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Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Bulgaria BG

Domains covered
8 of 8
Sources
144
Role actions
8
Horizon <90d
2
Jurisdiction profile
FATF status: Grey-List Tier: B Risk direction: Stable Enablement vs enforcement: Mixed

Bulgaria operates the Law on Measures Against Money Laundering (LMML) and Law on Measures Against Financing of Terrorism (LMFT), supervised principally by FID-SANS (State Agency for National Security) and the Bulgarian National Bank.

MoreIt has one of the EU's few free public beneficial-ownership registers, but MONEYVAL's 2022 MER found systemic effectiveness gaps in ML prosecution, confiscation, PF sanctions and VASP supervision, driving FATF grey-listing since October 2023.

Key deficiencies
  • Weak investigation/prosecution of high-scale corruption and organised-crime money laundering relative to risk profile
  • Gaps in proliferation-financing targeted-financial-sanctions (PF TFS) framework
  • Underdeveloped VASP-specific AML/CFT supervisory guidance despite market-entry registration controls
  • Confiscation not historically pursued as a systematic policy objective (partially remediated)
Recent developments (18m)
  • FATF/MONEYVAL Follow-Up Reports (Feb 2025, June 2025, Oct 2025, Feb 2026) progressively re-rated multiple Recommendations from Partially Compliant to Largely Compliant/Compliant
  • June 2026 FATF Plenary: initial determination that Bulgaria has substantially completed its action plan, triggering an on-site assessment ahead of possible delisting
  • Bulgaria adopted the euro on 1 January 2026, becoming the 21st euro-area member, ending lev-based cash/currency-conversion opacity risk over a transition period to August 2026
  • Bulgarian government seized control of Lukoil's Neftohim Burgas refinery and retail network (Nov 2025) after OFAC designated Rosneft and Lukoil, prompting Bulgaria-specific OFAC general licences
  • EPPO/GDCOC dismantled a shell-company network defrauding EU Human Resources Development Programme subsidies (2026)

Law made at European Economic Area level that applies in Bulgaria is covered once, on the European Economic Area page. This page covers Bulgaria’s own layer: implementation, national authorities, national options and local enforcement.

Brief

Lead signal

Lead Signal

Bulgaria has been removed from the Financial Action Task Force's list of jurisdictions under increased monitoring, a decision taken at the Plenary held 28-30 October 2026. The removal, announced alongside Cote d'Ivoire, the Democratic Republic of Congo and Monaco, follows FATF's confirmation that Bulgaria strengthened the effectiveness of its AML/CFT regime to meet the commitments in its action plan. The underlying basis for the delisting includes on-site verification of remediated technical-compliance deficiencies, the establishment of risk-based supervision over postal money operators, currency-exchange providers and real-estate agents, and the introduction of market-entry controls covering virtual-asset service providers and postal money operators. This is a structural finding, not an incident: it records a multi-year remediation programme, originating from Bulgaria's October 2023 listing, reaching the point FATF regards as sufficient to exit enhanced monitoring. MONEYVAL, the Council of Europe body responsible for Bulgaria's mutual evaluation, publicly welcomed the decision and confirmed it will continue follow-up work with Bulgaria to sustain the improvements made.

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Lead Signal

Bulgaria has been removed from the Financial Action Task Force's list of jurisdictions under increased monitoring, a decision taken at the Plenary held 28-30 October 2026. The removal, announced alongside Cote d'Ivoire, the Democratic Republic of Congo and Monaco, follows FATF's confirmation that Bulgaria strengthened the effectiveness of its AML/CFT regime to meet the commitments in its action plan. The underlying basis for the delisting includes on-site verification of remediated technical-compliance deficiencies, the establishment of risk-based supervision over postal money operators, currency-exchange providers and real-estate agents, and the introduction of market-entry controls covering virtual-asset service providers and postal money operators. This is a structural finding, not an incident: it records a multi-year remediation programme, originating from Bulgaria's October 2023 listing, reaching the point FATF regards as sufficient to exit enhanced monitoring. MONEYVAL, the Council of Europe body responsible for Bulgaria's mutual evaluation, publicly welcomed the decision and confirmed it will continue follow-up work with Bulgaria to sustain the improvements made.

The practical effect is a shift in Bulgaria's standing architecture rather than a change to any single control. For institutions conducting due diligence keyed to grey-list status, Bulgaria's removal alters the baseline risk categorisation that has applied since 2023. It does not, on its own, confirm that every underlying Recommendation has been re-rated to full compliance; FATF's own public materials describe a summary Plenary outcome, with the fuller Recommendation-by-Recommendation detail expected only once MONEYVAL's enhanced follow-up report is published.

Other Developments

MONEYVAL's corroborating statement adds a second, independent Tier-1-adjacent voice to the delisting, confirming that the regional mutual-evaluation body regards the FATF decision as warranted and intends to continue monitoring Bulgaria's implementation going forward, rather than treating the Plenary outcome as a closing of the file.

The expected publication of MONEYVAL's full enhanced follow-up report, anticipated in the fourth quarter of 2026 following quality-and-consistency review, will be the document that actually sets out Bulgaria's current compliance rating against each individual FATF Recommendation. Until that report is public, the delisting should be read as a summary finding: substantively significant, but not yet accompanied by the granular technical detail that will let firms recalibrate control-by-control.

Cross-Monitor Connections

A jurisdiction's movement off the FATF increased-monitoring list is the kind of structural signal that typically has knock-on relevance for monitors tracking state capture and conflict finance, insofar as grey-list status is often used as a proxy input to jurisdictional risk scoring in sanctions-adjacent and PEP-exposure screening elsewhere in the compliance stack. No Bulgaria-specific conflict-finance or enabler-jurisdiction development was identified this cycle to connect to, however, and the present record should not be read as implying one.

Outlook

The immediate outlook centres on MONEYVAL's enhanced follow-up report, expected in the fourth quarter of 2026, which will provide the detailed Recommendation-level basis for Bulgaria's new status. Firms that maintain jurisdiction risk matrices referencing the FATF increased-monitoring list should expect to update Bulgaria's entry to reflect the 30 October 2026 removal, while treating the underlying technical-compliance detail as provisional pending that fuller publication. As scheduled, no further Bulgaria-specific action plan obligations are outstanding at this stage, though MONEYVAL's continuing follow-up work means the file remains open in a supervisory, rather than remedial, sense.

Earlier periodic briefs (5)
4 Nov 2026 · fim-2026-11-01

Lead Signal

Bulgaria has been removed from the Financial Action Task Force's list of jurisdictions under increased monitoring, a decision taken at the Plenary held 28-30 October 2026. The removal, announced alongside Cote d'Ivoire, the Democratic Republic of Congo and Monaco, follows FATF's confirmation that Bulgaria strengthened the effectiveness of its AML/CFT regime to meet the commitments in its action plan. The underlying basis for the delisting includes on-site verification of remediated technical-compliance deficiencies, the establishment of risk-based supervision over postal money operators, currency-exchange providers and real-estate agents, and the introduction of market-entry controls covering virtual-asset service providers and postal money operators. This is a structural finding, not an incident: it records a multi-year remediation programme, originating from Bulgaria's October 2023 listing, reaching the point FATF regards as sufficient to exit enhanced monitoring. MONEYVAL, the Council of Europe body responsible for Bulgaria's mutual evaluation, publicly welcomed the decision and confirmed it will continue follow-up work with Bulgaria to sustain the improvements made.

The practical effect is a shift in Bulgaria's standing architecture rather than a change to any single control. For institutions conducting due diligence keyed to grey-list status, Bulgaria's removal alters the baseline risk categorisation that has applied since 2023. It does not, on its own, confirm that every underlying Recommendation has been re-rated to full compliance; FATF's own public materials describe a summary Plenary outcome, with the fuller Recommendation-by-Recommendation detail expected only once MONEYVAL's enhanced follow-up report is published.

Other Developments

MONEYVAL's corroborating statement adds a second, independent Tier-1-adjacent voice to the delisting, confirming that the regional mutual-evaluation body regards the FATF decision as warranted and intends to continue monitoring Bulgaria's implementation going forward, rather than treating the Plenary outcome as a closing of the file.

The expected publication of MONEYVAL's full enhanced follow-up report, anticipated in the fourth quarter of 2026 following quality-and-consistency review, will be the document that actually sets out Bulgaria's current compliance rating against each individual FATF Recommendation. Until that report is public, the delisting should be read as a summary finding: substantively significant, but not yet accompanied by the granular technical detail that will let firms recalibrate control-by-control.

Cross-Monitor Connections

A jurisdiction's movement off the FATF increased-monitoring list is the kind of structural signal that typically has knock-on relevance for monitors tracking state capture and conflict finance, insofar as grey-list status is often used as a proxy input to jurisdictional risk scoring in sanctions-adjacent and PEP-exposure screening elsewhere in the compliance stack. No Bulgaria-specific conflict-finance or enabler-jurisdiction development was identified to connect to, however, and the present record should not be read as implying one.

Outlook

The immediate outlook centres on MONEYVAL's enhanced follow-up report, expected in the fourth quarter of 2026, which will provide the detailed Recommendation-level basis for Bulgaria's new status. Firms that maintain jurisdiction risk matrices referencing the FATF increased-monitoring list should expect to update Bulgaria's entry to reflect the 30 October 2026 removal, while treating the underlying technical-compliance detail as provisional pending that fuller publication. As scheduled, no further Bulgaria-specific action plan obligations are outstanding at this stage, though MONEYVAL's continuing follow-up work means the file remains open in a supervisory, rather than remedial, sense.

3 Nov 2026 · fim-2026-11-03

Lead Signal

Bulgaria was removed from the Financial Action Task Force list of jurisdictions under increased monitoring at the Plenary held 28-30 October 2026. The FATF's own statement credits Sofia with strengthening the effectiveness of its anti-money-laundering and counter-terrorist-financing regime to meet the commitments set out in its action plan, and MONEYVAL, the Council of Europe body that conducted the underlying on-site assessment, publicly welcomed the decision and confirmed it will continue working with Bulgarian authorities to sustain the improvements made. This is a structural recalibration rather than an isolated enforcement event: it reflects a multi-year programme of legislative and supervisory change inside Bulgaria culminating in a confirmed assessment that the action-plan commitments were met.

The practical significance of grey-list exit runs through correspondent banking and client-onboarding channels rather than through any single transaction. While Bulgaria sat on the list, counterparties applying FATF-aligned risk frameworks were entitled, and in practice often required by their own supervisors, to apply incrementally closer scrutiny to Bulgarian-domiciled relationships. Removal does not retroactively undo supervisory caution built up over the monitoring period, but it removes the categorical trigger for enhanced treatment that attached specifically to grey-list status, and it is the clearest FATF-level signal available that Bulgaria's framework for postal money operators, currency-exchange providers, real-estate agents, and market-entry controls for virtual-asset service providers has been assessed as operating on a risk-sensitive basis.

Other Developments

MONEYVAL's follow-up posture remains active. The welcome statement from MONEYVAL was paired with an explicit commitment to continue engagement with Bulgaria to sustain the improvements that justified delisting, signalling that oversight does not end with the Plenary decision; the body's enhanced follow-up architecture remains in place as the mechanism for confirming durability.

