In recent years, the cryptocurrency market has experienced rapid growth, leading to increased regulatory scrutiny worldwide. Bulgaria is no exception, with recent amendments to the Anti-Money Laundering Act (AML) and related regulations impacting companies operating within the cryptocurrency sphere. One significant change is the requirement for companies already registered as virtual currencies exchange service providers to re-register in the electronic public register maintained by the National Revenue Agency (NRA). These new regulations came into effect on March 22, 2024. Аll entities currently registered with the NRA must initiate the re-registration process up to May 22, 2024. However, amid these regulatory changes, there are notable opportunities. 

The new regulations may also present a valuable opportunity for companies. As part of the re-registration process, businesses can now broaden their service offerings without the burden of extra state fees. This includes: (i) engaging in the transfer or exchange of virtual assets; (ii) providing services for the storage and management of virtual assets which grant control over these assets, and (ii) handling services related to the public offering of virtual assets.

This expansion allows companies to enhance their capabilities and potentially reach new markets and customers.

The re-registration application necessitates supplementary documentation, including a specialised declaration signed with a qualified electronic signature confirming the absence of criminal records, no prior management roles in insolvent companies, and no disqualifications from positions of significant responsibility. Non-Bulgarian citizens must also provide documents verifying no criminal convictions and no restrictions on holding senior management positions. These requirements apply to individuals holding key roles within the applicant company, such as managers, directors, procurators, members of the management or control body, and/or beneficial owners.

The application is submitted electronically only, with a qualified electronic signature. It shall be underscored that failure to submit an application for re-registration within the specified period will result in automatic deregistration from the register and the inability to conduct business activities connected to the exchange of crypto against fiat and vice versa, custodian wallet services, transfer or exchange of virtual assets, storage and management of virtual assets, enabling control over the assets or services relating to the public offering of virtual assets

In essence, navigating the re-registration process for crypto exchanges and wallet providers is imperative to maintain legal compliance within Bulgaria’s dynamic regulatory landscape. By meticulously following outlined requirements and deadlines, entities can mitigate disruptions to their operations while upholding regulatory standards.

If you require any assistance during this process, rest assured, we are fully equipped to support you. At Progressive Lawyers, we pride ourselves on being pioneers in Bulgaria’s legal landscape, particularly in the dynamic realm of Web 3 consultancy. With our wealth of experience and expertise, we offer a comprehensive suite of services tailored to your needs.