Anti Money Laundering (AML)

Overview

Anti-money laundering (AML) compliance is a critical and increasingly complex aspect of doing business in Bulgaria and across the European Union. Supervisory expectations continue to rise, enforcement activity is intensifying, and the consequences of non-compliance can be severe for both financial and non-financial businesses.

We have advised on AML matters since 2017. Our team combines legal expertise with direct regulatory and investigative experience, including leadership by a former senior special agent of the State Agency for National Security (SANS). This enables us to provide advice grounded in practical insight into supervisory practice and enforcement risk.

Our Approach

AML sits at the intersection of regulatory compliance, criminal law, data protection and fundamental rights. Obliged entities must implement effective systems for customer due diligence, risk assessment, monitoring and reporting—while also maintaining commercial relationships and protecting the rights of customers and third parties. We help clients meet these obligations in a way that is legally robust, proportionate and aligned with their business objectives.

We advise clients across the AML compliance lifecycle, from framework design and implementation to regulatory engagement and dispute resolution. Our approach is pragmatic and risk-focused, reflecting both statutory requirements and how AML rules are applied by supervisory authorities in practice.

AML Compliance for Financial Institutions

We advise banks, payment and electronic money institutions, investment firms and other regulated entities on AML compliance under Bulgarian and EU law. Our work focuses on governance, internal controls and accountability at board and senior management level.

We regularly advise on product and distribution risk, outsourcing arrangements and cross-border services. We also have strong experience with fintech, crypto-asset and technology-driven business models, where regulatory expectations continue to evolve rapidly.

AML Obligations of Non-Financial Businesses

We advise non-financial obliged entities, including professional services firms, real estate businesses, gambling operators and other designated sectors, on the scope and application of their AML obligations.

Our advice translates legal requirements into practical internal processes that reflect the client’s risk profile and commercial reality, while remaining defensible in the event of supervisory review.

Customer Due Diligence and Risk Assessment

Customer due diligence is central to effective AML compliance. We advise on the identification and verification of customers and ultimate beneficial owners (UBOs), including the assessment of complex ownership and control structures across multiple jurisdictions.

We support clients in applying enhanced due diligence measures where higher risks are identified, including verification of source of funds and source of wealth. Our approach balances regulatory expectations with proportionality, data protection and customer rights.

Internal AML Frameworks and Training

We assist clients with the development and implementation of internal AML policies and procedures, including enterprise-wide risk assessments, internal rules, reporting workflows and allocation of responsibilities.

We also deliver AML training, in person or online, tailored to the client’s sector, risk exposure and the expectations of Bulgarian and EU supervisory authorities. Training is practical and scenario-based, aimed at improving awareness and reducing enforcement risk.

AML Readiness, Audits and Risk Reviews

We assist clients in assessing the effectiveness of their AML frameworks against applicable Bulgarian and EU requirements. Our AML readiness and audit work focuses on identifying vulnerabilities that may expose the business to regulatory action, sanctions or reputational damage.

Our reviews take into account forthcoming regulatory developments, including the EU Anti-Money Laundering Regulation (AMLR), the Sixth Anti-Money Laundering Directive (AMLD6), and evolving supervisory and enforcement practice.

Regulatory Engagement and Enforcement

We represent and support clients in their interactions with competent authorities, including SANS, the Financial Supervision Commission and the Bulgarian National Bank. Our work includes responding to information requests and inspections, managing reporting obligations, advising on asset freezes and precautionary measures, and representing clients in enforcement proceedings and related disputes.

Where AML measures affect customer rights, access to funds or data protection interests, we advise on balancing compliance obligations with legal safeguards and proportionality requirements.

EU and Cross-Border AML Matters

We advise clients with a forward-looking view of AML regulation, including the transition to a more centralised EU framework and the establishment of the EU Anti-Money Laundering Authority (AMLA).

We regularly advise on cross-border structures, group-wide AML policies and multi-jurisdictional matters, working closely with foreign counsel where appropriate to ensure consistency, regulatory alignment and effective risk management.