1. Does Bulgaria have a sanctions regime in place?


2. Does Bulgaria implement UN sanctions?

Yes, as a member state to the UN and the EU, Bulgaria is bound, by virtue of the UN Charter and the EU Treaties, to implement the restrictive measures (sanctions) imposed by the UN and the EU respectively.

3. Does Bulgaria implement an autonomous sanctions regime?

Bulgaria has not adopted any statutory rules establishing a general autonomous regime for imposition of sanctions at national level independently from (i.e. not in implementation of) sanctions imposed by the UN and the EU - except for the Law on Measures against Financing of Terrorism (“LMFT”) provides for a special autonomous national regime for imposition of restrictive measures specifically targeted against people, entities, groups and organizations suspected of having links with terrorism.

Also, Bulgaria has implemented national sanctions regimes with respect to the sale and supply of armaments and armaments-related inventory, as well as a sanction regime against Iran (for more information on these sanctions regimes, please refer to the response to question 6 below).

4. What is the nature of the sanctions regime in Bulgaria?

LMFT defines some restrictive measures against the financing of terrorism with the aim to prevent and reveal any actions of individuals, legal entities, groups or organizations directed at financing terrorism. The measures under the LMFT are:

  • blocking/freezing of funds, financial assets and other property owned or possessed by sanctioned subjects; and/or
  • prohibition to provide financial services, funds, financial assets or other property to any of the sanctioned subjects.

5. Does Belgium maintain a list of sanctioned individuals and entities?

Yes. Acting on a motion by either the Minister of Foreign Affairs, the Minister of Interior, the Chairperson of the State Agency for National Security or the Prosecutor General, the Council of Ministers is empowered to adopt, supplement and modify the list of persons to be affected by the measures under the LMFT. This list includes:

  • individuals against whom criminal proceedings have been initiated on the grounds of alleged terrorism; financing of terrorism; recruitment and training of individuals or groups of people for the purpose of practising terrorism, crossing the border or illegal stay in the country with the purpose to participate in terrorism, establishing, managing or being a member of an organized crime syndicate having as its purpose the practice of terrorism or the financing of terrorism; preparation to practise terrorism; forgery of an official document for the purpose of facilitating the practice of terrorism, manifest incitement to practising terrorism; or a threat to practise terrorism, as defined by the Criminal Code,
  • individuals for whom there is sufficient data that they pursue activities related to terrorism or financing of terrorism; and
  • other persons identified by the competent authorities of another country. The decision of the Council of Ministers shall be promulgated in State Gazette and published on the websites of the Council of Ministers, the Ministry of Interior and the State Agency for National Security. The Ministry of Foreign Affairs maintains on its website a consolidated version of the list adopted by the Council of Ministers. The Ministry of Foreign Affairs also publishes information on the regulations adopted by the European Parliament and the Council for imposition of sanctions regarding terrorism or financing of terrorism, as well as the resolutions adopted by the UNSC for imposition of sanctions regarding terrorism or financing of terrorism and any modifications to the lists of individuals thereto.

Other than the above, the Bulgarian sanctions regime against Iran is also oriented to individuals and entities (for more information, please refer to the response to question 6 below).

6. Are there any other lists related to sanctions?


National Regulations on Sanctions for Sale and Supply of Armaments and Armaments-Related Inventory:

Specific restrictions on the sale and supplies of armaments and armaments-related inventory are implemented in Council of Ministers’ Decree No. 91 issued in compliance with UN Security Council’s Resolutions and Resolutions of the EU and of the Organisation for Economic Co-operation and Development, adopting a list of countries and organisations which are subject to a prohibition or restriction on the sale and supplies of armaments and armaments-related inventory (“Decree No. 91”).

National Regulations on Sanctions against Iran:

Council of Ministers’ Decree No. 83 for the Implementation of Resolution 1737 of the UN Security Council of 23 December 2006 and of Common Position 140 оf the Council of the European Union of 27 February 2007 for imposing sanctions on the Islamic Republic of Iran (“Decree No. 83”).

