Anti-Money Laundering Measures

I. Risk Assessment and Adoption of Internal Rules

The Anti-Money Laundering Act (AMLA) defines a broad scope of obliged entities that are required to maintain and implement internal rules against any attempt at money laundering.

We make specific risk assessments for each category of obliged entities on the basis of which we prepare comprehensible and easily applicable internal rules so as to comply with the law and to avoid the huge penalties for any infringement.

II. Disclosure of a Beneficial Owner

The AMLA requires that each legal person disclose its beneficial owner, even in the cases of an obvious sole owner of a company, who could turn out to be only a figurehead.

For legal persons obligated to disclose their beneficial owner we prepare all the requisite documentation needed for the valid identification of the owner and record the beneficial owner in the relevant register (Commercial Register, Register of Non-profit Legal Entities or BULSTAT Register).

III. Identification of a Contact Person

The AMLA requires every legal person without a legitimate representative with permanent residence in Bulgaria to indicate a contact person who is a permanent resident and can be contacted at any time for the purpose of providing any information or document.

In such cases, we provide a natural person to serve as a contact person in full compliance with the law, including the preparation and registration of all the documents needed for entering him or her as a contact person in the Companies Register.

IV. Training under the AMLA

In accordance with the AMLA, each obliged entity has to conduct regular training of their staff with regard to the contents of the law, the approved internal rules, and the way to detect suspicious operations, transactions and clients.

The training plan is sent to the National Security Agency on an annual basis and the evidence of holding training sessions has to be reliably recorded and stored.

We can provide practical training of the staff of every obliged entity in line with their specificities and internal rules, undertaking also to prepare and record all the documentation needed to prove that the training was held.