insurers, companies trading with oil and petroleum products, etc.

What to do?

  • Adapt your internal rules in accordance with the requirements of Article 101 of the AMLA.
  • Some of the main requirements include sound criteria for identifying suspicious clients and transactions, internal risk assessment and the terms and procedures for the collection, retention and disclosure of information.
  • The obligation to submit updated internal rules to the SANS for approval is waived, but the requirement to update and apply the internal rules remains.

What is the deadline?

  • 9 July 2020.

What are the fines for non-compliance?

  • Generally, EUR 500 – 5,000 for the first established incident of non-compliance.
  • Banks, insurers, leasing undertakings, investment intermediaries: EUR 1,000 – 10,000 for the first established incident of non-compliance.

What else?

  • According to an official notice published on the SANS website, obliged entities are not required to submit their training plans for 2020 to the SANS. This does not waive the obliged entities' obligation to adopt an annual training plan for 2020 by 15 February 2020 and to apply it.
  • The Bulgarian Registry Agency recently started a campaign to sanction companies that missed the statutory deadline (31 May 2019) to register their beneficial owner in the Commercial Register. Besides companies that have not registered their beneficial owner at all, the targets include those that did so only after 31 May 2019. The administrative sanctions for such an administrative infringement are between EUR 500 and EUR 5,000

This is a general communication to alert you to the approaching deadline to adapt your internal rules. The Schoenherr Sofia team remains available to support you and respond to your questions in this regard.


Attorney at Law