No parallel movement surfaced elsewhere in the sanctions, beneficial-ownership, enabler-jurisdiction, conflict-finance, crypto, compliance-technology, or commercial-activity typologies for Bulgaria this period. The research effort was concentrated on the grey-list development, and the other seven typology domains remain on their prior standing assessments without new Bulgaria-specific material to report.

Cross-Monitor Connections

The grey-list exit is the kind of structural regulatory finding that typically eases frictions tracked on the payments side of the fleet's coverage, since correspondent-banking de-risking decisions and account-opening scrutiny for Bulgarian payment and financial institutions are frequently calibrated, in part, against FATF list status. A reduction in that friction is a plausible downstream effect of this finding rather than a confirmed one, and it should be read as context for, not a conclusion about, any commercial or market-access findings reported elsewhere in the coverage.

Outlook

MONEYVAL's third enhanced follow-up report, covering the fifth-round mutual-evaluation cycle, is expected in the fourth quarter of 2026 as scheduled, pending the organisation's internal quality-review process; the current public record consists only of the summary delisting statement, and the fuller Recommendation-by-Recommendation compliance ratings have not yet been published. That report, once issued, will be the next substantive test of whether the structural improvements behind this delisting are holding. In the interim, the delisting itself stands as a confirmed, dated change in Bulgaria's FATF standing, and the analytical posture going forward is to track whether correspondent-banking and onboarding practice actually adjusts in response, rather than to assume it will.

18 Oct 2026 · fim-2026-10-18

Lead Signal

The US Treasury Office of Foreign Assets Control has extended General License No. 130B/135, authorising transactions involving Lukoil Neftohim Burgas JSC, Lukoil Bulgaria EOOD, Lukoil Aviation Bulgaria EOOD and Lukoil Bulgaria Bunker EOOD through 24 April 2027. The licence had been due to expire on 29 October 2026. The extension removes a near-term sanctions cliff for Bulgaria's Lukoil-linked energy sector but leaves the underlying divestment of Lukoil's foreign assets unresolved, and a parallel sale-negotiation licence, General License 131J, is due to expire 22 October 2026.

Other Developments

A sanctions-circumvention criminal offence bill advanced to first reading. Bulgaria's National Assembly adopted at first reading, on 24 September 2026, government bill No. 52-602-01-43, creating a new Criminal Code chapter on sanctions-circumvention offences. The bill was prompted by a European Commission infringement action after Bulgaria missed the May 2025 deadline for transposing Directive (EU) 2024/1226. As drafted, the bill would impose penalties of up to ten years' imprisonment for individuals and court-imposed pecuniary sanctions of up to EUR 40.5 million for companies, under a new Administrative Violations and Sanctions Act provision. The bill fills a domestic enforcement-architecture gap but remains unenacted, and reported drafting weaknesses include a missing breach element for dual-use-goods offences and a travel-ban penalty below the EU minimum. MONEYVAL closed Bulgaria's Fifth Round enhanced follow-up process. The Council of Europe's MONEYVAL committee published its third enhanced follow-up report on 17 June 2026, re-rating eight Recommendations and finding Bulgaria compliant or largely compliant on all 40 FATF Recommendations, closing the enhanced follow-up process that had been open since Bulgaria's Fifth Round mutual evaluation. Bulgaria's MiCA transitional cutover completed 1 July 2026. The Financial Supervision Commission is now the sole licensing authority for crypto-asset service providers in Bulgaria, with the prior National Revenue Agency registration basis under Article 9a of the Measures Against Money Laundering Act no longer a valid basis for operation.

Cross-Monitor Connections

The OFAC general-licence extension for Lukoil-linked Bulgarian entities is a correspondent-banking and payment-access question as much as a sanctions-architecture one: the licence's practical effect is to preserve the ability of named entities to transact through the US financial system and, by extension, correspondent banks relying on US nexus, a theme that connects directly to payments-monitoring work tracking settlement and access channels. The advancing sanctions-circumvention criminal bill and the completed MiCA licensing cutover both sit against the backdrop of the broader EU AML Package architecture, in which the directly-applicable AML Regulation, the sixth AML Directive's national transposition, and the AMLA Regulation's shift of supervision toward a hybrid EU-level model are reshaping how enabler-jurisdiction gaps and crypto-sector authorisation are policed across the bloc, even though AMLA's own direct-supervision selection process has not yet produced a Bulgaria-specific outcome.

Outlook

The clearest near-term marker to watch is 22 October 2026, when the parallel General License 131J covering Lukoil sale-negotiation activity is due to expire, distinct from the now-extended General License 130B/135. On the enforcement-architecture side, the sanctions-circumvention bill's passage beyond first reading, and whether the reported drafting gaps around dual-use offences and travel-ban penalties are addressed before enactment, will determine whether Bulgaria's domestic criminal framework closes the gap the European Commission's infringement action identified.

11 Oct 2026 · fim-2026-10-11

Lead Signal

Bulgaria's AML/CTF architecture closed a multi-year chapter this period. MONEYVAL's follow-up report, adopted and published 17 June 2026, formally closed Bulgaria's 5th-round mutual evaluation, finding the country compliant or largely compliant with all 40 FATF Recommendations. Bloomberg, reporting via the Bulgarian Telegraph Agency, indicates Bulgaria is expected to be removed from the FATF list of jurisdictions under increased monitoring at the plenary concluding 30 October 2026, alongside Monaco and Cote d'Ivoire. As of FATF's own 19 June 2026 statement, Bulgaria remained listed among 22 jurisdictions subject to increased monitoring, so the removal reporting, while probable given the MONEYVAL closure, has not yet been confirmed by FATF itself. The structural significance of this sequence is that an exit, if it occurs as reported, resolves increased-monitoring status that has shaped counterparty due-diligence treatment of Bulgaria for several years.

Other Developments

Bulgaria's crypto-asset enforcement perimeter tightened sharply after the MiCA transitional period expired on 1 July 2026. The Financial Supervision Commission is reported to have publicly named six websites offering unauthorised crypto-asset services and one site offering unauthorised investment services on 8 October 2026, ordering cessation within three days under the Crypto-Asset Markets Act and the Financial Supervision Commission Act. This is a secondary report; the primary FSC enforcement notice was not directly retrieved this period. A Bulgarian Offshore Companies Act amendment introduces a beneficial-ownership registration condition for treaty-state entities seeking exception from blanket offshore restrictions, with a sanction of EUR 5,000 to 25,000 for failure to register the beneficial owner with the Commercial Register. This rests on a single legal-commentary source; the primary State Gazette text was not retrieved this period, so the exact provision and sanction figures remain unconfirmed at the pinpoint level. Sofia-based payments fintech Paypercut closed a EUR 5 million seed round on 3 June 2026, co-led by Concentric, Passion Capital and Araya Ventures, bringing total funding to EUR 7 million, to pursue an Irish EMI licence and build stablecoin-based cross-border settlement rails for Central and Eastern European corridors.

Cross-Monitor Connections

The FSC's crypto-enforcement sweep is a direct overlap point with the crypto monitor's coverage of Bulgaria's post-MiCA-transition licensing perimeter; the same underlying enforcement episode is read here through an AML/CFT enforcement-theory lens and there through a CASP-licensing lens. Paypercut's pursuit of an Irish EMI licence and stablecoin-based settlement rails connects directly to the world-payments monitor's tracking of Bulgarian payments-sector commercial activity and to this period's broader crypto/stablecoin-innovation signal. The Offshore Companies Act amendment's beneficial-ownership registration condition sits within the structural backdrop of the EU AML Package: the directly-applicable AML Regulation (Reg (EU) 2024/1624), the sixth AML Directive requiring Member State transposition, and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority and shifting supervision toward a hybrid EU-level regime; Bulgaria's own 6AMLD beneficial-ownership-register transposition instrument was not located this period.

Outlook

The clearest near-term marker is the FATF plenary concluding 30 October 2026: a primary FATF statement confirming Bulgaria's removal from the grey list would move the current Probable-sourced reporting to a confirmed structural change in Bulgaria's international AML standing. A second marker is whether the FSC's October enforcement sweep against unauthorised crypto providers repeats, which would indicate a sustained rather than one-off post-transition enforcement posture. Locating Bulgaria's primary State Gazette text for the Offshore Companies Act amendment, and its own 6AMLD transposition instrument, remain the two outstanding gaps most likely to firm up the beneficial-ownership picture in a future period.

28 Sep 2026 · fim-2026-09-28

Lead Signal

Bulgaria's anti-money-laundering standing improved materially this cycle: MONEYVAL closed Bulgaria's 5th-round mutual evaluation on 17 June 2026, rating all 40 FATF Recommendations compliant or largely compliant. The closure follows a re-rating exercise addressing confiscation, the terrorist-financing offence, proliferation-related targeted financial sanctions, non-profit organisations, correspondent banking, sanctions, and mutual legal assistance, and ends several years of enhanced follow-up that had run since the May 2022 mutual evaluation report. Bulgaria is not on the FATF grey list, and this closure removes a standing item of supervisory attention that had persisted across multiple prior cycles.

Other Developments

A structural consolidation of crypto-asset AML registration architecture is underway. The Bulgarian MiCA Act is understood to repeal the National Revenue Agency's Article 9a Anti-Money Laundering Act register of virtual-asset service providers, folding VASP AML-registration history into the Financial Supervision Commission's MiCA CASP register. Legacy NRA-registered VASPs' transitional operating right expired 1 July 2026. This is a single-source, probable-confidence finding not yet corroborated against the MiCA Act's own text, but it describes an architecture shift — consolidation of a national AML-specific register into a supranationally-harmonised licensing register — rather than an isolated incident. The same transitional cliff-edge creates a residual verification gap. Whether any BG-registered legacy VASP failed to secure CASP authorisation by the 1 July 2026 deadline, and was accordingly removed from or never correctly added to the register, has not been confirmed against the Financial Supervision Commission's own register this cycle.

Cross-Monitor Connections

The MiCA-driven consolidation of VASP AML registration architecture is the same underlying development the crypto monitor tracks under its crypto_licensing module, and the same transitional-expiry cliff-edge that world-payments and crypto both treat as a residual authorisation-status question for legacy providers. Readers of this brief's D2 and D5 domain sub-briefs should treat the crypto monitor's crypto_licensing coverage as the technical-architecture companion to this brief's AML-registration and financial-crime framing of the identical underlying MiCA Act change.

Outlook

The MONEYVAL closure removes Bulgaria from the enhanced-follow-up track that had run since 2022, and the near-term outlook on the AML/CTF regime itself is stable-to-positive absent a new deficiency finding. The open question sits in the crypto-adjacent architecture: whether the FSC's own register confirms that all legacy NRA-registered VASPs completed the transition to MiCA CASP authorisation by 1 July 2026, and whether Bulgaria's 6AMLD transposition status (not yet established this cycle) introduces any gap relative to the AMLR's direct application as an EU-27 member state.

