Following the amendments of 7 May the following requirements were waved or changed:
1. The internal rules of the obliged persons under the Measures Against Money Laundering Act (MAML) to be brought into line with the law within 6 months of the publication of the results of the national risk assessment on the website of the State Agency for National Security /SANS/ and on the mass media.
2. The internal rules should not be sent to SANS for approval.
3. The obligation to declare the ultimate beneficial owners of Bulgarian companies was waived under certain conditions:
– Bulgarian companies which capital is owned by a chain of companies incorporated in Bulgaria, and shareholders and/or sole owners of the capital who are listed in the Bulgarian Commercial Register.
For example, a Bulgarian Limited Liability Company (LLC), whose shareholders are 2 Bulgarian LLC’s whose shareholders are natural persons and are listed as shareholders in the Commercial Register, do not need to declare its ultimate beneficial owners because this information is already public in the Commercial Register and can be traced along the property chain.
In case the companies involved in the property chain are not Bulgarian companies, the obligation to declare the ultimate beneficial owners remains. For example, if shareholders in the Bulgarian LLC of the above example are 2 foreign companies.
The deadline for declaring the ultimate beneficial owners expires on the 31st of May 2019!
In case you need assistance or want to know if your company falls under the law, you can contact us at any time.