The Measures Against Money Laundering Act (ЗМИП) introduced the obligation for the persons specified in Article 4 of the Act to prepare and submit to the State Agency "National Security" (ДАНС), within the established time limits, updated or new Internal Rules for the Control and Prevention of Money Laundering and the Financing of Terrorism.

The range of obliged persons described in Article 4 of ЗМИП includes both the entities expressly listed in items 1 to 35 and others, such as:

  • leasing undertakings;
  • investment intermediaries;
  • registered auditors;
  • accountants, accounting firms, tax and legal consultants;
  • persons providing a registered office address and other similar services to legal entities;
  • real estate brokers;
  • wholesale traders;
  • pawnshops;
  • non-profit legal entities;
  • professional sports clubs, and others.

Where an activity described in Article 4 of ЗМИП is entered in the registration of a legal entity or legal arrangement but is not subject to authorisation or licensing, the activity is deemed to be carried out by way of trade, and the person falls within the requirements of the Act. This remains the case until it is proven, by means of official and accounting documents upon inspection, that the activity is not carried out professionally or is merely incidental.

Newly registered companies are obliged to adopt internal rules for the prevention of money laundering and the financing of terrorism within four months of their registration, and, where they require a licence, from the date of issue of the document.

Persons who were already obliged to apply measures against money laundering before the entry into force of the new ЗМИП must update their internal rules and send them for approval to ДАНС by 12 May 2019. Persons who fall within the requirements of the new ЗМИП for the first time must likewise adopt and submit their internal rules by the same date.

The internal rules are sent for approval by the director of the Financial Intelligence Directorate at ДАНС within 14 days of their adoption. The procedure does not require the payment of any fee to ДАНС.

Should you require assistance in preparing and submitting the documents under ЗМИП, please contact us on tel.: 0887550706 or by e-mail: [email protected]