--- title: "Bulgaria (BG) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/bulgaria/ source_html: /jurisdictions/bulgaria/index.html description: "Financial integrity intelligence for Bulgaria (BG): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 0705f3b68cd3147aebb76cbb4697b52314d8227bbeefa6ce5e0ae142cbf3628b generator: "fe-fleet/md-twin@1.0" --- # Bulgaria (BG) — Financial-Integrity Intelligence · Sentinel 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. More It 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](/jurisdictions/eea/) 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. Read full brief #### 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) #### 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. Continue reading 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 #### 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. Continue reading 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 #### 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. Continue reading 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 Judgment: No Bulgaria-specific conflict-finance development surfaced this cycle. Uncertain #### 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. Continue reading 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 Judgment: No RegTech/compliance-technology development surfaced for Bulgaria this cycle; D6 is exempt from the substantive-finding floor. Uncertain #### 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. Continue reading 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 #### 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. Continue reading 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 Adopted 2026-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](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html) Adopted 2026-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](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html) Adopted 2028 · ±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](https://finance.ec.europa.eu/financial-crime/amla/frequently-asked-questions_en) 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) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material BG-specific sanctions-evasion signal this cycle. T2 · EU AML Package / AMLA no_change No BG-specific AMLR/6AMLD/AMLA development this cycle beyond the FATF/MONEYVAL delisting captured under T3/D7. T3 · FATF Grey List improving Bulgaria 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 Status no_change No BG-specific beneficial-ownership register development this cycle. T5 · Crypto & Digital-Asset Integrity no_change No new BG VASP/CASP sanctions-evasion or DeFi-enforcement signal this cycle. T6 · Sanctions Regime Divergence no_change No 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 - [Page 1 of 5 HM Treasury Advisory Notice: Changes to the FATF’s Public Lists](https://assets.publishing.service.gov.uk/media/69988878b33a4db7ff889ef3/Annex_C_-_Advisory_Notice_-_February_2026.pdf) - [Council of Europe](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) - [CMS Law](https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-regulation/bulgaria) - [Wolf Theiss](https://www.wolftheiss.com/insights/markets-in-crypto-assets-mica-licensing-in-bulgaria/) - [Innovires](https://www.innovires.com/en/blog/mica-crypto-regulation-bulgaria.html) - [O2K](https://www.o2k.tech/blog/mica-in-the-balkans-2026-guide) - [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)](https://www.bnb.bg/bnbweb/groups/public/documents/bnb_download/bs_aml_c_guidelines_a12_bg.pdf) - [Годишен отчет за дейността на КФН за 2025 г.](https://www.fsc.bg/wp-content/uploads/2026/05/godishen-otchet-na-kfn-2025-.pdf) - [КФН взе решение за спазване на насоки за противодействието на изпирането на пари и финансирането на тероризма](https://www.fsc.bg/%D0%BA%D1%84%D0%BD-%D0%B2%D0%B7%D0%B5-%D1%80%D0%B5%D1%88%D0%B5%D0%BD%D0%B8%D0%B5-%D0%B7%D0%B0-%D1%81%D0%BF%D0%B0%D0%B7%D0%B2%D0%B0%D0%BD%D0%B5-%D0%BD%D0%B0-%D0%BD%D0%B0%D1%81%D0%BE%D0%BA%D0%B8-%D0%B7/) - [Закон за пазарите на криптоактиви (ДВ, бр. 54 от 4.7.2025 г.)](https://dv.parliament.bg/DVWeb/showMaterialDV.jsp?idMat=235621) - [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](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) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Bulgaria-FUR-2025.