Global sanctions guide

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


  1. Does Bulgaria implement UN sanctions?

Yes. Bulgaria is a member of the European Union, which implements UN sanctions in all member states by way of directly effective regulations.

  1. Does Bulgaria implement an autonomous sanctions regime?

No. However, the Law on Measures against Financing of Terrorism (“LMFT”) creates an autonomous regime for restrictive measures targeting persons, entities, groups and organisations which have suspected links with terrorism.

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

The measures under the LMFT are:

  • blocking/freezing of funds, financial assets and other property owned or possessed by sanctioned subjects
  • prohibiting provision of financial services, funds, financial assets or other property to sanctioned subjects
  1. Does Bulgaria maintain a list of sanctioned individuals and entities?

Yes. Bulgaria maintains a list of persons affected by LMFT measures. This list may be modified by the Council of Ministers acting on a motion by either the Minister of Interior, the Chairperson of the State Agency for National Security, or the Prosecutor General.

It includes:

  • individuals, legal entities, groups and organisations identified by the UNSC as being associated with terrorism, or with respect to whom sanctions for terrorism have been imposed by a UNSC resolution
  • individuals against whom criminal proceedings have been initiated on the grounds of alleged terrorism or related terrorist activities (as defined by the Bulgarian Criminal Code)
  • other persons identified by the competent authorities of another country or the EU
  1. Are there any other lists related to sanctions?


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

Where assets have been blocked or frozen pursuant to the LMFT, the Minister of Finance may authorise that payments or other disposals are allowed for the following purposes:

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

The authorisation 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 between BGN 2,000 to BGN 5,000 (approx. €1,000 to €2,500) for individuals, and BGN 20,000 to BGN 50,000 (approx. €10,500 to €26,000) for legal entities, unless the act committed is a criminal offence in which case the person will be penalised according to the Bulgarian 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 Ministry of Interior oversees the LMFT regime.  The Minister of Interior or officials authorised by him may impose the fines described above.

29 Shesti Septemvri Street
1000 Sofia

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: (+352) 2 932 1100
F: (+359) 2 980 3586