Domain intelligence (D1–D8)

D1 Sanctions

improvingmaterial_change

Sanctions Architecture and Evasion

Bulgaria's removal from the FATF list of jurisdictions under increased monitoring, confirmed at the 28-30 October 2026 Plenary, is directly relevant to the sanctions-architecture reading of jurisdictional enablement risk even though no new sanctions-specific designation or enforcement action was identified for Bulgaria this cycle. Grey-list status has functioned since October 2023 as a proxy signal feeding into jurisdiction risk scoring used across sanctions-compliance programmes; its removal changes that proxy input directly. The remediation basis FATF cited, in particular the introduction of market-entry controls for virtual-asset service providers and postal money operators and the extension of risk-based supervision to currency-exchange providers, addresses precisely the categories of intermediary most structurally exploited for sanctions circumvention: cash-intensive conversion points and cross-border money-remittance channels. The improvement in Bulgaria's standing AML/CFT posture, as assessed by FATF and corroborated by MONEYVAL, should be read as narrowing the space in that architecture that evasion typologies have historically used, even in the absence of a specific interdicted transaction or designated entity tied to this cycle.

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This is an architecture-over-incident finding in the clearest sense: no enforcement action, asset freeze or new designation occurred, and the significance lies entirely in the structural remediation of supervisory gaps that a permissive jurisdiction previously carried. The absence of any new Bulgaria-specific sanctions-evasion signal this cycle is itself consistent with, rather than contradictory to, a jurisdiction moving toward tighter systemic controls.

Outlook

The near-term outlook for the sanctions-architecture reading of Bulgaria depends on MONEYVAL's enhanced follow-up report, expected in the fourth quarter of 2026, which will set out Recommendation-by-Recommendation ratings including those most relevant to sanctions enablement (customer due diligence, beneficial ownership verification, and supervision of money-or-value transfer services). Until that report is published, the FATF delisting should be treated as a summary-level improvement in the systemic backdrop rather than a confirmed, granular closing of every previously identified gap.

Judgment: Bulgaria's removal from the FATF grey list reflects improved systemic AML/CFT posture directly relevant to sanctions-architecture enablement risk, though no new sanctions-specific development was identified this cycle. Probable
Cumulative analysis

Sanctions

The US Treasury's Office of Foreign Assets Control has extended General License No. 130B/135, authorising transactions involving Lukoil Neftohim Burgas JSC, Lukoil Bulgaria EOOD, Lukoil Aviation Bulgaria EOOD and Lukoil Bulgaria Bunker EOOD through 24 April 2027. This replaces a licence that had been due to expire on 29 October 2026, and removes what would otherwise have been a near-term sanctions cliff for Bulgaria's Lukoil-linked energy infrastructure, including refining and aviation-fuel supply entities operating under the Lukoil brand within Bulgarian territory.

The extension addresses the operational continuity of named entities, not the underlying ownership question: Lukoil's divestment of its foreign assets, including the Bulgarian operations the general licence covers, remains unresolved. A second, parallel general licence, GL 131J, specifically authorising sale-negotiation activity around that divestment, is due to expire on 22 October 2026, considerably sooner than the operational-continuity licence just extended. The distinction matters for counterparties and correspondent banks assessing exposure: the 24 April 2027 date covers continued operation of the named Bulgarian entities, while the 22 October 2026 date governs the window within which a sale of Lukoil's foreign assets can be negotiated under US sanctions cover. A lapse of GL 131J without a resulting transaction would not, on its own, affect the operational licence's validity through April 2027, but it would narrow the near-term paths available for resolving the ownership question that the operational extension defers rather than settles.

For Bulgarian counterparties and the banks that serve them, the practical sanctions-architecture read is that the designation-adjacent extension lowers acute near-term risk for maintaining banking and payment relationships with the named entities, while the ownership uncertainty behind the original designation persists. This is a US Treasury instrument operating territorially in Bulgaria rather than a Bulgarian-originated measure, and Bulgarian institutions dealing with the named entities should track both licence numbers and their distinct expiry dates rather than treating the April 2027 extension as resolving all sanctions-related timing risk around Lukoil's Bulgarian operations.

Outlook

The near-term date to track is 22 October 2026, the expiry of General License 131J governing sale-negotiation activity, which falls well before the 24 April 2027 operational-continuity extension. Whether a transaction is reached, extended, or allowed to lapse within that negotiation window will be the clearer signal of where Lukoil's Bulgarian divestment is actually heading, since the operational extension itself defers rather than resolves that question.

domain_sub_briefs · D1 · Cumulative analysis
Standing baseline position

OFAC General License No. 130B/135 extended to authorise transactions with four named Bulgarian Lukoil entities through 24 April 2027, removing the previously scheduled 29 October 2026 expiry.

D2 Beneficial Ownership

no_changeno_changestanding position

Beneficial Ownership and Corporate Transparency

Globally, the EU AML Package sets the structural direction for beneficial-ownership and corporate-transparency supervision: three distinct instruments now govern the field across the European Economic Area — the AML Regulation (AMLR, Regulation (EU) 2024/1624), which applies directly and uniformly across Member States; the sixth AML Directive (6AMLD), which each Member State transposes into national law on its own timeline; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority and begins shifting supervision of certain obliged entities from purely national authorities toward a hybrid EU-level regime combining direct AMLA supervision of the highest-risk cross-border entities with continued indirect national supervision of the rest. This is the durable architectural backdrop against which Bulgaria's own developments this cycle should be read.

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In Bulgaria specifically, the directly relevant beneficial-ownership and corporate-transparency development this cycle is not a 6AMLD transposition milestone but a crypto-adjacent registration consolidation: the Bulgarian MiCA Act is understood to repeal the National Revenue Agency's Article 9a Anti-Money Laundering Act register of virtual-asset service providers, folding the AML-registration history of VASPs into the Financial Supervision Commission's MiCA CASP register. This is a single Tier-3-sourced, Probable-confidence finding, not yet corroborated against the MiCA Act's own statutory text, but it is properly read as an architecture-level change — the retirement of a national, AML-specific VASP register in favour of a supranationally-harmonised licensing register that itself carries AML-registration consequences — rather than as an isolated administrative footnote. Bulgaria's specific 6AMLD transposition status (whether not yet transposed, partially transposed, or fully transposed) has not been established this cycle, which limits how confidently the AMLR/6AMLD architecture described above can be tied to Bulgaria's domestic beneficial-ownership register practice specifically, as distinct from the crypto-registration consolidation, which is independently evidenced.

The practical consequence of the NRA register's repeal is that a compliance function checking a Bulgarian virtual-asset counterparty's AML-registration history can no longer rely on the legacy NRA Article 9a register as a current source; that history is now understood to sit within the FSC's MiCA CASP register instead. Because Bulgaria sits within the EEA legal bloc and is bound directly by the AMLR as an EU-27 member, the medium-term direction is toward greater harmonisation of this exact kind of registration architecture across Member States, even where the specific national implementing detail (such as which national register a given class of AML registration migrates into) is still resolving on a per-Member-State basis.

Outlook

The register-consolidation finding rests on a single Tier-3 source and has not been corroborated against the MiCA Act's own text; a future cycle that locates a primary-source confirmation, or a contradiction, of the NRA register's repeal would materially change the confidence with which this development can be reported. Separately, Bulgaria's 6AMLD transposition status remains an open gap and would clarify how far the broader EU AML Package architecture has moved from directly-applicable-regulation (AMLR) to domestically-legislated-directive (6AMLD) within Bulgaria specifically.

Judgment: No Bulgaria-specific beneficial-ownership development surfaced this cycle. Uncertain
Periodic updates (1)
11 Oct 2026 · fim-2026-10-11

Beneficial Ownership and Corporate Transparency

In Bulgaria, the directly relevant beneficial-ownership development this period is national rather than EU-level: a recent amendment to the Bulgarian Offshore Companies Act introduces exceptions from blanket offshore restrictions for entities tax-resident in treaty states, conditioned on registering the beneficial owner with the Bulgarian Commercial Register. Failure to register carries a sanction of EUR 5,000 to 25,000. This rests on a single T3 legal-commentary source; the primary State Gazette text was not retrieved this period, so the precise provision and sanction figures should be treated as probable rather than confirmed pending primary verification.

Globally, the EU AML Package sets the structural direction for beneficial-ownership transparency across the bloc: the AML Regulation (AMLR, Reg (EU) 2024/1624) is directly applicable across Member States without need for national transposition, the sixth AML Directive (6AMLD) requires Member State transposition of its beneficial-ownership-register provisions, and the AMLA Regulation (Reg (EU) 2024/1620) establishes the Anti-Money Laundering Authority, shifting supervision of cross-border obliged entities from purely national authorities toward a hybrid EU-level regime combining AMLA direct supervision of a subset of high-risk entities with indirect supervision and coordination of national authorities for the rest. For Bulgaria specifically, this period's evidence does not show a located national 6AMLD transposition instrument for the beneficial-ownership-register provisions (Articles 11-13 and 15); this is an identified gap rather than a confirmed absence of transposition.

Taken together, Bulgaria's own Commercial Register continues to operate a beneficial-ownership regime at a 25% ownership threshold, consistent with the broader EU approach, and the Offshore Companies Act amendment adds a dedicated registration condition specific to the treaty-state exception rather than changing the general threshold.

Outlook

Locating the primary State Gazette text for the Offshore Companies Act amendment would confirm the exact provision and sanction figures. Locating Bulgaria's own 6AMLD transposition instrument would clarify how the national beneficial-ownership register interacts with the broader AMLA-era EU architecture as that hybrid supervisory model comes into force.

D3 Enabler Jurisdictions

no_changeno_changestanding position

Enabler Jurisdictions

Bulgaria's National Assembly adopted at first reading, on 24 September 2026, government bill No. 52-602-01-43, creating a new Criminal Code chapter criminalising sanctions-circumvention. The bill responds directly to a European Commission infringement action brought after Bulgaria missed the May 2025 deadline for transposing Directive (EU) 2024/1226, the EU directive establishing minimum rules for criminal offences and penalties for the violation of Union restrictive measures. As drafted, the bill would expose individuals to up to ten years' imprisonment for sanctions-circumvention offences, while companies would face court-imposed pecuniary sanctions of up to EUR 40.5 million under a new provision of the Administrative Violations and Sanctions Act.

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Read through an enabler-jurisdiction lens, this bill is significant less for the novelty of the conduct it targets, which general industry practice already screens for through sanctions-exposure checks, than for the domestic enforcement-architecture gap it is designed to close. Before this bill, Bulgaria lacked a dedicated criminal offence for sanctions-circumvention, meaning that even where screening correctly identified exposure, the domestic legal toolkit for prosecuting circumvention conduct was thinner than the EU minimum standard required. That gap is precisely the kind of structural enablement risk that an enabler-jurisdiction analysis looks for: not an absence of detection capacity, but an absence of a prosecutable offence once detection occurs.

The bill, however, remains unenacted, and reported drafting weaknesses temper how much enforcement-architecture improvement it currently represents. Observers have flagged a missing breach element for dual-use-goods offences, a category of particular relevance given Bulgaria's role as a transit and manufacturing point for goods with both civilian and military application, and a travel-ban penalty set below the EU minimum standard. Until these are addressed, the bill's passage would improve Bulgaria's domestic architecture without necessarily bringing it into full alignment with the EU framework it is intended to transpose.

