At the beginning of December 2025, a Bill for the Amendment and Supplementation of the Measures Against Money Laundering Act (AS-MAMLA) was submitted to the National Assembly of the Republic of Bulgaria.
The proposed bill provides for additional measures against money laundering, targeting persons from third countries who are subject to sanctions, including under the “Magnitsky Act”. It obliges all reporting entities to carry out enhanced due diligence and continuous monitoring of both the sanctioned persons and those connected to them, with the results to be submitted to the financial intelligence unit. The primary objective is to prevent the use of the Bulgarian financial system and economic turnover for the circumvention of sanctions or for activities related to violations of international peace, human rights, and corruption.
Any transaction or operation carried out by sanctioned persons or persons connected to them shall be deemed suspicious and shall be subject to reporting to the financial intelligence unit and the National Assembly. The same data shall also be provided to the competent authorities of the respective third country, in order to maintain up-to-date information regarding the sanctioned persons.
With the amendments to Art. 11 of the MAMLA, an additional rule is introduced, according to which the obliged entities must apply enhanced due diligence measures when establishing business relationships with sanctioned persons, as well as with persons who have been connected to them during a certain period prior to their inclusion in a sanctions list. In this way, an expanded, risk-based approach is applied, taking into account the practice of sanctioned persons using related or proxy individuals and structures under their control in order to continue their participation in economic and financial relations.
The prescribed period of five years prior to the date of inclusion in a sanctions list is intended to cover a broader range of connections that may have been used for the preparation or concealment of activities leading to the sanctions, while at the same time setting a reasonable limit so as not to disproportionately expand the circle of persons subject to verification.
The scope of the affected parties is limited to the member states of the Organisation for Economic Co-operation and Development (OECD), in order to prevent abuses. The State Agency for National Security shall provide and publish updated sanctions lists and data on related persons, thereby creating a single source of information which enhances legal certainty and reduces the risk of divergent interpretations.
With the AS-MAMLA, in § 1, item 36, a definition of “sanctioned person” is introduced, encompassing individuals subject to sanctions imposed by the EU, the UN, the OECD, or by EU and OECD member states. Criminal convictions are excluded, as they fall under other regimes. The limitation is intended to avoid consequences arising from acts of repressive regimes, while the choice of the OECD is linked to the standards of democracy, the rule of law, and the protection of human rights.
The proposed amendments to the Law on Credit Institutions oblige the Bulgarian National Bank to publish information regarding the accounts and safe deposit boxes of sanctioned persons, without disclosing their value. The purpose is to ensure transparency of the financial activity of such persons and to strengthen the system against money laundering and terrorist financing. The measures limit sanctions to regimes of the EU, the UN, and the OECD, thereby guaranteeing legal predictability and the protection of fundamental rights, and are expected to improve the reputation of the Bulgarian financial system.