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Bulgaria-FUR-2025.html) - [https://www.innovires.com/en/blog/mica-crypto-regulation-bulgaria.html](https://www.innovires.com/en/blog/mica-crypto-regulation-bulgaria.html) - [https://www.eternitylaw.com/news/crypto-license-in-bulgaria/](https://www.eternitylaw.com/news/crypto-license-in-bulgaria/) - [https://streamlinefeed.co.ke/news/monaco-bulgaria-ivory-coast-set-to-exit-fatf-grey-list](https://streamlinefeed.co.ke/news/monaco-bulgaria-ivory-coast-set-to-exit-fatf-grey-list) - [https://www.bta.bg/en/news/economy/1205393-bulgaria-expected-to-exit-fatf-grey-list-by-end-of-october-bloomberg-reports](https://www.bta.bg/en/news/economy/1205393-bulgaria-expected-to-exit-fatf-grey-list-by-end-of-october-bloomberg-reports) - [https://cms.law/en/bgr/legal-updates/bulgarian-offshore-companies-act-amendment-seeks-to-ease-restrictions](https://cms.law/en/bgr/legal-updates/bulgarian-offshore-companies-act-amendment-seeks-to-ease-restrictions) - [https://burgasmedia.com/amp/news/kfn-posochi-shest-sayta-koito-predlagat-kriptouslugi-bez-razreshenie?lang=en](https://burgasmedia.com/amp/news/kfn-posochi-shest-sayta-koito-predlagat-kriptouslugi-bez-razreshenie?lang=en) - [https://therecursive.com/bulgarian-fintech-paypercut-raises-eur5m-to-expand-its-payments-platform-across-cee/](https://therecursive.com/bulgarian-fintech-paypercut-raises-eur5m-to-expand-its-payments-platform-across-cee/) - [https://ofac.treasury.gov/media/937241/download?inline=](https://ofac.treasury.gov/media/937241/download?inline=) - [https://www.novinite.com/articles/241096/US+Extends+Lukoil+Exemption+in+Bulgaria+Until+April+2027](https://www.novinite.com/articles/241096/US+Extends+Lukoil+Exemption+in+Bulgaria+Until+April+2027) - [https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Mutualevaluations/bulgaria-fur-2026.html](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Mutualevaluations/bulgaria-fur-2026.html) - [https://www.wolftheiss.com/insights/bulgaria-advances-criminal-and-administrative-enforcement-of-eu-sanctions/](https://www.wolftheiss.com/insights/bulgaria-advances-criminal-and-administrative-enforcement-of-eu-sanctions/) - [https://www.fsc.bg/en/from-july-1-only-licensed-companies-may-offer-crypto-assets-within-the-eu/](https://www.fsc.bg/en/from-july-1-only-licensed-companies-may-offer-crypto-assets-within-the-eu/) - [Innovires](https://www.innovires.com/en/blog/beneficial-owners-ubo-bulgaria.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Bulgarian Telegraph Agency (BTA)](https://www.bta.bg/en/news/bulgaria/1151449-fatf-gives-green-light-for-bulgaria-s-exit-from-anti-money-laundering-grey-list) - [Kyckr](https://kyckr.com/guides-and-reports/eu-ubo-register-access-for-obliged-entities) - [Financial Supervision Commission (publishing MAMLA text)](https://www.fsc.bg/wp-content/uploads/2026/02/measures_against_money_laundering_act.pdf) - [Fibank (First Investment Bank) via EQS-News](https://www.webdisclosure.com/press-release/fibank-first-investment-bank-etr-fibank-and-bitpanda-forge-strategic-partnership-to-launch-integrated-crypto-asset-access-via-my-fibank-mobile-app-S2TTzY9SNR7) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2026.html) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2026.html) - [Council of Europe](https://www.coe.int/en/web/moneyval/-/moneyval-welcomes-bulgaria-s-and-monaco-s-removal-from-the-fatf-s-grey-list-) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Bulgaria](https://www.fatf-gafi.org/en/countries/detail/Bulgaria.