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In recent months, Bulgaria has undergone significant changes to its Anti-Money Laundering (AML) legislation intending to achieve the long-overdue complete transposition of the EU 2018/843 Directive into national law and meeting the higher standards set forth in the Financial Action Task Force’s (FATF) recommendations on Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT), especially following the country’s inclusion in FATF’s so-called “grey list” of jurisdictions under increased monitoring.  Naturally, these changes give rise to a number of new obligations for businesses to comply with. The purpose of this article is to provide an overview of the most significant changes.

The Supreme Administrative Court (SAC) ordered the National Revenue Agency (NRA) to repay default interest charged on precisely defined and fully paid advance corporate income tax instalments that were not declared.

As of June 1, 2025, the traditional paper labour book will be phased out in favor of a digital alternative. All employment data will now be maintained in an electronic employment register managed by the National Revenue Agency (NRA). This transition is part of a broader effort to modernize the Labour Code and digitize employment relationships, aiming to eliminate the risks associated with physical document loss and to ensure that data is always current and accurate.

The Anti-Money Laundering and Countering Financing of Terrorism legislative package of the European Union (“EU”), proposed on 20 July 2021 by the European Commission, and approved by the European Parliament plenary this April was published in the Official Journal of the EU on 19 June. The new legislative package introduces significant regulatory changes in connection with the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, both on European and national level.

Djingov Gouginski Kyutchukov & Velichkov has advised Bianor Holding on its acquisition of Digital Lights and Prime Holding. Karastoyanov, Mitkov & Associates advised the seller of Digital Lights Dimitar Dimitrov. Shopova, Kolarova & Partners advised Prime Holding's sellers Noratex and minority shareholders.

Bulgaria has outlined a procedure for electronic labour records (ELR) in a draft Ordinance published for public consultations on 21 May 2024. The switch to ELR will take effect on 1 June 2025, as stipulated by recent amendments to the Labour Code. This represents a significant step in the long-awaited digitalisation of employment records.

On June 12, 2024, the Bulgarian Council of Ministers released a draft bill for public discussion, aiming to revise the Bulgarian Consumer Protection Act (“CPA”) to align with the requirements of the General Product Safety Regulation 2023/988 (“GPSR”) and the Class Action Directive 2020/1828 (the “Class Action Directive”).

On February 29, 2024, energy experts from Bulgaria, Croatia, Moldova, Turkiye, and Ukraine sat down for a virtual round table moderated by CEE Legal Matters Managing Editor Radu Cotarcea to discuss the key developments in the field of oil & gas over the past few years.

In The Corner Office, we ask Managing Partners at law firms across Central and Eastern Europe about their backgrounds, strategies, and responsibilities. While in the legal field maintaining client relationships is vital, there are occasions when law firms must end engagements. To explore some of the reasons that might lead to this, we asked: After accepting mandates, what have been the main reasons for which you ended up having to drop clients?

Bulgaria Knowledge Partner

Schoenherr is a leading full-service law firm providing local and international companies stellar advice that is straight to the point. With 15 offices and 4 country desks Schoenherr has a firm footprint in Central and Eastern Europe. Our lawyers are recognised leaders in their specialised areas and have a track record of getting deals done with a can-do, solution-oriented approach. Quality, flexibility, innovation and practical problem-solving in complex commercial mandates are at the core of our philosophy.

Firm's website: www.schoenherr.eu

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