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The publication of the National Risk Assessment of Money Laundering and Terrorist Financing Risks (NRA) by the State Agency for National Security (SANS) has started the countdown towards the statutory deadlines for a wide range of obliged entities to bring their internal control environment in compliance with the legal requirements. Following a temporary suspension due to the Emergency COVID-19 State in Bulgaria, the revised deadline has now been set for 21 August 2020.

What are the key elements of the local legal framework?

—   Measures against Money Laundering Act (MAMLA), last amended 28 February 2020

—   Rules of Implementation of the MAMLA, last amended 13 March 2020

—   NRA, published by SANS on 9 January 2020

—   Measures against Terrorism Financing Act (MATFA), last amended 29 November 2019

KPMG panel of experts presented the main points to be considered in light of the AML compliance. You can download the presentation slides from the session here.

What do businesses need to prioritize?

Obliged entities need to carry out a business-wide risk assessment of their ML/TF risks in accordance with the requirements of MAMLA. The risk assessment must take into account a range of risk factors prescribed by the regulatory framework, as well as the results of the Supranational Risk Assessment issued by the European Commission (latest dated July 2019), and the NRA issued by SANS.

Obliged entities also need to bring their internal rules and procedures into conformity with the requirements of MAMLA by 21 August 2020. This includes the completion of their business-wide risk assessment, which needs to be incorporated into the internal rules.

Pursuant to last year’s MAMLA amendments, businesses no longer need to submit their internal rules to SANS. However, the rules must be internally adopted and effective within the statutory deadline, fully operational and ready for a potential regulatory inspection.

How KPMG can help

Our team of professionals has extensive international and local experience in the field of anti-money laundering compliance. We would be delighted to advise you on:

—   Assessing the impact of the legal requirements on your business and developing a risk assessment methodology tailored to your business model

—   Development or review of policies, procedures and internal rules for the control and prevention of money laundering and terrorist financing

—   Development of client risk profiling matrices and strategies for optimization of the due diligence process

—   Capacity building and capacity support of the specialized AML units

—   Conducting tailored training for employees in relation to the AML requirements.

—   Independent compliance reviews; lookback and remediation exercises

To learn more about how KPMG can help your company, get in touch with us.

Our AML team

Siana Garbolino

Siana Garbolino, Senior Manager, Legal Advisory

sgarbolino@kpmg.com

Antonova, Monika

Monika Antonova, Senior Advisor

mantonova@kpmg.com

Nina Shumarova, Senior Lawyer

nshumarova@kpmg.com

Ivan Lyubenov, Manager

ilyubenov@kpmg.com