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Mutual Evaluation of Bulgaria](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofbulgaria.html) - [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html) - [Jurisdictions under Increased Monitoring - June 2024](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2024.html) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - [Bulgaria's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Bulgaria-FUR-2025.html) - [1 Anti-money laundering and counter-terrorist financing measures Bulgaria](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Bulgaria-FUR-2025.pdf.coredownload.inline.pdf) - [Bulgaria's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-bulgaria-2022.html) - [Enhancing the capabilities for risk-based AML supervision and financial intelligence in Bulgaria - European Commission](https://reform-support.ec.europa.eu/what-we-do/financial-sector-and-access-finance/enhancing-capabilities-risk-based-aml-supervision-and-financial-intelligence-bulgaria_en) - [bg0103-07-money laundering - European Union](https://enlargement.ec.europa.eu/document/download/b86dbe52-dc02-46f1-ab79-ec7b2f8e2a16_en?filename=bg0103-07-money_laundering.pdf&prefLang=cs) - [Mutual Evaluation of Bulgaria](https://www.fatf-gafi.org/en/countries/a-c/bulgaria/documents/mutualevaluationofbulgaria.html) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Balkans-Related Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/balkans-related-sanctions) - [Issuance of New and Amended Russia-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251114) - [UK sanctions high profile Bulgarian figures involved in corruption - GOV.UK](https://www.gov.uk/government/news/uk-sanctions-high-profile-bulgarian-figures-involved-in-corruption) - [Global Magnitsky Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20230210) - [US Sanctions Bulgarian Oligarchs, Public Officials for Corruption | OCCRP](https://www.occrp.org/en/news/us-sanctions-bulgarian-oligarchs-public-officials-for-corruption) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [Issuance of Amended Executive Order Taking Additional Steps with Respect to the Situation in the Western Balkans | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250108) - [1 Financial Sanctions Notice 10/02/2023 Global Anti-Corruption Introduction](https://assets.publishing.service.gov.uk/media/63e62d828fa8f505133b4286/Notice_Global_Anti-Corruption_100223.pdf) - [Office of Foreign Assets Control U.S. Department of the Treasury](https://ofac.treasury.gov/media/6181/download) - [Bulgaria Seizes Refinery Before US Sanctions Hit Russia’s Lukoil - Bloomberg](https://www.bloomberg.com/news/articles/2025-11-14/bulgaria-seizes-refinery-before-us-sanctions-hit-russia-s-lukoil) - [Russian oil in EU soil | Global Witness](https://globalwitness.org/en/campaigns/fossil-fuels/russian-oil-on-eu-soil-bulgarian-refinery-skirts-sanctions-and-buys-russian-crude-worth-an-estimated-11-billion-in-tax-to-the-kremlin/) - [DEPARTMENT OF THE TREASURY WASHINGTON, D.C. OFFICE OF FOREIGN ASSETS CONTROL](https://ofac.treasury.gov/media/934756/download?inline=) - [Russian Oil Loophole - EU's contribution to the Kremlin | Global Witness](https://globalwitness.org/en/press-releases/investigation-reveals-the-eus-russian-oil-loophole-contributing-an-estimated-11-billion-in-taxes-to-kremlin/) - [Bulgaria Bans Russian Oil in Blow to Lukoil Refinery - Bloomberg](https://www.bloomberg.com/news/articles/2023-09-28/bulgaria-set-to-ban-russian-oil-in-blow-to-lukoil-refinery) - [Bulgaria to End Russian Oil Imports As Lukoil Considers Refinery Sale - Bloomberg](https://www.bloomberg.com/news/articles/2023-12-18/bulgaria-to-end-russian-oil-imports-from-march-as-lukoil-considers-refinery-sale) - [Eastern Europe Newsletter: Tussle Over Russian Oil Refinery Heats Up in Bulgaria - Bloomberg](https://www.bloomberg.com/news/newsletters/2025-01-10/eastern-europe-newsletter-tussle-over-russian-oil-refinery-heats-up-in-bulgaria) - [Lukoil’s