Outlook

The bill's progression beyond first reading, and specifically whether the dual-use-offence breach element and the below-minimum travel-ban penalty are corrected before final adoption, will determine whether Bulgaria closes the enforcement-architecture gap the European Commission's infringement action identified, or merely narrows it. No enactment date has been confirmed.

Judgment: No Bulgaria-specific enabler-jurisdiction development surfaced this cycle. Uncertain
Standing baseline position

Government bill No. 52-602-01-43 adopted at first reading on 24 September 2026, creating a new Criminal Code chapter criminalising violation/circumvention of EU restrictive measures, transposing Directive (EU) 2024/1226.

D4 Conflict Finance

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Judgment: No Bulgaria-specific conflict-finance development surfaced this cycle. Uncertain

D5 Crypto / Digital Assets / Financial Innovation

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Crypto, Digital Assets, and Financial Innovation

Bulgaria's crypto-asset regulatory architecture reached a structural cutover on 1 July 2026, specific to Bulgaria's own regulatory perimeter rather than a purely EU-level development. The Financial Supervision Commission is now the sole authority licensing crypto-asset service providers operating in or from Bulgaria, ending the prior transitional period under which entities registered with the National Revenue Agency under Article 9a of the Measures Against Money Laundering Act could continue operating without full MiCA authorisation. From the cutover date, that NRA registration basis is no longer valid: a crypto-asset service provider operating in Bulgaria must hold FSC authorisation.

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This is a jurisdiction-specific implementation event within the broader EU Markets in Crypto-Assets Regulation framework, which applies directly across the EU, but the specific mechanics, the identity of the competent authority, the prior registration basis being superseded, and the cutover date, are Bulgaria's own regulatory story rather than a restatement of the EU-wide MiCA timeline. For financial-integrity purposes, the significance is that Bulgaria's crypto sector now has a single, clearly identified licensing gatekeeper, which simplifies the question of which entities operating in Bulgaria are authorised and which are not, relative to the dual-track registration-and-licensing ambiguity that existed during the transitional period.

Globally, the EU AML Package, comprising the directly applicable AML Regulation, the sixth AML Directive's national transposition, and the AMLA Regulation establishing the Anti-Money Laundering Authority, sets the structural direction for how crypto-asset service providers will eventually be supervised across the bloc, with AMLA's emerging direct and indirect supervision perimeter shifting the balance away from purely national authorities. In Bulgaria specifically, however, the FSC's assumption of sole CASP-licensing authority is the directly relevant development this cycle, with the AMLA architecture remaining contextual backdrop rather than the operative mechanism governing Bulgarian CASPs today.

Outlook

The open question for Bulgaria's crypto sector is how the Financial Supervision Commission handles entities that were mid-application at the 1 July 2026 cutover and filed suspension plans rather than securing authorisation outright; no Bulgaria-specific enforcement precedent under the post-cutover regime has yet been identified.

Judgment: No Bulgaria-specific crypto/digital-asset AML development surfaced this cycle. Uncertain
Cumulative analysis

Crypto / Digital Assets / Financial Innovation

Bulgaria's crypto-asset regulatory architecture completed a structural transition this cycle. The Markets in Crypto-Assets Act, in force since 8 July 2025, designated the Financial Supervision Commission as the competent authority for licensing crypto-asset service providers and supervising asset-referenced tokens, while assigning supervision of electronic-money tokens to the Bulgarian National Bank. This designation repealed the National Revenue Agency's Article 9a AML-register as the operative authorisation basis for virtual-asset service providers, a genuine narrowing of what had previously been a lighter-touch registration pathway.

The eighteen-month transitional grandfathering period, under which entities registered on the legacy NRA register before 30 December 2024 could continue operating without a MiCA licence, closed on 1 July 2026. That deadline has now passed, meaning entities that had not obtained, or been refused, FSC authorisation by that date are, in principle, no longer entitled to rely on the transitional basis. This is an architecture-level finding: the closure of a grandfathering window is a structural narrowing of the regulatory perimeter, not an isolated enforcement incident, and it is consistent with the FIM analytical principle that architecture changes carry more diagnostic weight than any single enforcement action.

Evidencing that the new regime is operationally live rather than merely transposed on paper, the FSC issued Bulgaria's first MiCA crypto-asset service provider licence, to Alaric Securities, in April 2026. This finding is treated with caution: it rests on a single lower-tier vendor source with no corroborating primary or law-firm confirmation located this cycle, and confidence is assessed accordingly.

A remaining coverage gap should be stated plainly: no Tier-1 FSC or EUR-Lex primary source was directly retrieved this cycle for the MiCA/CASP designation or the grandfathering-window closure. The findings above rest on law-firm commentary (CMS Law, Wolf Theiss) and vendor-blog sourcing rather than direct regulator or EU-instrument text, and confidence tiers on the underlying claims are capped accordingly.

Outlook

The MiCA full-authorisation deadline for legacy NRA-registered VASPs sits on the regulatory horizon for the third quarter of 2026. General industry practice for legacy registrants had been to rely on the transitional grandfathering window; with that window now closed, entities that had not obtained FSC authorisation face, in principle, a compliance cliff. Watch for confirmation of any enforcement or licence-refusal action against a legacy registrant that failed to secure timely FSC authorisation, which would be the clearest incident-level test of how firmly the closure of the transitional pathway is being enforced in practice.

domain_sub_briefs · D5 · Cumulative analysis
Periodic updates (3)
25 Oct 2026 · fim-2026-10-25

Crypto, Digital Assets, and Financial Innovation

Bulgaria's crypto-asset regulatory architecture reached a structural cutover on 1 July 2026, specific to Bulgaria's own regulatory perimeter rather than a purely EU-level development. The Financial Supervision Commission is now the sole authority licensing crypto-asset service providers operating in or from Bulgaria, ending the prior transitional period under which entities registered with the National Revenue Agency under Article 9a of the Measures Against Money Laundering Act could continue operating without full MiCA authorisation. From the cutover date, that NRA registration basis is no longer valid: a crypto-asset service provider operating in Bulgaria must hold FSC authorisation.

This is a jurisdiction-specific implementation event within the broader EU Markets in Crypto-Assets Regulation framework, which applies directly across the EU, but the specific mechanics, the identity of the competent authority, the prior registration basis being superseded, and the cutover date, are Bulgaria's own regulatory story rather than a restatement of the EU-wide MiCA timeline. For financial-integrity purposes, the significance is that Bulgaria's crypto sector now has a single, clearly identified licensing gatekeeper, which simplifies the question of which entities operating in Bulgaria are authorised and which are not, relative to the dual-track registration-and-licensing ambiguity that existed during the transitional period.

Globally, the EU AML Package, comprising the directly applicable AML Regulation, the sixth AML Directive's national transposition, and the AMLA Regulation establishing the Anti-Money Laundering Authority, sets the structural direction for how crypto-asset service providers will eventually be supervised across the bloc, with AMLA's emerging direct and indirect supervision perimeter shifting the balance away from purely national authorities. In Bulgaria specifically, however, the FSC's assumption of sole CASP-licensing authority is the directly relevant development, with the AMLA architecture remaining contextual backdrop rather than the operative mechanism governing Bulgarian CASPs today.

Outlook

The open question for Bulgaria's crypto sector is how the Financial Supervision Commission handles entities that were mid-application at the 1 July 2026 cutover and filed suspension plans rather than securing authorisation outright; no Bulgaria-specific enforcement precedent under the post-cutover regime has yet been identified.

11 Oct 2026 · fim-2026-10-11

Crypto, Digital Assets, and Financial Innovation

Bulgaria's crypto-asset regulatory environment moved from a transitional period into active post-transition enforcement this period. The MiCA transitional licensing period expired on 1 July 2026; shortly afterward, on 8 October 2026, Bulgaria's Financial Supervision Commission is reported to have publicly named six websites offering unauthorised crypto-asset services and one site offering unauthorised investment services, ordering cessation within three days under the Crypto-Asset Markets Act and the Financial Supervision Commission Act. This is reported via a secondary source; the primary FSC enforcement notice was not directly retrieved this period, so the finding is treated as probable.

This enforcement sequence is the clearest Bulgaria-specific financial-innovation signal this period and should be read as evidence of active post-transition supervisory follow-through rather than a one-off action, pending confirmation of whether further sweeps occur. Separately, Sofia-based payments fintech Paypercut closed a EUR 5 million seed round on 3 June 2026, targeting an Irish EMI licence and stablecoin-based cross-border settlement rails for Central and Eastern European corridors; while Paypercut is a payments rather than a crypto-native firm, its stablecoin-rail ambitions place it within the broader financial-innovation perimeter this domain tracks, and its choice of an Irish rather than Bulgarian licensing route is itself a data point on where regulatory friction is perceived to be lower.

Outlook

Whether the FSC's 8 October enforcement action repeats in a subsequent period is the clearest marker of whether Bulgaria's post-MiCA-transition enforcement posture is sustained. Paypercut's progress toward its targeted Irish EMI licence and the development of its stablecoin-based CEE settlement rails are a secondary marker worth tracking for cross-border payment-innovation signal.

28 Sep 2026 · fim-2026-09-28

Crypto, Digital Assets, and Financial Innovation

In Bulgaria, the directly relevant digital-asset development this cycle is the expiry, on 1 July 2026, of MiCA CASP authorisation grandfathering for legacy National Revenue Agency-registered virtual-asset providers. Before that date, providers that had held NRA registration under Bulgaria's prior virtual-asset regime could continue operating on a transitional basis while migrating to authorisation from the Financial Supervision Commission (for asset-referenced tokens and crypto-asset service providers generally) or the Bulgarian National Bank (for electronic money tokens). After 1 July 2026, that transitional bridge closed, and continued operation without completed MiCA CASP authorisation now falls outside the lawful perimeter and constitutes a MiCA compliance breach.

Globally, the MiCA framework and FATF's virtual-asset standards set the structural direction for how crypto-asset activity is brought within AML/CFT-relevant supervision; in Bulgaria, the transitional grandfathering cliff-edge is the concrete mechanism through which that structural direction is being enforced against the specific population of legacy-registered providers. The grandfathering cliff-edge creates a residual population of potentially unauthorised legacy VASPs pending confirmation against the FSC register — a finding assessed at Probable confidence, given that it rests on legal-commentary sourcing (CMS, Eternity Law) rather than a primary FSC publication confirming which specific legacy providers did or did not complete the transition in time.

This residual-population question is the single most consequential open item in Bulgaria's crypto/digital-asset financial-integrity exposure this cycle. A compliance function assessing exposure to Bulgarian virtual-asset counterparties should treat legacy NRA registration, standing alone, as no longer sufficient evidence of current lawful operating status; only confirmed FSC CASP authorisation (or BNB authorisation for EMT issuers) now supports that assurance. Whether any specific legacy provider in fact failed to transition, and what enforcement or de-registration consequence followed if so, has not been confirmed against the FSC's own register this cycle.

