Further to the 'National Risk Assessment on Money Laundering and Terrorist Financing' issued by the Bulgarian State Agency for National Security (SANS) on 9 January 2020, the SANS has published online templates of internal rules that are intended to help some obliged entities comply with the requirements of the Bulgarian Anti-Money Laundering (AML) Act.
People and organisations applying anti-money laundering and terrorist financing measures had to adopt new or adapt their internal rules in accordance to Article 101 of the Bulgarian AML Act within six months of the National Risk Assessment's publication, i.e. no later than 9 July 2020. Due to the COVID-19 state of emergency declared in Bulgaria, however, the deadline was extended, and the majority of incumbent entities now have until 21 August 2020 to adopt or amend their internal rules.
There are almost 40 categories of reporting entities under the AML Act to which this requirement applies, including banks, financial institutions, payment services providers, insurance and reinsurance companies and intermediaries. In Bulgaria, the reporting entities under the AML Directives have been extended to include wholesalers. Each of the reporting entities should adapt their AML rules to comply with more than a dozen requirements, including the establishment of an internal system for determining the risk profile of clients based on the results of the National Risk Assessment and on information obtained from extended complex verification processes and internal and external databases.
The good news is that this week the SANS published internal rules templates on its website that should help some categories obliged entities comply with the requirements. The template internal rules concern persons who by occupation provide accounting services or consultations in the field of taxation, wholesalers, non-profit legal entities, traders in arms, oil and petroleum products, legal entities with mutual aid funds, trade unions and professional organisations, and professional sports clubs. These categories can make use of the template internal rules provided by the SANS but should supplement them to address the level of risk determined by the National Risk Assessment and the specifics of their activity, including the criteria for suspicious operations, transactions and clients.
More information on the National Risk Assessment can be found here.
For further information on this eAlert, contact your regular CMS advisor or local CMS expert: Nevena Radlova. This article was co-authored by Kalina Krastanova.