Litasco Disputes Bulgaria’s Seizure of Its Assets](https://www.bloomberg.com/news/articles/2026-02-25/lukoil-s-litasco-disputes-bulgaria-s-seizure-of-its-assets) - [Diesel Prices Jump on Russia Sanctions and Refinery Outages - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-28/diesel-surges-on-double-whammy-of-sanctions-and-refinery-outages) - [Anti-money laundering and countering the financing of terrorism at EU level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en) - [Bulgaria opens public consultation on new international protection law which addresses integration - Migration and Home Affairs](https://home-affairs.ec.europa.eu/news/bulgaria-opens-public-consultation-new-international-protection-law-which-addresses-integration-2026-02-18_en) - [Anti-money laundering and countering the financing of terrorism legislative package - Finance](https://finance.ec.europa.eu/publications/anti-money-laundering-and-countering-financing-terrorism-legislative-package_en) - [Anti-money laundering directive V (AMLD V) - transposition status | European Commission](https://ec.europa.eu/info/publications/anti-money-laundering-directive-5-transposition-status_en) - [1 Anti-money laundering and counter-terrorist financing measures Bulgaria](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Bulgaria_MONEYVAL_FUR_2024.pdf.coredownload.pdf) - [Anti-money laundering: Council and Parliament strike deal on stricter rules - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2024/01/18/anti-money-laundering-council-and-parliament-strike-deal-on-stricter-rules/) - [FAQs - Authority for Anti-Money Laundering and Countering the Financing of Terrorism](https://finance.ec.europa.eu/financial-crime/amla/frequently-asked-questions_en) - [Anti-money laundering: Council adopts package of rules - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2024/05/30/anti-money-laundering-council-adopts-package-of-rules/) - [Bulgaria - Reform Support - European Commission](https://reform-support.ec.europa.eu/our-projects/country-factsheets/bulgaria_en) - [NIS2 Directive implementation in Bulgaria | Shaping Europe’s digital future](https://digital-strategy.ec.europa.eu/en/policies/nis2-directive-bulgaria) - [Guide to setting up your company in Bulgaria](https://ec.europa.eu/programmes/erasmus-plus/project-result-content/6ae14c33-ed6b-4a7d-80b7-f08038684d77/Guide_to_setting_up_your_company_in_7_countries.pdf) - [European e-Justice Portal - Business registers in EU countries](https://webgate.ec.europa.eu/e-justice/106/EN/business_registers_in_eu_countries?BULGARIA=&init=true&member=1) - [Frequently Asked Questions | OCCRP](https://www.occrp.org/en/project/openlux/frequently-asked-questions) - [Patchy progress in beneficial ownership registers in the EU | Global Witness](https://globalwitness.org/en/campaigns/corruption-and-money-laundering/patchy-progress-in-setting-up-beneficial-ownership-registers-in-the-eu/) - [Directory of Open-Source Registries: Bulgaria](https://globenetwork.unodc.org/globenetwork/en/directory-of-open-source-registries/bulgaria.html) - [Beneficial Ownership Registers Interconnection System](https://webgate.ec.europa.eu/e-justice/searchBoris.do) - [European e-Justice Portal - Beneficial ownership registers interconnection system (BORIS)](https://webgate.ec.europa.eu/e-justice/38590/EN/beneficial_ownership_registers_interconnection_system_boris?init=true&idSubpage=1) - [Bulgaria SME rules - VAT rules for small enterprises – SME scheme](https://sme-vat-rules.ec.europa.eu/national-vat-rules/bulgaria-sme-rules_en) - [AVAILABILITY OF COMPANY BENEFICIAL OWNERSHIP ...](https://www.globalwitness.org/documents/19879/EU_BO_registers_Annex.pdf) - [Bulgarian Chamber of Commerce and Industry - IP Helpdesk](https://intellectual-property-helpdesk.ec.europa.eu/organisations/bulgarian-chamber-commerce-and-industry_en) - [Bulgaria adopts euro as of 