Outlook

The outlook for this domain turns entirely on primary-source confirmation from the Financial Supervision Commission's own register: a future cycle that surfaces the FSC's transitional-completion statistics, or any enforcement or removal action taken against a legacy provider that failed to transition, would resolve the current residual-population uncertainty. Absent that confirmation, the domain should continue to be tracked as a structural cliff-edge with an unconfirmed real-world application, rather than as a settled compliance picture.

D6 Compliance Technology & Active Defence

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Judgment: No RegTech/compliance-technology development surfaced for Bulgaria this cycle; D6 is exempt from the substantive-finding floor. Uncertain

D7 AML/CTF Regime

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AML/CTF Regime

Bulgaria's AML/CTF regime moved from grey-listed to normal-monitoring status with FATF's removal of the country from its list of jurisdictions under increased monitoring on 30 October 2026, following the 28-30 October Plenary. FATF's own statement records that Bulgaria strengthened the effectiveness of its AML/CFT regime to meet the commitments set out in its action plan, a determination reached through on-site verification rather than desk review alone. The specific remediation items cited include completion of technical-compliance deficiencies identified at the time of the original October 2023 listing, the rollout of risk-based supervision over postal money operators, currency-exchange providers and real-estate agents, and the introduction of market-entry controls for virtual-asset service providers and postal money operators. MONEYVAL, the FATF-style regional body with direct mutual-evaluation responsibility for Bulgaria, issued its own statement welcoming the decision, giving the finding independent corroboration beyond FATF's own Plenary communique.

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This is the baseline-descriptive record of a standing regime status change rather than a single enforcement episode, and it should be weighted accordingly: it reflects a multi-year programme of supervisory build-out across several previously under-regulated sectors, not a one-off intervention. MONEYVAL's confirmation that it will continue working with Bulgaria to sustain the improvements signals that supervisory engagement continues notwithstanding the delisting, which is consistent with the three-pillar expectation that AML gains be tested for durability through ongoing follow-up rather than treated as self-executing once a Plenary vote is taken.

Outlook

The pending publication of MONEYVAL's enhanced follow-up report, expected in the fourth quarter of 2026 after quality-and-consistency review, will provide the detailed Recommendation-by-Recommendation re-rating that the current public record lacks. Firms maintaining AML/CTF risk assessments referencing Bulgaria's grey-list history should treat the 30 October 2026 removal as the operative status change now, while awaiting that fuller report before recalibrating control-level detail such as customer due diligence intensity for Bulgarian counterparties.

Judgment: Bulgaria's FATF delisting is the baseline-descriptive record of the standing AML/CTF regime moving from grey-listed to normal-monitoring status, pending MONEYVAL's full enhanced follow-up report expected December 2026. Probable
Cumulative analysis

AML/CTF Regime

Bulgaria's AML/CTF architecture received a materially positive assessment this cycle. MONEYVAL's 17 June 2026 enhanced follow-up report formally closed Bulgaria's 5th-round mutual evaluation, rating all 40 FATF Recommendations as compliant or largely compliant. This closure followed demonstrated improvement in technical compliance across eight further Recommendations: confiscation, the terrorist-financing offence, proliferation-financing-related targeted financial sanctions, non-profit organisations, correspondent banking, sanctions, and mutual legal assistance. The evaluation cycle being closed had run since April 2022, so this represents the conclusion of a multi-year monitoring process rather than a single-cycle event, an architecture-level finding consistent with the FIM principle of weighting structural findings over isolated incidents.

The source underlying this finding is a direct primary publication from the Council of Europe / MONEYVAL, and confidence is rated Confirmed, the highest tier available. The overall jurisdictional risk direction on the AML/CTF dimension is assessed as decreasing as a direct consequence of the clean evaluation closure. This should be read as a positive structural signal for Bulgaria's obliged-entity ecosystem: a jurisdiction that has closed out its mutual evaluation with full compliance or largely-compliant ratings across all 40 Recommendations presents a materially lower architecture-level AML/CTF risk profile than one still under active monitoring for outstanding deficiencies.

Bulgaria's national AML implementing instrument, the Measures Against Money Laundering Act, was positively assessed within MONEYVAL's June 2026 follow-up, though no BG-specific development regarding the EU AML Package's supervisory-perimeter shift (AMLA direct or indirect supervision) surfaced independently this cycle beyond what is captured in the mutual-evaluation closure itself.

Outlook

With the 5th-round mutual evaluation now closed, the near-term AML/CTF outlook for Bulgaria is one of consolidation rather than active monitoring pressure. The improvement across eight further FATF Recommendations addressed specific technical-compliance gaps that had been outstanding since the original evaluation; the principal item to watch going forward is whether Bulgaria maintains this compliance trajectory as EU-level AML Package instruments, including AMLA's supervisory perimeter, phase in across the bloc, which would be the next structural test of the architecture just confirmed as sound by MONEYVAL.

domain_sub_briefs · D7 · Cumulative analysis
Standing baseline position

Not subject to FATF increased monitoring as of 30 October 2026; prior listing dated October 2023.

Periodic updates (5)
3 Nov 2026 · fim-2026-11-03

AML/CTF Regime

Bulgaria's removal from the Financial Action Task Force list of jurisdictions under increased monitoring, confirmed at the Plenary of 28-30 October 2026, is the defining AML/CTF development of this cycle. The FATF statement attributes the decision to Bulgaria having strengthened the effectiveness of its AML/CFT regime to meet the commitments of its action plan; this is a judgment about effectiveness of implementation, not merely the existence of legislation, and it follows on-site verification rather than a desk review alone. MONEYVAL, the Council of Europe body responsible for Bulgaria's mutual-evaluation and follow-up process, issued its own statement welcoming the FATF decision and confirming it will continue engaging with Bulgarian authorities to sustain the improvements achieved to date.

The architecture behind this outcome matters more than the single Plenary vote. Grey-listing and delisting decisions are the product of a sustained, multi-year action-plan process in which a jurisdiction commits to specific, sequenced reforms across its legal framework, supervisory practice, and enforcement record, and is then subject to on-site verification before the FATF will certify the commitments as met. The FATF statement specifically references risk-based supervision of postal money operators, currency-exchange providers, and real-estate agents, together with market-entry controls for virtual-asset service providers, as areas where Bulgaria demonstrated the required effectiveness. That breadth, spanning traditional money-services businesses, a designated non-financial business and profession category, and the newer virtual-asset sector, indicates the action plan touched multiple supervisory perimeters rather than a single narrow fix.

For institutions and counterparties that apply FATF list status as an automatic input into their own risk-based due-diligence frameworks, removal eliminates the categorical trigger for enhanced treatment that attached specifically to grey-list membership. It does not retroactively erase caution accumulated by individual correspondent banks or compliance functions over the monitoring period, and those institutional risk assessments will adjust, if at all, on their own separate timelines and criteria. The distinction is between a list-driven categorical trigger, which has now been removed, and an institution's own accumulated risk view, which is a separate and slower-moving thing.

Three-pillar balance is worth noting explicitly here: the public record so far speaks primarily to the AML dimension of the action plan, through references to money-services and real-estate supervision and VASP market entry. The FATF statement itself is framed around AML/CFT effectiveness broadly, which by the FATF's own standard-setting architecture encompasses counter-terrorist-financing and counter-proliferation-financing elements of the same Recommendation framework, but no distinct CTF or CPF-specific development was separately surfaced beyond the general effectiveness finding. That absence of granular CTF/CPF detail in the public materials should not be read as those pillars being weaker; the fuller picture waits on the Recommendation-by-Recommendation ratings described below.

Outlook

The next material checkpoint is MONEYVAL's enhanced follow-up report, specifically described in the regulatory horizon as the third enhanced follow-up report under the fifth-round mutual-evaluation cycle, expected in the fourth quarter of 2026 as scheduled following the organisation's internal quality-review process. That report, once published, will set out Bulgaria's current Recommendation-by-Recommendation compliance ratings, replacing the current public record, which consists only of the summary delisting statement from the Plenary and MONEYVAL's accompanying welcome. Until that fuller report lands, the delisting itself is the confirmed, dated fact in hand: a FATF Plenary decision of 30 October 2026, corroborated by the jurisdiction's own mutual-evaluation body. Analytically, the open question going forward is whether the effectiveness gains credited by FATF prove durable under MONEYVAL's continuing engagement, and whether correspondent-banking and onboarding practice for Bulgarian institutions measurably adjusts in response to the change in categorical list status, a behavioural question that sits outside the FATF decision itself and will need to be tracked separately as practice data becomes available.

25 Oct 2026 · fim-2026-10-25

AML/CTF Regime

MONEYVAL, the Council of Europe's mutual-evaluation body for money-laundering and terrorist-financing standards, published its third enhanced follow-up report on Bulgaria on 17 June 2026. The report re-rated eight FATF Recommendations and found Bulgaria compliant or largely compliant on all 40 FATF Recommendations, a result that closed the enhanced follow-up process opened after Bulgaria's Fifth Round mutual evaluation. Reaching full compliant-or-largely-compliant status across all 40 Recommendations is a structural endpoint for a jurisdiction's AML/CFT technical-compliance track record, distinct from and more durable than any single enforcement action, and it reflects sustained legal-framework improvement across the recommendations originally rated partially or non-compliant.

This AML/CFT technical-compliance closure sits alongside two other developments that bear on Bulgaria's broader financial-crime architecture without being AML/CTF findings in their own right: the advancing sanctions-circumvention Criminal Code bill, which addresses a cross-pillar enforcement-architecture gap identified by a European Commission infringement action, and the completed MiCA crypto-licensing cutover, which consolidates crypto-asset service provider authorisation under the Financial Supervision Commission. None of these displaces the MONEYVAL finding as the primary AML/CTF-regime signal, but together they describe a jurisdiction whose core AML/CFT legal framework has been assessed as largely sound while adjacent enforcement and licensing architecture continues to be built out.

No Bulgaria-specific AML/CTF enforcement action, such as a financial institution penalty or a suspicious-transaction-reporting failure finding, was identified. The MONEYVAL result speaks to the adequacy of Bulgaria's legal framework as assessed by an international mutual-evaluation body; it does not itself constitute evidence of how that framework performs in live enforcement.

Outlook

With the Fifth Round enhanced follow-up process now closed, the next formal assessment point for Bulgaria's AML/CTF framework would be a future mutual-evaluation round; no date for that has been identified. In the interim, the practical test of the framework MONEYVAL assessed as compliant will be whichever enforcement actions, if any, Bulgarian authorities bring under it.

18 Oct 2026 · fim-2026-10-18

AML/CTF Regime

MONEYVAL, the Council of Europe's mutual-evaluation body for money-laundering and terrorist-financing standards, published its third enhanced follow-up report on Bulgaria on 17 June 2026. The report re-rated eight FATF Recommendations and found Bulgaria compliant or largely compliant on all 40 FATF Recommendations, a result that closed the enhanced follow-up process opened after Bulgaria's Fifth Round mutual evaluation. Reaching full compliant-or-largely-compliant status across all 40 Recommendations is a structural endpoint for a jurisdiction's AML/CFT technical-compliance track record, distinct from and more durable than any single enforcement action, and it reflects sustained legal-framework improvement across the recommendations originally rated partially or non-compliant.

