Ultimate Beneficial Owners

The obligation to register their ultimate beneficial owners (UBOs) will no longer apply to those entities whose UBOs may be identified by means of consecutive checks under the batches of the legal entities/organizations included in the corporate ownership chart in Bulgarian public registers, such as the Commercial Register and the BULSTAT Register.

Update of internal rules

The deadline for obliged entities under MAMLA/Measures against Terrorism Financing Act (MATFA) to update their internal rules for control and prevention of money laundering and terrorism financing is now changed. The new deadline by which the internal rules must be aligned with the new legal framework is six months as of the adoption and publication of the results of the national risk assessment on the website of State Agency National Security (SANS).

SANS guidance concerning wholesale traders

Wholesale traders are obliged entities both under the provisions of the previous MAMLA and under the rules of the currently applicable MAMLA and must enforce the measures provided by law. As the MAMLA does not include a definition of the term “wholesale trader”, the SANS published on its website guidelines explaining which legal entities are considered wholesale traders.

According to the SANS, a manufacturer may also fall within the definition of wholesale trader and needs to apply the measures against money laundering if it is a commercial entity/sole proprietor within the meaning of the Commercial Act and the purpose of the business activity consists of the sale-purchase of goods where the buyer aims to further resell the purchased goods or services.

The full guidelines can be accessed via the following link: http://www.dans.bg/en/msip-091209-menu-en/faq-mitem-bg

For questions, please do not hesitate to get in touch with us.