Anti-Money Laundering and Counter-Terrorist Financing
Bulgarian AML/CTF rules derive from the Measures Against Money Laundering Act (Закон за мерките срещу изпирането на пари, ЗМИП) and EU directives, supervised by the FSC for investment firms and by the State Agency for National Security (ДАНС) for intelligence. Core obligations: customer due diligence (CDD), including identification and verification, beneficial ownership identification, ongoing monitoring, record-keeping, and suspicious transaction reporting to the Financial Intelligence Unit (FIU, part of ДАНС).
Candidates must know enhanced due diligence for politically exposed persons (PEPs) and high-risk situations, simplified due diligence limits, and the prohibition on tipping off. Traps include assuming CDD can be skipped for existing clients (it must be updated on risk triggers), confusing the FSC with the FIU for STR filing, and forgetting that beneficial ownership must be traced to natural persons.
Rule of thumb: identify the client, the beneficial owner and the purpose of the relationship; if risk is high, enhance; if suspicion arises, report and do not tip off.
Worked example: a client requests a large transfer from an unrelated third party. The firm should apply enhanced measures, verify source of funds, and if suspicion remains, file an STR with the FIU without informing the client.