This AML/CFT technical-compliance closure sits alongside two other developments this cycle that bear on Bulgaria's broader financial-crime architecture without being AML/CTF findings in their own right: the advancing sanctions-circumvention Criminal Code bill, which addresses a cross-pillar enforcement-architecture gap identified by a European Commission infringement action, and the completed MiCA crypto-licensing cutover, which consolidates crypto-asset service provider authorisation under the Financial Supervision Commission. None of these displaces the MONEYVAL finding as the primary AML/CTF-regime signal this cycle, but together they describe a jurisdiction whose core AML/CFT legal framework has been assessed as largely sound while adjacent enforcement and licensing architecture continues to be built out.

No Bulgaria-specific AML/CTF enforcement action, such as a financial institution penalty or a suspicious-transaction-reporting failure finding, was identified this cycle. The MONEYVAL result speaks to the adequacy of Bulgaria's legal framework as assessed by an international mutual-evaluation body; it does not itself constitute evidence of how that framework performs in live enforcement.

Outlook

With the Fifth Round enhanced follow-up process now closed, the next formal assessment point for Bulgaria's AML/CTF framework would be a future mutual-evaluation round; no date for that has been identified this cycle. In the interim, the practical test of the framework MONEYVAL assessed as compliant will be whichever enforcement actions, if any, Bulgarian authorities bring under it.

11 Oct 2026 · fim-2026-10-11

AML/CTF Regime

Bulgaria's AML/CTF standing improved materially this period. MONEYVAL's follow-up report, adopted and published 17 June 2026, formally closed Bulgaria's 5th-round mutual evaluation, finding the country compliant or largely compliant with all 40 FATF Recommendations, including Recommendations 6, 10, 24, 28 and 34. This is a Confirmed finding sourced directly from MONEYVAL's own Tier-1 published committee statement.

Building on that closure, Bloomberg reporting, carried via the Bulgarian Telegraph Agency, indicates Bulgaria is expected to be removed from the FATF list of jurisdictions under increased monitoring at the plenary concluding 30 October 2026, alongside Monaco and Cote d'Ivoire. This reporting characterises discussions among people familiar with the matter rather than an FATF statement itself; as of FATF's own statement of 19 June 2026, Bulgaria remained listed among 22 jurisdictions under increased monitoring. The reported removal should therefore be read as probable, grounded in the MONEYVAL closure as a plausible precondition, but not yet confirmed by FATF's own plenary outcome.

Separately, the EU AML Package's 6AMLD beneficial-ownership-register transposition provisions were due EU-wide by 10 July 2026; Bulgaria's own transposition instrument for those provisions was not located within this period's evidence base, leaving open whether Bulgaria has completed that specific transposition step alongside its broader MONEYVAL-evaluated compliance.

Outlook

The FATF plenary concluding 30 October 2026 is the clearest near-term marker: a primary FATF statement confirming Bulgaria's removal from the list of jurisdictions under increased monitoring would convert this period's probable reporting into a confirmed structural change in Bulgaria's international AML standing. Locating Bulgaria's own 6AMLD transposition instrument remains a secondary open item.

28 Sep 2026 · fim-2026-09-28

AML/CTF Regime

Bulgaria's AML/CTF regime record strengthened materially this cycle with MONEYVAL's closure of the country's 5th-round mutual evaluation on 17 June 2026. All 40 FATF Recommendations are now rated compliant or largely compliant, following a re-rating exercise that specifically addressed confiscation, the terrorist-financing offence, proliferation-related targeted financial sanctions, non-profit-organisation oversight, correspondent banking, sanctions implementation, and mutual legal assistance. This closure ends an enhanced follow-up process that had run since the May 2022 mutual evaluation report identified technical-compliance deficiencies across several of these same areas.

The closure is assessed at Confirmed confidence, resting on Tier-1 sourcing directly from the Council of Europe / MONEYVAL and corroborated by FATF's own published follow-up materials. This is architecture-level good news: it reflects a multi-year remediation process across a broad range of FATF Recommendations reaching completion, rather than a single enforcement action or episodic event. Bulgaria is not on the FATF grey list, and the MONEYVAL closure removes what had been a standing item of supervisory and peer-review attention across multiple prior reporting cycles.

Set against this improving headline, two structural gaps remain in the evidence base. First, Bulgaria's specific 6AMLD transposition status — whether the directive has been fully transposed, partially transposed, or not yet transposed into national law — has not been established this cycle, notwithstanding that Bulgaria is bound directly by the AMLR as an EU-27 member state. Second, no BG-specific sanctions-evasion, enabler-jurisdiction, conflict-finance, or compliance-technology signal was located this cycle, reflecting that this dispatch was scoped exclusively to Bulgaria and did not run a standing multi-jurisdiction sweep across those adjacent domains; this is a scoping limitation on this cycle's coverage, not a finding that those risks are absent.

The crypto-adjacent AML registration consolidation — repeal of the NRA's Article 9a AML register in favour of the FSC's MiCA CASP register — sits alongside this cycle's core AML/CTF regime finding as a second, narrower architecture shift specific to the virtual-asset sector, distinct from the broader MONEYVAL-evaluated regime.

Outlook

With the MONEYVAL 5th-round evaluation closed and all 40 Recommendations rated compliant or largely compliant, the near-term outlook on Bulgaria's core AML/CTF regime is stable-to-positive absent a new FATF or MONEYVAL finding. The 6AMLD transposition-status gap is the most likely source of a future material development, as is any confirmation of how the crypto-sector AML-registration consolidation interacts with the broader regime evaluated by MONEYVAL.

D8 Commercial Activity

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Commercial Activity

Sofia-based payments fintech Paypercut closed a EUR 5 million seed round on 3 June 2026, co-led by Concentric, Passion Capital and Araya Ventures, bringing its total funding to date to EUR 7 million. The round is intended to fund pursuit of an Irish EMI licence and the build-out of stablecoin-based cross-border settlement rails for Central and Eastern European corridors. The event is corroborated across a press release and multiple trade outlets, though it rests on commercial reporting rather than a primary regulatory filing.

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The commercial significance for Bulgaria's financial-integrity picture is twofold: first, Paypercut represents continuing fintech investment activity originating from Bulgaria even as the company's chosen regulatory home for its EMI licence is Ireland rather than Bulgaria, a data point worth noting when assessing comparative regulatory attractiveness within the region; second, its stablecoin-rail ambitions place a Bulgaria-originated firm within the broader EU financial-innovation and cross-border settlement space that this domain, and the crypto/digital-assets domain, both track from different angles.

Outlook

Whether Paypercut secures its targeted Irish EMI licence, and the pace at which its stablecoin-based CEE settlement rails come into operation, are the clearest markers to track from a commercial-activity perspective in subsequent periods.

Judgment: No financial-integrity-sector commercial event identified for Bulgaria this cycle. Uncertain
Regulatory horizon
Adopted2026-Q4 · ±quarter

MONEYVAL enhanced follow-up report on Bulgaria

Publication of the full follow-up report will set out Bulgaria's current Recommendation-by-Recommendation compliance ratings in detail, beyond the Plenary's summary findings.
Source
Adopted2026-Q4 · ±quarter

MONEYVAL enhanced follow-up report on Bulgaria

Publication of the full follow-up report will set out Bulgaria's current Recommendation-by-Recommendation compliance ratings.
MONEYVAL Source
Adopted2028 · ±multi_year

AMLA direct supervision of selected obliged entities (first cohort)

AMLA begins direct supervision of a first cohort of high-risk cross-border obliged entities, shifting supervisory perimeter from purely national to hybrid EU-level regime; Bulgaria's first AMLA-selection round occurs in 2027 ahead of 2028 supervision start.
Source
3 dated · 4 pending date · baseline fim-2026-07-09
Role action cards
MLRO

Bulgaria exited FATF increased monitoring on 30 October 2026, changing the baseline jurisdiction-risk input for Bulgarian counterparties.

The systemic basis for applying enhanced scrutiny keyed to grey-list status no longer applies to Bulgaria as of the Plenary decision. The fuller Recommendation-level detail underpinning this change is not yet public, so the basis for any downgrade in due-diligence intensity remains at summary level pending MONEYVAL's follow-up report.

3 evidence refs
Compliance

Bulgaria's regulatory-change status moved from grey-listed to normal FATF monitoring following confirmed remediation of supervisory gaps.

The remediation basis cited by FATF, covering VASP and postal-money-operator market entry controls and risk-based supervision of currency-exchange and real-estate sectors, indicates a structural control-framework upgrade in Bulgaria rather than an isolated action. Policies referencing Bulgaria's prior grey-list status warrant review against this change.

2 evidence refs
Legal

No new sanctions-nexus or enforcement-trajectory development attaches specifically to Bulgaria this cycle beyond the FATF status change.

The FATF delisting is a systemic regulatory-standing change rather than a liability or enforcement-exposure event; it bears on client-jurisdiction risk framing rather than direct legal liability.

2 evidence refs
Board

Bulgaria's removal from the FATF increased-monitoring list is a material, structural improvement in the institution's jurisdiction-risk exposure to Bulgaria.

This is a strategic-level regulatory change rather than an incident, reflecting a multi-year remediation programme confirmed by both FATF and MONEYVAL. The fuller technical-compliance detail remains pending, so this should be read as a positive but not yet fully substantiated structural shift.

3 evidence refs
CTO

No material change for this persona this cycle.

No material change for this persona this cycle

Risk

Bulgaria's jurisdiction risk direction is assessed as improving, reflecting a structural rather than episodic remediation of AML/CFT supervisory gaps.

The shift from enforcement-triggered monitoring to normal status reduces the concentration of jurisdiction-risk exposure previously assigned to Bulgaria, though the absence of the full Recommendation-level follow-up report introduces a residual gap pending Q4 2026 publication.

2 evidence refs
Operations

No new transaction-monitoring or screening-threshold change is indicated for Bulgaria this cycle beyond the general FATF status update.

Screening lists keyed to FATF increased-monitoring status should be updated to reflect Bulgaria's removal as of 30 October 2026, but no new operational typology or threshold change has been identified to accompany it.

1 evidence refs
Audit

The evidentiary basis for Bulgaria's FATF status change is currently a summary Plenary finding, with full Recommendation-level detail pending.

Audit trails referencing Bulgaria's jurisdiction risk rating should note that the current public record supporting the improved status is a summary statement; the Recommendation-by-Recommendation substantiation is expected only once MONEYVAL's enhanced follow-up report is published in the fourth quarter of 2026.

