AML Training Requirements in Bulgaria — Obligations & Program (2026)

In brief

Training is mandatory at least once per year (Art. 101(11) AMLA)
Art. 67(1) of the Implementing Regulation requires an annual training plan
Introductory training for new hires + continuing training annually
If there are no employees, managing persons must be trained
Sanction for non-compliance: BGN 2,000 – 20,000
A performance report must be prepared for each training

Legal Basis for Training

The training obligation derives from two main provisions:

Art. 101(11) of the AMLA — obligated entities under Art. 4 must ensure introductory and continuing training for their employees on the requirements of the AMLA, the Law on Measures Against Terrorism Financing (LMATF), and their implementing regulations. Training must be conducted at least once per year.
Art. 67(1) of the Implementing Regulation — obligated entities must prepare an annual training plan for introductory and continuing employee training.

These provisions apply to all categories of obligated entities listed in Art. 4 of the AMLA — banks, insurers, accountants, lawyers, notaries, NPOs (foundations and associations), and others.

Who Must Be Trained

Employees

All employees participating in AML compliance, including those with direct client contact, those processing transactions, those responsible for due diligence, and management approving business relationships.

Managing Persons Without Employees

If the obligated entity has no employees (common among NPOs), managing persons must undergo training — directors, board members, chairpersons.

SANS Contact Person

The designated contact person with the Financial Intelligence Directorate of SANS must also complete training.

Types of Training — Introductory and Continuing

Introductory Training

Conducted for new employees at the start of employment, newly established organizations, and new obligated entities upon falling within Art. 4 of the AMLA.

Continuing Training

Conducted annually for all employees and managing persons, covering legislative updates, new SANS guidelines, and emerging typologies and risks.

Training Program Content

The training program should cover:

Regulatory framework — AMLA, Implementing Regulation, LMATF, and recent amendments.
Client identification — in-person and remote identification methods.
Due diligence — standard, simplified, and enhanced due diligence.
Beneficial owners — identification methods and declarations.
Politically Exposed Persons (PEPs) — identification, verification, enhanced measures.
Source of funds — establishing origin of funds and wealth.
Suspicious transactions — red flags for recognizing suspicious clients and operations.
Reporting — procedures and timelines for notifying SANS.
High-risk persons and jurisdictions — sanctions lists and restrictive measures.
Internal rules — organizational procedures.
Case law — recent court decisions on SANS sanctions appeals.

Internal vs. External Trainers

The AMLA does not impose specific qualification requirements on trainers. Training may be conducted by:

Internal trainers — designated employees with AML knowledge. Advantage: familiarity with the organization. Disadvantage: may lack awareness of recent legislative changes.

External trainers — lawyers, law firms, or consulting firms specializing in AML. Advantage: current knowledge, independent perspective, certificates. Disadvantage: higher cost.

Documentation Requirements

Documentation is critical, as SANS will request evidence of training during inspections:

Performance report — date, duration, topics, participant names and signatures, trainer details, format.
Certificate of participation — issued to each participant.
Annual training plan — as required by Art. 67(1) of the Implementing Regulation.
Training materials — presentations, tests, case studies.

All documents must be retained for 5 years.

Specifics for NPOs (Foundations and Associations)

For foundations and associations, AML training has additional characteristics:

Focus on donor and beneficiary identification rather than traditional clients.
Special attention to source of funds for donations.
Coverage of specific NPO risks — abuse of charitable purposes, terrorism financing through NPOs.
Following Bulgaria’s FATF grey listing, NPO oversight has been significantly increased.

For more information on NPO obligations, see our article on AML compliance for NGOs and foundations.

Annual Training Plan

Under Art. 67(1) of the Implementing Regulation, every obligated entity must prepare an annual training plan covering topics, timing, target groups, format, and trainer selection. The plan is approved by management at the start of each calendar year.

Sanctions for Non-Compliance

Category	First offense	Repeated offense
Legal entities / sole traders	BGN 2,000 – 20,000	BGN 5,000 – 50,000
Natural persons	BGN 1,000 – 10,000	BGN 2,000 – 20,000
Serious / systematic violations	Up to BGN 2,000,000	—

Lack of documentation for conducted training is treated by SANS the same as failure to conduct training.

Practical Recommendations

Plan training at the start of the year — do not leave it to the last moment.
Choose an appropriate format — online training is convenient, but in-person allows better interaction.
Document everything — performance report, attendance list, certificates.
Update the program annually — include new AMLA amendments and SANS guidelines.
Cover all obligated persons — do not forget managing persons if the organization has no employees.
Retain documentation for 5 years — it will be requested during SANS inspections.
Consider external trainers — especially for initial and specialized training.

Frequently Asked Questions

How often must AML training be conducted in Bulgaria?

Under Art. 101(11) of the AMLA, obligated entities must conduct training at least once per year. In addition to annual continuing training, introductory training must be provided to new employees upon hiring.

Who must undergo AML training?

All employees of the obligated entity must undergo training. If the organization has no employees, managing persons must be trained. The designated contact person with SANS must also complete training.

What should AML training cover?

Training must cover the requirements of the AMLA and its Implementing Regulation — client identification, due diligence, recognition of suspicious transactions, politically exposed persons, beneficial owners, source of funds, and reporting procedures.

How should AML training be documented?

A performance report must be prepared for each training, including the date, topics covered, participant names, and trainer details. This report is retained and presented during SANS inspections. Participants receive a certificate of completion.

Can AML training be conducted online?

Yes. The AMLA does not restrict the format of training. It may be in-person or online. The key requirement is proper documentation — a performance report and certificate of participation for each trainee.

What is the sanction for not conducting AML training?

The sanction for failure to conduct introductory or continuing training is a pecuniary penalty of BGN 2,000 to 20,000. For repeated violations, it can reach BGN 5,000 to 50,000. For serious or systematic violations — up to BGN 2,000,000.

Who can conduct AML training?

Training can be conducted by an internal trainer (a designated employee) or an external trainer — a lawyer, consultant, or specialized firm. The law does not impose specific qualification requirements on trainers.

Must NPOs with turnover below BGN 20,000 conduct training?

Yes. The annual training obligation under Art. 101(11) of the AMLA applies to all obligated entities, including NPOs with turnover below BGN 20,000. Training is a general obligation, not an additional one.

Conclusion

AML training is not a formality — it is a legal obligation with significant penalties for non-compliance. All obligated entities must conduct at least annual training, document it properly, and retain evidence for five years. With SANS inspections intensifying following Bulgaria’s FATF grey listing, the importance of proper training documentation cannot be overstated.

For questions about AML training, the team at Innovires Legal can provide expert guidance, conduct training sessions, and help you prepare all required documentation.

This article is for informational purposes only and does not constitute legal advice. For specific questions, please contact a qualified lawyer. The information is current as of the publication date (30 March 2026) and may be affected by subsequent legislative changes.