Under Decree No. 83 all funds, financial assets and economic resources owned by, in possession of, held by or (directly or indirectly) controlled by the following persons shall be frozen:

(1) Persons and undertakings specified in the schedule to UNSC Resolution 1737 (2006), and the new persons and undertakings specified by the UNSC or the Committee in accordance with § 12 of Resolution 1737 (2006) and § 7 of Resolution 1803 (2008) of the UNSC, as enlisted in the appendix to Decree No. 83.

(2) Persons and undertakings not enlisted in the schedule to UNSC Resolution 1737 (2006), who participate in, are directly related to or support Iran’s sensitive activities related to the dissemination of nuclear weapons or Iran’s development of nuclear weapons carriers, or persons and undertakings who are known to act in their name or on their instructions, or undertakings owned or controlled thereby, whether lawfully or unlawfully, as well as persons who have supported such persons and undertakings to evade the application of or to violate the provisions of UNSC Resolutions 1737 (2006), 1747 (2007) and 1803 (2008), as enlisted in the appendix to Decree No. 83.

The provision of any funds, financial assets or economic resources by Bulgarian citizens or by other persons on Bulgarian territory in favour of the persons specified above shall be prohibited.

However, interest and other accruals on frozen accounts, and payments under contracts or obligations which arose before the accounts became subject to the restrictive measures, may be permitted on the condition that all such interest and other accruals and payments continue to be subject to the restrictive measures described above and are also frozen.

The provision of any grants, financial support and concession loans to the government of the Islamic Republic of Iran, including by participation in international organisations, shall be prohibited, unless provided for humanitarian and development purposes.

7. Does Bulgaria have a licensing or authorization system in place?

LMFT Sanctions:

The Minister of Interior or officials authorized by him may authorise that payments or other acts of disposition with the funds, financial assets and other property blocked/frozen under the LMFT are allowed, when necessary, for the following purposes:

  • medical treatment or other urgent humanitarian needs of the person whose property is blocked/frozen, or of a member of his/her family,
  • payment of liabilities to the state,
  • payment of remunerations for work performed,
  • compulsory social insurance; and
  • meeting current daily needs of the sanctioned individuals and the members of their families.

The authorization shall be granted on a case-by-case basis upon a reasoned request by the person concerned or, with respect to the payment of liabilities to the state only, upon the initiative of the Minister of Finance. The Minister of Interior or an official authorized thereby shall return a decision within 48 hours of the submission of the application.

Sanctions against Iran

Decree No. 83 provides for certain conditions upon which the restrictive measures thereunder (see the response to question 6 above) shall not apply (e.g. if the funds, financial assets or economic resources are necessary for payment of main expenses, including for food, rent or mortgage payments, medicine and medical treatment, taxes, insurance premiums and utility costs).

8. What are the consequences for a breach of sanctions in Bulgaria?

Any person who commits or allows another to commit a violation of the sanctions imposed under the LMFT is subject to a fine within the range of: (i) BGN 2,000 to BGN 2,000,000 (approx. EUR 1,000 to EUR 1,000,000) for individuals, (ii) BGN 20,000 to BGN 2,000,000 (approx. EUR 10,500 to EUR for 1,000,000) or up to the double amount of the proceeds received as a result of the violation for legal entities, and (iii) BGN 30,000 to BGN 10,000,000 (approx. EUR 15,000 to EUR 5,000,000) or up to 10% of the annual turnover (including gross income, according to the consolidated accounts of the parent undertaking for the previous year, comprising interest receivable and other similar income, income from shares and other variable or fixed yield securities income and receivables from commissions and/or fees) for certain specific types of entities obliged under the Bulgarian Law on Measures Against Money Laundering.

In addition, anything given by the parties to a transaction carried out in violation of imposed sanctions shall be forfeited to the state. The financial penalties which may be imposed for violation of Decree No. 91 of the Council of Ministers are: (i) from BGN 100 to BGN 2,000 (approx. EUR 50 to EUR 1,000) for individuals, and (ii) up to BGN 100,000 (approx. EUR 50,000) for legal entities.

No financial penalties are provided with respect to breach of sanctions against Iran under Decree No. 83.

In any case, if the act committed in breach of the sanctions regimes constitutes a criminal offence, the responsible individuals will be penalized according to the Criminal Code.