2 evidence refs
Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo material BG-specific sanctions-evasion signal this cycle.
T2 · EU AML Package / AMLAno_changeNo BG-specific AMLR/6AMLD/AMLA development this cycle beyond the FATF/MONEYVAL delisting captured under T3/D7.
T3 · FATF Grey ListimprovingBulgaria removed from the FATF grey list (increased monitoring) on 30 October 2026, following the October 2026 Plenary and completion of its action plan.
T4 · Beneficial-Ownership Register Statusno_changeNo BG-specific beneficial-ownership register development this cycle.
T5 · Crypto & Digital-Asset Integrityno_changeNo new BG VASP/CASP sanctions-evasion or DeFi-enforcement signal this cycle.
T6 · Sanctions Regime Divergenceno_changeNo BG-specific EU/US/UK autonomous-listing divergence signal this cycle.
Registers

Enforcement actions

  • 14 Nov 2025
  • 14 Apr 2026
  • 1 Jul 2026
  • 19 Jun 2026
  • 25 Feb 2026
  • Bulgaria appointed the head of its tax agency as external administrator over Lukoil's Neftohim Burgas refinery and the company's 220-station retail chain to keep fuel supply stable after OFAC's Rosneft/Lukoil SDN designation threatened to disrupt operations. 14 Nov 2025
  • OFAC issued Russia-related General License 130 (Nov 14, 2025), later amended as GL130A (Apr 14, 2026), specifically authorizing transactions involving named Lukoil entities in Bulgaria that would otherwise be prohibited following the Lukoil SDN designation. 14 Apr 2026
  • Eight suspects, including a public official, were detained and eight search warrants executed after an investigation found a network used shell companies and fabricated employment contracts to fraudulently secure nearly EUR1 million in EU employment subsidies. 1 Jul 2026
  • At its June 2026 Plenary, the FATF made an initial determination that Bulgaria has substantially completed its grey-list action plan, following successive Follow-Up Report re-ratings upgrading multiple Recommendations from Partially Compliant to Largely Compliant or Compliant. 19 Jun 2026
  • Litasco, Lukoil's Geneva-based trading arm and majority shareholder in the Burgas refinery, formally challenged Bulgaria's November 2025 seizure of its local assets and signalled readiness to pursue litigation if no resolution is reached. 25 Feb 2026

Sanctions changes

  • 22 Oct 2025
  • 14 Apr 2026
  • 17 Jun 2026
  • 13 Feb 2026
  • OFAC designated Rosneft and Lukoil (and subsidiaries) as Specially Designated Nationals under the Russian Harmful Foreign Activities Sanctions program in October 2025, directly implicating Lukoil's Bulgarian refining and retail operations. 22 Oct 2025
  • OFAC issued and subsequently amended Russia-related General License 130/130A, authorizing continued transactions with named Lukoil entities located in Bulgaria notwithstanding the parent-company SDN designation. 14 Apr 2026
  • Bulgaria's government indicated it will oppose the inclusion of Russian Orthodox Patriarch Kirill in a new EU sanctions package targeting Russia, breaking with the emerging EU consensus position. 17 Jun 2026
  • HM Treasury's February 2026 High-Risk Third Countries Advisory Notice lists Bulgaria among jurisdictions UK firms must treat as a 'High-Risk Third Country' under Regulation 33 of the MLRs, since the UK's post-2024 regime ties HRTC status directly to the live FATF grey/black lists. 13 Feb 2026

Regulatory horizon (register)

  • AMLA direct supervision of selected obliged entities (first cohort)
  • MiCA full-authorisation deadline for legacy NRA-registered VASPs
  • MiCA full-authorisation deadline for legacy NRA-registered VASPs
  • BG MiCA Act CASP transitional-period expiry
  • Criminal Code chapter criminalising EU sanctions-circumvention
  • FATF plenary decision on Bulgaria's grey-list exit
  • MONEYVAL enhanced follow-up report on Bulgaria
  • MONEYVAL enhanced follow-up report on Bulgaria
  • FATF on-site assessment and possible grey-list exit decision
  • EU AML Regulation (AMLR) becomes directly applicable
  • 6AMLD national transposition deadline for Bulgaria
  • End of mandatory lev/euro dual price display
  • AMLA first harmonised selection of directly-supervised obliged entities

