Custodial wallet / SaaS in Bulgaria

The Measures Against Money Laundering Act (SG No. 27/2018) remains Bulgaria's AML/CFT statute for crypto businesses: the Markets in Crypto-Assets Act (SG No. 54/2025), in force since 8 July 2025, amended it in § 18 to add FSC-authorised crypto-asset service providers as obliged entities (Article 4, item 19), repeal the NRA register (Article 9a) and repeal the former VASP items 38 and 39 from 1 July 2026.

The Measures Against Money Laundering Act covered virtual-asset providers through Article 4, items 38 and 39; the Markets in Crypto-Assets Act repealed those items from 1 July 2026, replaced them with item 19 (FSC-authorised crypto-asset service providers) and added definitions of crypto-asset, crypto-asset service provider and self-hosted address (Supplementary Provisions § 1, items 33–35).

Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.

SANS does not supervise crypto-asset service providers: under the Markets in Crypto-Assets Act the Financial Supervision Commission authorises and supervises them (Art 3(1)) and monitors their crypto-transfer compliance under Regulation (EU) 2023/1113 (Art 20), and only notifies SANS when it starts enforcing a coercive administrative measure (Art 24).

National Revenue Agency (NRA) (Национална агенция за приходите - НАП)

In Bulgaria, the identification and verification of the beneficial owner is required under the AML Act, but if no individual beneficial owner can be identified through ownership or control criteria, the law provides that members of senior management are treated as the beneficial owner for registration purposes, so the process is not absolute but includes a fallback.

Natural Persons: Name, date and place of birth, nationality, permanent address, unique identification number (e.g., national ID card, passport number). Identity must be verified using reliable, independent source documents or data (e.g., valid official identification document).

Legal Entities: Company name, legal form, registration number, registered address, and the names of the individuals authorized to represent the company. Verification involves obtaining extracts from commercial registers or similar official documents.

For legal entities, VASPs must identify the natural person(s) who ultimately own or control the customer, typically defined as holding 25% plus one share or more of the voting rights or exercising control via other means. This information must also be verified.

Evidence fact bg.aml.understanding-the-purpose-and-intended not found (may have been renamed).

Regular scrutiny of transactions undertaken throughout the course of the business relationship to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile.

Keeping customer documents, data, and information up-to-date.

Politically Exposed Persons (PEPs): Customers who hold or have held prominent public functions, their family members, or close associates.

High-Risk Third Countries: Transactions involving customers or beneficial owners from countries identified by the EU or FATF as having strategic AML/CFT deficiencies.

Complex, Unusual, Large Transactions, or Unusual Patterns: Transactions that have no apparent economic or lawful purpose.

Since the Markets in Crypto-Assets Act (SG No. 54/2025) the FSC sanctions MiCA breaches under Article 37 (natural persons BGN 1,400 to 700,000; legal persons up to the higher of BGN 5,000,000 or 1.5% to 6.25% of annual turnover, depending on the provision) and travel-rule breaches under Article 39; on its § 5(3) list of former NRA-registered VASPs the FSC has cancelled 47 registrations by decisions dated 12 August 2025 to 24 June 2026. Amounts are stated in BGN as written in the Act; Bulgaria adopted the euro on 1 January 2026 at 1.95583 BGN per EUR.

Outcome: Administrative fines, cessation of non-compliant activities, and potential criminal investigations in severe cases of money laundering.

Legal Basis: EU sanctions are typically imposed through Council Decisions and implemented via Council Regulations. These Regulations are directly applicable in all EU Member States without the need for national transposition.