The transparency register in the 4th AML directive in Bulgaria

The current legal basis of the Bulgarian Transparency Register is Chapter II, Part VI of the Bulgarian Anti-Money Laundering Measures Act (Закон за мерките срещу изпирането на пари) published in State Gazette Issue No 27/2018 on 27 March 2018, effective from 31 March 2018.

Further amendments implementing the Directive were promulgated in State Gazette Issue No 94 dated 29 November 2019.

Only upon request.

The UBO is obliged to provide the legal entity with all documents and information required for the purposes of fulfilling transparency obligations upon request.  

Yes.

There is an obligation for the legal entity to have and to keep adequate, accurate and up-to-date information on the identity of the UBO.

The legal entity.

5. Are there exemptions to the filing obligation?

Yes.

There is an exemption if the required information is already available in the relevant registers.

6. What is the due date for the initial filing? Is there an obligation to update the filing?

1 February 2019 – 31 May 2019.

Yes, if there is a change in circumstances.

7. What are the sanctions in case of a breach of the transparency obligation?

Fines range between EUR 250 and EUR 2,500 for responsible managers of a legal entity. Fines for legal entities range between EUR 500 and EUR 5,000.

8. Is the Transparency Register established as a separate register or part of an existing one?

The Bulgarian Transparency Register is part of two existing public registers: the Commercial Register and the BULSTAT Register.

9. Notable amendments (including through the Directive)

N/A