Information notice
Thursday, 09 January 2020 00:00

In 2019 the State Agency for National Security (SANS) continued its activity related to the organization of the national cooperation and co-ordination with regard to the National Risk Assessment of the ML and TF risks (NRA).

In preparation of the NRA a number of coordination activities were undertaken, in accordance with the CoE’s national risk assessment and management process. A permanent Interagency Working Group on National Risk Assessment and Management (NRAM WG) was established through Council of Ministers Decision and according to the requirement of art.96q Para 1 of the Law on Measures Against Money Laundering (LMML), which continued the work of the former Interagency Working Group on National Risk Assessment and Management, co-chaired by the Ministry of Interior and SANS, and serves as the ultimate decision making and oversight body of the NRA process and risk management. The NRAM WG consists of representatives of the following competent authorities:

  • State Agency for National Security (SANS)- both through the FIU (a specialised administrative directorate „Financial Intelligence” – FID-SANS) and its specialized directorates;
  • Ministry of Interior (MoI);
  • Prosecutor’s Office;
  • Bulgarian National Bank (BNB);
  • Financial Supervision Commission (FSC);
  • Commission for Combating Corruption and Illegal Assets Forfeiture (CACIAF);
  • National Revenue Agency (NRA);
  • The National Customs Agency (NCA);
  • The State Commission on Gambling (SCG);
  • Ministry of Justice (MoJ);
  • Ministry of Finance (MoF).

For the NRA process the NRAM WG used the Council of Europe’s National Risk Assessment Methodology, which is the third universal NRA methodology world-wide. In November 2019 г. the NRAM WG adopted the NRA Report prepared by the Analytical Coordination Team and the Risk Assessment and Ratings Matrix (Annex 1 to the NRA Report).

In order to assess country’s ML/TF risks, the NRA obtained information and analyses from a variety of government (the FIU, BNB, FSC, the Prosecutor’s Office, MoI, CACIAF, the National Statistics Institute and the Ministry of Economy, The National Revenue Agency, The State Commission on Gabling, The National Customs Agency, specialized directorates of SANS, etc.), regional (MONEYVAL, Europol, GRECO), international (FATF) and open sources (NGOs like Centre for the Study of Democracy). Information from foreign partner FIUs, LEAs, as well as practitioner opinions (from the public and private sectors) were also obtained and analysed.

The NRA Report adopted by the WG uses statistical data, typologies, trends and other strategic documents. All qualitative data provided for the NRA Report through questionnaires are specifically targeting recent and actual practitioner opinions. Any recent changes in the threats and vulnerabilities as well as other objective factors influencing the residual risk which are not in conformity with the previous data are discussed additionally and taken into account where relevant and justified under the NRA methodology used (i.e. its relevance could be clearly demonstrated).

Following the requirements of Recommendation 1 and Immediate Outcome 1 of the FATF, as well as the aforementioned decision, some parts of the NRA (which do not contain classified or sensitive information) shall be made publically available with the purpose of achieving a unified understanding about the ML/TF risks and taking common, targeted risk mitigating approaches.

Pursuant to the requirements mentioned above and to Art. 97, Para 2 of the LMML, the Executive Summary of the NRA report, the ML and TF Risk Events and the Risk Assessment and Ratings Matrix (Annex 1 to the NRA Report) have been published on SANS website.

According to § 6, Para 1 of the Transitional and Final Provisions of the LMML, the persons referred to in Article 4 of the LMML, for whom the obligation to apply measures against money laundering arose before the entry into force of the law, shall bring the internal rules thereof into conformity with the requirements of Article 101 of the same law within six months from the publication of the results of the national risk assessment on the website of SANS.