9. Who are the relevant regulators in Bulgaria and what are their contact details?

The following governmental bodies are empowered to control whether the LMFT regime has been breached and to impose the fines described above:

Minister of Interior 29 Shesti Septemvri Street, 1000 Sofia Bulgaria T: (+359) 2 877 511 F: (+359) 2 877 967 E: spvo@mvr.bg www.mvr.bg

State Agency for National Security 45 “Cherni Vrah” Blvd., Sofia, Bulgaria T: (+359) 2 963 21 88 F: (+359) 2 814 74 41 E: dans@dans.bg

National Revenue Agency 52, Dondukov Blvd.; 1000 Sofia, Bulgaria T: 0700 18 700 E: infocenter@nra.bg

Bulgarian National Bank 1, Knyaz Alexander І Sq., 1000 Sofia, Bulgaria T: (+3592) 91459 (Switchboard) F: (+3592) 980-24-25; (+3592) 980-64-93

Financial Supervision Commission 1000 Sofia,16 Budapeshta str. T: (+359) 800 40 444 F: (+359) 2 9404 606

E: bg_fsc@fsc.bg

The control over the implementation of the provisions of Decree No. 91 is vested in the following governmental bodies:

Intra-departmental Council of Defence Industry and Supplies Safety with the Council of Ministers of the Republic of Bulgaria: 1 Dondukov Blvd., 1594 Sofia, Bulgaria T: 02 940 28 42 F: 02 988 03 79 E: micmrc@government.bg

Minister of Economy 8, Slavyanska Str., Sofia 1052, Bulgaria T: (+359) 2 9407001 F: (+359) 2 987 2190; +359 2 981 9970 E: e-docs@mi.government.bg

Minister of Defence 3 Dyakon Ignatiy Str., 1000 Sofia, Bulgaria T: (+359) 2 92 20 922 F: (+359) 2 987 96 93

Minister of Finance 102, G. S. Rakovski str., Sofia, 1040, Bulgaria T: (+359) 2 9859 1 F: (+359) 2 980 68 63

Minister of Foreign Affairs 2, Aleksandar Zhendov Str., Sofia 1113, Bulgaria T: (+ 359) 2 948 2999

Minister of Interior (please see details above)

Minister of Transport, Information Technology and Communications 9, Dyakon Ignatiy str. Sofia 1000, Bulgaria T.: 02/940 – 9771 F.: 02/988 – 5094 E: mail@mtitc.government.bg

Governor of the Bulgarian National Bank (please see details above)

The implementation of Decree No. 83 is vested in the following governmental bodies:

Intra-departmental Council of Defence Industry and Supplies Safety with the Council of Ministers of the Republic of Bulgaria

(please see details above)

Interministerial Commission for Export Control and Non-Proliferation of Weapons of Mass Destruction with the Minister of Economy 8, Slavyanska Str., Sofia 1052, Bulgaria T: (+359) 2 9407771 (7681) F: (+359) 2 9880727 W: http://www.exportcontrol.bg/indexbg.php.

Minister of Interior (please see details above)

Minister of Finance (please see details above)

Director of Customs Agency G.S.Rakovski 47 Str., Sofia 1202, Bulgaria T: (+359) 2 9859 4210 F: (+359) 2 9859 4066 W: delovodstvo@customs.bg

Minister of Education and Science 2A Dondukov Blvd., 1000 Sofia, Bulgaria T: (+359) 2 9217 799 F: (+359) 2 988 24 85

Minister of Foreign Affairs

(please see details above)

Contributor law firm

Kamen Gogov Senior Associate

Lora Aleksandrova Associate

Djingov, Gouginski

Kyutchukov & Velichkov 10 Tsar Osvoboditel Blvd., Sofia 1000, Bulgaria

T: (+359) 2 932 1100 F: (+359) 2 980 3586 kamen.gogov@dgkv.com http://www.dgkv.com/

T: +359 2 932 1100 F: +359 2 980 3586 lora.aleksandrova@dgkv.com


Explore other countries

© Eversheds Sutherland 2021. All rights reserved. Eversheds Sutherland is a global provider of legal and other services operating through various separate and distinct legal entities. Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client.

Share this page