1 January 2026 | Access2Markets](https://trade.ec.europa.eu/access-to-markets/en/news/bulgaria-adopts-euro-1-january-2026) - [Bulgaria ready to use the euro from 1 January 2026: Council takes final steps - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/07/08/bulgaria-ready-to-use-the-euro-from-1-january-2026-council-takes-final-steps/) - [Bulgaria and the euro - Economy and Finance - European Commission](https://economy-finance.ec.europa.eu/euro/eu-countries-and-euro/bulgaria-and-euro_en) - [Overseas business risk: Bulgaria - GOV.UK](https://www.gov.uk/government/publications/overseas-business-risk-bulgaria/overseas-business-risk-bulgaria) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [Questions and answers on Bulgaria\'s changeover to the euro](https://ec.europa.eu/commission/presscorner/detail/it/qanda_25_1751) - [What Is a VASP? Virtual Asset Service Provider - Chainalysis](https://www.chainalysis.com/glossary/virtual-asset-service-provider/) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp) - [The Importance of Knowing Your VASP in AML Compliance](https://www.elliptic.co/blockchain-basics/what-is-a-vasp) - [VASP Screening & Due Diligence | Elliptic Discovery](https://www.elliptic.co/discovery-vasp-screening) - [Entity Due Diligence & VASP Screening | Elliptic](https://www.elliptic.co/solutions/due-diligence) - [Updated-Guidance-VA-VASP.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Updated-Guidance-VA-VASP.pdf) - [Crypto Due Diligence & VASP Tracking from Elliptic](https://www.elliptic.co/solutions/vasp-tracking) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Countering the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-3) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Bulgaria Detains 8 in EU Subsidy Fraud Probe | OCCRP](https://www.occrp.org/en/news/eppo-detains-8-in-bulgaria-eu-subsidy-fraud-probe) - [Scam Empire: Inside A Merciless International Investment Scam | OCCRP](https://www.occrp.org/en/project/scam-empire/scam-empire-inside-a-merciless-international-investment-scam) - [Bulgaria Loses EU Money Because of OC | OCCRP](https://www.occrp.org/en/project/battered-justice/bulgaria-loses-eu-money-because-of-oc) - [3 Arrested in Bulgaria for US Money Laundering Scam | OCCRP](https://www.occrp.org/en/feature/3-arrested-in-bulgaria-for-us-money-laundering-scam) - [All Investigations | OCCRP](https://www.occrp.org/en/investigations) - [Bulgarian Police Take Down Online Investment Scam Network | OCCRP](https://www.occrp.org/en/news/bulgarian-police-take-down-online-investment-scam-network) - [Bulgaria: Joint Operation Dismantles Laundering Ring | OCCRP](https://www.occrp.org/en/news/bulgaria-joint-operation-dismantles-laundering-ring) - [Bulgaria: Asset Seizure? | OCCRP](https://www.occrp.org/en/news/bulgaria-asset-seizure) - [EU Prosecutor Investigates Embezzlement of EU Funds in Bulgaria | OCCRP](https://www.occrp.org/en/news/eu-prosecutor-investigates-embezzlement-of-eu-funds-in-bulgaria) - [Global Magnitsky Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20210602) - [CONSOLIDATED LIST OF FINANCIAL SANCTIONS TARGETS IN THE UK](https://assets.publishing.service.gov.uk/media/6852d229df3015b374b73635/Global_Anti-Corruption__3_.pdf) - [FCDO - UK Sanctions List Search - GOV.UK](https://search-uk-sanctions-list.service.gov.uk/designations/GAC0037/Individual) - [Global Magnitsky Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/global-magnitsky-sanctions) - [Bulgaria to Oppose EU Sanctions on Russian Patriarch Kirill, Minister Says - Bloomberg](https://www.bloomberg.com/news/articles/2026-06-17/bulgaria-to-oppose-eu-sanctions-against-russian-patriarch-kirill) - [Magnitsky Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/the-magnitsky-sanctions) - [Bulgaria loses EU money | OCCRP](https://www.occrp.org/en/news/bulgaria-loses-eu-money) - [Euro Aspirant Bulgaria Sees Exit From Watchdog’s ‘Gray List’ - Bloomberg](https://www.bloomberg.com/news/articles/2023-11-03/euro-aspirant-bulgaria-sees-exit-from-watchdog-s-gray-list) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh31555) - [HM Treasury Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/hm-treasury-advisory-notice-high-risk-third-countries) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [ECSH64830 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh64830) - [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) (No. 3) Regulations 2022](https://www.legislation.gov.uk/uksi/2022/1183/made) - [Enhanced due diligence: designation of high-risk countries](https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1165484/Updated_Impact_Assessment_-_HRTC_Measure_amendement_2_ECCTB_21.06.23_MIN_CLEARED.pdf) - [HM Treasury publish updated list of high risk third jurisdictions](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-publish-updated-list-of-high-risk-third-jurisdictions) - [Page 1 of 5 HM Treasury Advisory Notice: Changes to the FATF’s Public Lists](https://assets.publishing.service.gov.uk/media/69988878b33a4db7ff889ef3/Annex_C_-_Advisory_Notice_-_February_2026.pdf) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [FATF / MONEYVAL](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Bulgaria-FUR-2025.pdf.coredownload.inline.pdf) - [U.S. Department of the Treasury / OFAC](https://ofac.treasury.gov/media/934756/download?inline=) - [HM Treasury (UK)](https://assets.publishing.service.gov.uk/media/69988878b33a4db7ff889ef3/Annex_C_-_Advisory_Notice_-_February_2026.pdf) - [Global Witness](https://globalwitness.org/en/press-releases/investigation-reveals-the-eus-russian-oil-loophole-contributing-an-estimated-11-billion-in-taxes-to-kremlin/) - [OCCRP](https://www.occrp.org/en/news/eppo-detains-8-in-bulgaria-eu-subsidy-fraud-probe) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-11-14/bulgaria-seizes-refinery-before-us-sanctions-hit-russia-s-lukoil) - [Council of the European Union](https://www.consilium.europa.eu/en/press/press-releases/2025/07/08/bulgaria-ready-to-use-the-euro-from-1-january-2026-council-takes-final-steps/) - [European Commission](https://finance.ec.europa.eu/financial-crime/amla/frequently-asked-questions_en) - [Global Witness](https://globalwitness.org/en/campaigns/corruption-and-money-laundering/patchy-progress-in-setting-up-beneficial-ownership-registers-in-the-eu/) 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]](#sec-sources) Probable · 1 source Expected removal at 30 October 2026 FATF plenary, alongside Monaco and Côte d'Ivoire [[Source 1]](#sec-sources) Probable · 1 source Named six websites offering unauthorised crypto-asset services and one unauthorised investment-services site, ordering cessation within three days [[Source 1]](#sec-sources) 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]](#sec-sources) Uncertain · 1 source EUR 5 million seed round closed 3 June 2026, total funding EUR 7 million [[Source 1]](#sec-sources) Probable · 1 source 2027-04-24 [[Source 1]](#sec-sources) Probable · 1 source first_reading_adopted_2026-09-24 [[Source 1]](#sec-sources) Probable · 1 source compliant_or_largely_compliant_all_40_recommendations [[Source 1]](#sec-sources) Probable · 1 source 2026-07-01 [[Source 1]](#sec-sources) Probable · 1 source embedded_in_commercial_register_no_standalone_bor [[Source 1]](#sec-sources) 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]](#sec-sources) 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]](#sec-sources) Probable · 1 source removed [[Source 1]](#sec-sources) Probable · 1 source welcomed [[Source 1]](#sec-sources) Probable · 1 source Removed from FATF list of jurisdictions under increased monitoring as of 30 October 2026 [[Source 1]](#sec-sources) Probable · 1 source MONEYVAL welcomes FATF's removal of Bulgaria from increased monitoring and will continue follow-up work [[Source 1]](#sec-sources) Probable · 1 source decreasing (risk improving) [[Source 1]](#sec-sources) Probable · 1 source