Global sanctions guide

British Virgin Islands
  1. Does Bulgaria have a sanctions regime in place?


  1. 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.

  1. 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 (ie not in implementation of) sanctions imposed by the UN and the EU.

However, 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.

  1. 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

  • prohibition to provide financial services, funds, financial assets or other property to any of the sanctioned subjects

  1. Does Bulgaria 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

  • 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.

  1. Are there any other lists related to sanctions?


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

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

  • 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.

  1. 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 BGN 2,000 to BGN 5,000 (approx. EUR 1,000 to EUR 2,500) for individuals, and BGN 20,000 to BGN 50,000 (approx. EUR 10,500 to EUR 26,000) for legal entities, unless the act committed constitutes a criminal offence, in which case the person will be penalized according to the Criminal Code.

In addition, anything given by the parties to a transaction carried out in violation of imposed sanctions shall be forfeited to the state.

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

The officials of the Ministry of Interior are empowered to control whether the LMFT regime has been breached, and the Minister of Interior or officials authorized by him are empowered 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

Contributor law firm

Kamen Gogov, Djingov, Gouginski, Kyutchukov & Velichkov, 10 Tsar Osvoboditel Blvd., Sofia 1000, Bulgaria

T: (+359) 2 932 1100
F: (+359) 2 980 3586