Active schemes

  • [CRITICAL] Neftohim Burgas Russian-oil refining/export laundromat
  • [HIGH] Shell-company layering for EU subsidy and fund fraud
  • Bulgaria-based staffing in transnational crypto investment-scam rings
Sources
  1. Page 1 of 5 HM Treasury Advisory Notice: Changes to the FATF’s Public Lists
  2. Council of Europe
  3. CMS Law
  4. Wolf Theiss
  5. Innovires
  6. O2K
  7. Насоки за банките относно превенция на изпирането на пари и финансирането на тероризма и финансирането на пролиферацията, във връзка с извършването на дейности с виртуални активи (криптоактиви)
  8. Годишен отчет за дейността на КФН за 2025 г.
  9. КФН взе решение за спазване на насоки за противодействието на изпирането на пари и финансирането на тероризма
  10. Закон за пазарите на криптоактиви (ДВ, бр. 54 от 4.7.2025 г.)
  11. https://www.coe.int/en/web/moneyval/-/bulgaria-has-improved-its-legal-framework-to-prevent-money-laundering-and-terrorist-financing-says-council-of-europe-s-moneyval-committee
  12. https://www.fatf-gafi.org/en/publications/Mutualevaluations/Bulgaria-FUR-2025.html
  13. https://www.innovires.com/en/blog/mica-crypto-regulation-bulgaria.html
  14. https://www.eternitylaw.com/news/crypto-license-in-bulgaria/
  15. https://streamlinefeed.co.ke/news/monaco-bulgaria-ivory-coast-set-to-exit-fatf-grey-list
  16. https://www.bta.bg/en/news/economy/1205393-bulgaria-expected-to-exit-fatf-grey-list-by-end-of-october-bloomberg-reports
  17. https://cms.law/en/bgr/legal-updates/bulgarian-offshore-companies-act-amendment-seeks-to-ease-restrictions
  18. https://burgasmedia.com/amp/news/kfn-posochi-shest-sayta-koito-predlagat-kriptouslugi-bez-razreshenie?lang=en
  19. https://therecursive.com/bulgarian-fintech-paypercut-raises-eur5m-to-expand-its-payments-platform-across-cee/
  20. https://ofac.treasury.gov/media/937241/download?inline=
  21. https://www.novinite.com/articles/241096/US+Extends+Lukoil+Exemption+in+Bulgaria+Until+April+2027
  22. https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Mutualevaluations/bulgaria-fur-2026.html
  23. https://www.wolftheiss.com/insights/bulgaria-advances-criminal-and-administrative-enforcement-of-eu-sanctions/
  24. https://www.fsc.bg/en/from-july-1-only-licensed-companies-may-offer-crypto-assets-within-the-eu/
  25. Innovires
  26. FATF
  27. Bulgarian Telegraph Agency (BTA)
  28. Kyckr
  29. Financial Supervision Commission (publishing MAMLA text)
  30. Fibank (First Investment Bank) via EQS-News
  31. FATF
  32. FATF
  33. Council of Europe
  34. Jurisdictions under Increased Monitoring - 19 June 2026
  35. Jurisdictions under Increased Monitoring - 13 February 2026
  36. Bulgaria
  37. "Black and grey" lists
  38. Mutual Evaluation of Bulgaria
  39. Jurisdictions under Increased Monitoring - 21 February 2025
  40. Jurisdictions under Increased Monitoring - 24 October 2025
  41. Jurisdictions under Increased Monitoring - 13 June 2025
  42. Jurisdictions under Increased Monitoring - June 2024
  43. Countries / Jurisdictions
  44. Bulgaria's progress in strengthening measures to tackle money laundering and terrorist financing
  45. 1 Anti-money laundering and counter-terrorist financing measures Bulgaria
  46. Bulgaria's measures to combat money laundering and terrorist financing
  47. Enhancing the capabilities for risk-based AML supervision and financial intelligence in Bulgaria - European Commission
  48. bg0103-07-money laundering - European Union
  49. Mutual Evaluation of Bulgaria
  50. Sanctions Programs and Country Information | Office of Foreign Assets Control
  51. Balkans-Related Sanctions | Office of Foreign Assets Control
  52. Issuance of New and Amended Russia-related General Licenses | Office of Foreign Assets Control
  53. UK sanctions high profile Bulgarian figures involved in corruption - GOV.UK
  54. Global Magnitsky Designations | Office of Foreign Assets Control
  55. US Sanctions Bulgarian Oligarchs, Public Officials for Corruption | OCCRP
  56. Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control
  57. Issuance of Amended Executive Order Taking Additional Steps with Respect to the Situation in the Western Balkans | Office of Foreign Assets Control
  58. 1 Financial Sanctions Notice 10/02/2023 Global Anti-Corruption Introduction
  59. Office of Foreign Assets Control U.S. Department of the Treasury
  60. Bulgaria Seizes Refinery Before US Sanctions Hit Russia’s Lukoil - Bloomberg
  61. Russian oil in EU soil | Global Witness
  62. DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL
  63. Russian Oil Loophole - EU's contribution to the Kremlin | Global Witness
  64. Bulgaria Bans Russian Oil in Blow to Lukoil Refinery - Bloomberg
  65. Bulgaria to End Russian Oil Imports As Lukoil Considers Refinery Sale - Bloomberg
  66. Eastern Europe Newsletter: Tussle Over Russian Oil Refinery Heats Up in Bulgaria - Bloomberg
  67. Lukoil’s Litasco Disputes Bulgaria’s Seizure of Its Assets
  68. Diesel Prices Jump on Russia Sanctions and Refinery Outages - Bloomberg
  69. Anti-money laundering and countering the financing of terrorism at EU level - Finance
  70. Bulgaria opens public consultation on new international protection law which addresses integration - Migration and Home Affairs
  71. Anti-money laundering and countering the financing of terrorism legislative package - Finance
  72. Anti-money laundering directive V (AMLD V) - transposition status | European Commission
  73. 1 Anti-money laundering and counter-terrorist financing measures Bulgaria
  74. Anti-money laundering: Council and Parliament strike deal on stricter rules - Consilium
  75. FAQs - Authority for Anti-Money Laundering and Countering the Financing of Terrorism
  76. Anti-money laundering: Council adopts package of rules - Consilium
  77. Bulgaria - Reform Support - European Commission
  78. NIS2 Directive implementation in Bulgaria | Shaping Europe’s digital future
  79. Guide to setting up your company in Bulgaria
  80. European e-Justice Portal - Business registers in EU countries
  81. Frequently Asked Questions | OCCRP
  82. Patchy progress in beneficial ownership registers in the EU | Global Witness
  83. Directory of Open-Source Registries: Bulgaria
  84. Beneficial Ownership Registers Interconnection System
  85. European e-Justice Portal - Beneficial ownership registers interconnection system (BORIS)
  86. Bulgaria SME rules - VAT rules for small enterprises – SME scheme
  87. AVAILABILITY OF COMPANY BENEFICIAL OWNERSHIP ...
  88. Bulgarian Chamber of Commerce and Industry - IP Helpdesk
  89. Bulgaria adopts euro as of 1 January 2026 | Access2Markets
  90. Bulgaria ready to use the euro from 1 January 2026: Council takes final steps - Consilium
  91. Bulgaria and the euro - Economy and Finance - European Commission
  92. Overseas business risk: Bulgaria - GOV.UK
  93. Anti-money laundering and countering the financing of terrorism at international level - Finance
  94. Questions and answers on Bulgaria\'s changeover to the euro
  95. What Is a VASP? Virtual Asset Service Provider - Chainalysis
  96. Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs
  97. Virtual Assets
  98. Virtual Asset Service Provider (VASP): Definition, Compliance & Examples
  99. The Importance of Knowing Your VASP in AML Compliance
  100. VASP Screening & Due Diligence | Elliptic Discovery
  101. Entity Due Diligence & VASP Screening | Elliptic
  102. Updated-Guidance-VA-VASP.pdf
  103. Crypto Due Diligence & VASP Tracking from Elliptic
  104. Special Measures | FinCEN.gov
  105. Enforcement Actions | FinCEN.gov
  106. Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Countering the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
  107. Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  108. Bulgaria Detains 8 in EU Subsidy Fraud Probe | OCCRP
  109. Scam Empire: Inside A Merciless International Investment Scam | OCCRP
  110. Bulgaria Loses EU Money Because of OC | OCCRP
  111. 3 Arrested in Bulgaria for US Money Laundering Scam | OCCRP
  112. All Investigations | OCCRP
  113. Bulgarian Police Take Down Online Investment Scam Network | OCCRP
  114. Bulgaria: Joint Operation Dismantles Laundering Ring | OCCRP
  115. Bulgaria: Asset Seizure? | OCCRP
  116. EU Prosecutor Investigates Embezzlement of EU Funds in Bulgaria | OCCRP
  117. Global Magnitsky Designations | Office of Foreign Assets Control
  118. CONSOLIDATED LIST OF FINANCIAL SANCTIONS TARGETS IN THE UK
  119. FCDO - UK Sanctions List Search - GOV.UK
  120. Global Magnitsky Sanctions | Office of Foreign Assets Control
  121. Bulgaria to Oppose EU Sanctions on Russian Patriarch Kirill, Minister Says - Bloomberg
  122. Magnitsky Sanctions | Office of Foreign Assets Control
  123. Bulgaria loses EU money | OCCRP
  124. Euro Aspirant Bulgaria Sees Exit From Watchdog’s ‘Gray List’ - Bloomberg
  125. High-risk and other monitored jurisdictions
  126. ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK
  127. HM Treasury Advisory Notice: High Risk Third Countries - GOV.UK
  128. Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK
  129. ECSH64830 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK
  130. High-risk third countries
  131. The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) (No. 3) Regulations 2022
  132. Enhanced due diligence: designation of high-risk countries
  133. HM Treasury publish updated list of high risk third jurisdictions
  134. Page 1 of 5 HM Treasury Advisory Notice: Changes to the FATF’s Public Lists
  135. Financial Action Task Force (FATF)
  136. FATF / MONEYVAL
  137. U.S. Department of the Treasury / OFAC
  138. HM Treasury (UK)
  139. Global Witness
  140. OCCRP
  141. Bloomberg
  142. Council of the European Union
  143. European Commission
  144. Global Witness
Coverage gaps
fim-int-2026-07-07-G001: Bulgaria's national 6AMLD transposi…
fim-int-2026-07-07-G001: Bulgaria's national 6AMLD transposition vehicle and legislative timeline have not been identified in the public record this cycle, limiting confidence in transposition-status assessment. [resolved]
fim-int-2026-07-07-G002: No Bulgaria-specific RegTech, SupTe…
fim-int-2026-07-07-G002: No Bulgaria-specific RegTech, SupTech, or AI-driven transaction-monitoring evidence exists at baseline; targeted Bulgarian National Bank / FID-SANS primary sourcing would close this D6 evidentiary gap. [resolved]
fim-int-2026-07-07-G003: Confirmation from a primary OFAC do…
fim-int-2026-07-07-G003: Confirmation from a primary OFAC document of the GL130A extended expiry date (29 October 2026) would resolve the timeline ambiguity flagged in the amendment-versus-expiration conflation. [resolved]
fim-int-2026-07-07-G004: No confirmation exists of whether F…
fim-int-2026-07-07-G004: No confirmation exists of whether FID-SANS has issued or plans to issue VASP-specific suspicious-transaction-report detection guidance, distinct from generic AML/CFT guidance. [resolved]
fim-int-2026-07-07-G005: The outcome of the EU sanctions-pac…
fim-int-2026-07-07-G005: The outcome of the EU sanctions-package vote affecting Patriarch Kirill, and whether Bulgaria's dissent persists or is isolated, is not yet resolved and would materially update the T6 divergence and F1 state-capture assessment. [resolved]
fim-int-2026-09-02-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-02-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No Tier-1 FSC or eur-lex primary source directly retrieved this cycle for the MiCA/CASP designation and grandfathering-window closure; sourcing rests on law-firm and vendor commentary. [resolved]
fim-int-2026-09-02-G002: D1 (Sanctions), D2 (Beneficial Owne…
fim-int-2026-09-02-G002: D1 (Sanctions), D2 (Beneficial Ownership), D3 (Enabler Jurisdictions), D4 (Conflict Finance) and D6 (Compliance Technology) carried no BG-specific findings this cycle; recorded as unexamined coverage gaps rather than confirmed absences. [resolved]
fim-int-2026-09-02-G003: Tier D jurisdictions (KH, LA, MX, C…
fim-int-2026-09-02-G003: Tier D jurisdictions (KH, LA, MX, CO) were not independently swept this cycle; the pooled retrieval budget for this union pass was concentrated on BG-scoped queries. [resolved]
fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No BG-specific sanctions-evasion, enabler-jurisdiction, conflict-finance, or compliance-technology signal was located this cycle; this dispatch was scoped exclusively to BG and could not run the standing multi-jurisdiction Tier D sweep. [resolved]
fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): BG-specific 6AMLD transposition status (not yet transposed / partial / fully transposed) not established this cycle. [resolved]
fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Whether any BG-registered legacy VASP failed to secure CASP authorisation by the 1 July 2026 deadline and was removed from the register has not been confirmed against the FSC's own register this cycle. [resolved]
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Primary FATF plenary statement confirming Bulgaria's removal from the grey list would move this claim from Probable to Confirmed. [resolved]
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): Primary State Gazette text of the Bulgarian Offshore Companies Act amendment would confirm the UBO-registration condition and sanction figures. [resolved]
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): Bulgaria's own 6AMLD transposition instrument for the beneficial-ownership-register provisions (Arts 11-13, 15) was not located this cycle. [resolved]
fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D4'}): No Bulgaria-specific D4 conflict-finance finding was identified this cycle. [resolved]
fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D6'}): No Bulgaria-specific D6 RegTech/AI transaction-monitoring finding was identified this cycle. [resolved]
fim-int-2026-10-18-G003: No Bulgaria-specific enforcement ac…
fim-int-2026-10-18-G003: No Bulgaria-specific enforcement action was identified this cycle. [resolved]
fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No direct confirmation from FATF itself of a delisting outcome for Bulgaria; secondary vendor commentary anticipates one at the late-October 2026 plenary, which falls after this cycle's cutoff. [resolved]
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): 6AMLD per-Member-State transposition status for Bulgaria was not independently confirmed this cycle. [resolved]
fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): Domains D2-D6 and D8 were not actively searched for Bulgaria-specific signal this cycle; this union dispatch's research budget was bound to BG alone. [open]
fim-int-2026-11-01-G002: Tier-D jurisdiction watch (KH, LA, …
fim-int-2026-11-01-G002: Tier-D jurisdiction watch (KH, LA, MX, CO) and the monthly regional-balance pass were not searched this cycle. [open]
FIM-GAP-001 (D2): Despite consecutive technical-compliance r…
FIM-GAP-001 (D2): Despite consecutive technical-compliance re-ratings, the FATF/MONEYVAL follow-up cycle from February 2025 through June 2026 repeatedly flagged that Bulgaria has not sufficiently increased investigations and prosecutions of money laundering tied to high-scale corruption and organised crime, and that action-plan deadlines on this point have expired.
FIM-GAP-002 (D1): Bulgaria's new government (2026) has signa…
FIM-GAP-002 (D1): Bulgaria's new government (2026) has signalled it will oppose an EU sanctions package element targeting Russian Orthodox Patriarch Kirill, following a pattern of historically close Bulgaria-Russia political and commercial ties (including the Lukoil refinery relationship) that has previously slowed sanctions implementation.
FIM-GAP-003 (D6): No Bulgaria-specific public-domain evidenc…
FIM-GAP-003 (D6): No Bulgaria-specific public-domain evidence of RegTech/SupTech adoption, AI-driven transaction monitoring, or supervisory technology roadmaps was identified during this baseline; FID-SANS's supervisory-technology posture could not be substantiated beyond generic references to 'automated STR prioritisation' in FATF follow-up reports.
FIM-GAP-004 (D1): FATF follow-up statements from February 20…
FIM-GAP-004 (D1): FATF follow-up statements from February 2025 through June 2025 repeatedly identified gaps in Bulgaria's proliferation-financing targeted financial sanctions (PF TFS) framework, though the June 2026 statement suggests this deficiency has now been substantially addressed alongside the broader action-plan determination.

Evidence

Confidence-tiered claims

MONEYVAL closed 5th-round mutual evaluation, compliant/largely compliant on all 40 FATF Recommendations [Source 1]
Probable · 1 source
Expected removal at 30 October 2026 FATF plenary, alongside Monaco and Côte d'Ivoire [Source 1]
Probable · 1 source
Named six websites offering unauthorised crypto-asset services and one unauthorised investment-services site, ordering cessation within three days [Source 1]
Probable · 1 source
Introduces treaty-state exceptions conditioned on UBO registration with the Commercial Register; new sanction EUR 5,000-25,000 for non-registration [Source 1]
Uncertain · 1 source
EUR 5 million seed round closed 3 June 2026, total funding EUR 7 million [Source 1]
Probable · 1 source
2027-04-24 [Source 1]
Probable · 1 source
first_reading_adopted_2026-09-24 [Source 1]
Probable · 1 source
compliant_or_largely_compliant_all_40_recommendations [Source 1]
Probable · 1 source
2026-07-01 [Source 1]
Probable · 1 source
embedded_in_commercial_register_no_standalone_bor [Source 1]
Probable · 1 source
UBO data embedded in the Commercial Register under MAMLA; a July 2025 amendment introduced a legitimate-interest gate on the most sensitive fields, though basic UBO data remained retrievable in a July 2026 vendor access test [Source 1]
Probable · 1 source
strategic partnership with Austrian CASP Bitpanda GmbH signed 12 October 2026 to embed crypto-asset trading in the My Fibank app, expected early 2027 [Source 1]
Probable · 1 source
removed [Source 1]
Probable · 1 source
welcomed [Source 1]
Probable · 1 source
Removed from FATF list of jurisdictions under increased monitoring as of 30 October 2026 [Source 1]
Probable · 1 source
MONEYVAL welcomes FATF's removal of Bulgaria from increased monitoring and will continue follow-up work [Source 1]
Probable · 1 source
decreasing (risk improving) [Source 1]
Probable · 1 source