We organise your financial profile and supporting evidence and help answer bank questions. Account opening and transaction approval remain with the bank.
A private client approached ARG wanting the bank’s checks supported by an organised file from the outset. ARG brought the client’s personal, property, and financial records together for the KYC work. Once the task was complete, the documents were easier to follow, and the client had a more manageable process for keeping the file in order.
When a Bulgarian bank reviews a private client, identity evidence is only the starting point. The bank may also need to understand the origin of particular funds, how wider wealth was accumulated, and whether the full financial story is consistent. Preparing these layers together can make the compliance process clearer before submission and when questions arise.
ARG can help when you need to
Prepare identity, address and tax-residence information, together with the real purpose and expected activity of the account or transaction.
Identify every relevant entity and the natural persons who ultimately own or control it. Include representatives, voting arrangements and documents connecting the ownership chain.
Link the event that generated the money to receipt and onward transfer. Contracts, issuer records, tax evidence and statements should reconcile with the amount being used.
Disclose public functions, significant geographic links and unusual ownership or payments. These facts can require wider wealth evidence and additional institutional approval.
Customer due diligence, often called KYC, means identifying and verifying the client, understanding the purpose of the relationship and assessing the activity expected through it. Bulgarian banks apply these duties under the Measures Against Money Laundering Act, known as ЗМИП. A passport answers who you are; it does not explain why the account is needed or whether the proposed transactions fit your circumstances.
Prepare a current identity document, address information, tax-residence details and a concise description of your employment, business or investment activity. Explain the Bulgarian connection: relocation, ownership of a local property, business operations or another genuine purpose. Give realistic expected volumes, currencies, countries and counterparties. A newly opened account expected to receive the proceeds of a company sale needs a different explanation from an account used for ordinary household expenses. Bulgarian Measures Against Money Laundering Act.
Where somebody acts for you, the institution also identifies the representative and checks their authority. A company must establish its existence, representatives and beneficial owners. The beneficial owner is ultimately a natural person; an ownership chart ending at another company leaves the central question unanswered. Control through voting arrangements or other means can matter alongside percentage ownership.
ARG helps organise a consistent account of these facts and the supporting records. The bank determines its acceptance process and whether remote identification is available for your profile. Ask about document language, originals and any appointment before making travel plans. Give the same accurate residence and ownership information throughout the file and explain legitimate differences between your residential address, correspondence address and tax residence.
Source of funds explains the economic origin of the money for a particular transaction. Source of wealth explains how the person accumulated their broader assets. The sending bank's name establishes a transfer route, not necessarily either source. Moving your own money between accounts does not create new wealth and does not, by itself, prove how the money was earned.
For a property payment funded by a business sale, show the sale agreement, your ownership of the interest sold, completion evidence and the receipt and onward movement of proceeds. If the purchaser paid in instalments, reconcile those amounts with the balance now available. For salary savings, employment and income records should fit the period over which the savings arose. For inheritance, link the estate documents to your entitlement, distribution and receipt. Bulgarian Measures Against Money Laundering Act.
A mixed payment needs a split explanation. Identify the amount from each source, the documents proving it and the account through which it moved. If a family member contributes, state whether the money is a gift, loan or payment on your behalf and provide the relevant evidence for that person where requested. Calling all incoming money “savings” can conceal the very distinction the reviewer needs to understand.
ARG helps arrange a chronological, document-supported explanation directed to the proposed transaction. The aim is not a persuasive story detached from the records but a file in which the reviewer can follow each material step. Where wealth arose many years ago, identify the original event and the surviving independent evidence. A declaration can have a role under the law, but it should not be treated as an automatic replacement for available underlying documents.
Borrowing requires its own evidence chain. The loan agreement explains the repayment obligation, while the lender’s payment and your account receipt establish disbursement. A related-party lender may also need to explain its ability to advance the amount. Distinguish an approved facility from money already drawn and available. Loan proceeds can fund a purchase but do not represent an equal increase in your net wealth, because the repayment liability remains. Include that liability when explaining the overall financial profile and do not describe borrowed funds as earned income.
Article 66 of the Bulgarian AML Act requires the obliged institution to clarify source of funds using at least two of the methods listed in the provision. These include information from the customer about their activity, independent public sources, information collected for other legal obligations, relevant group information and tracing money flows. It is a duty on the institution to apply appropriate methods, not a rule that every client can satisfy the law by uploading any two documents.
Select evidence for what it proves. A company-register extract can establish an ownership or management link; it does not show that a dividend was lawfully declared and paid. A tax return can corroborate reported income; it does not necessarily trace the balance now being transferred. A bank statement can show receipt and movement; it may still need the underlying contract explaining the payment. Bulgarian Measures Against Money Laundering Act.
Prepare a short evidence index stating the event, date, amount, parties and supporting record. Resolve differences in names, currencies and dates with documents or a clear reconciliation. For translated records, keep the original and the translation together. If a record is incomplete, identify the gap and seek an issuer copy or independent corroboration rather than editing the record to make it appear complete.
Article 66 also sets out the circumstances in which a written declaration is used, including exhausted or contradictory methods and certain occasional transactions where two methods cannot be applied. The institution evaluates the result and can ask further questions. ARG organises the factual and documentary response; a prepared file does not replace the bank's or notary's own assessment.
Tax residence is a factual and legal classification, not simply nationality, immigration permission or ownership of an apartment. Article 4 of the Bulgarian Personal Income Tax Act considers the statutory residence criteria, including presence for more than 183 days in a twelve-month period and the centre of vital interests. A Bulgarian permanent address does not make a person resident where the centre of vital interests is outside the country under the Act's exception.
The centre-of-interests assessment considers family, property, work or business and where the person manages their assets. Collect the actual facts: travel dates, home availability, employment, family location and management activity. A residence certificate supports a position but should correspond to those facts. Do not assume that spending fewer than 183 days in one calendar year automatically settles every domestic or treaty question. NRA: tax-residence criteria.
If two countries treat you as resident, the relevant double-tax treaty may apply a tie-breaker sequence. The exact treaty, income article and relief method must be checked for the countries involved. Bulgarian tax residents generally face taxation on worldwide income under the applicable rules, while nonresidents are assessed on relevant Bulgarian-source income. A foreign bank account does not by itself take income outside the Bulgarian analysis.
Plan the year of relocation before a major distribution, sale or retirement payment. Identify when income is legally acquired, which country can tax it, what was withheld and what evidence supports relief. ARG coordinates the facts with tax advisers in the relevant jurisdictions so returns and bank self-certifications use a coherent residence position. The objective is to claim the correct relief with evidence, not to change labels while the underlying life and business remain elsewhere.
A relocation chronology should distinguish physical arrival, availability of the family home, commencement of work and the dates of major receipts. Those events may fall in different months and need separate evidence rather than one assumed “move date”.
An SPV, or special-purpose vehicle, describes a company organised for a defined asset or project. It is not automatically a separate Bulgarian legal form or an investment licence. A privately owned EOOD or OOD holding a property should not be confused with a regulated special-investment-purpose company or a fund. The intended activity, sources of capital and services supplied to others determine whether additional regulation is relevant.
When the company buys an asset, the company becomes owner. The shareholder owns shares, not the company's apartment or bank account directly. This can make co-investment, management and transfer of ownership interests easier, but it introduces company accounts, decisions, filings and a separate tax position. Limited liability is not an assurance that the asset is protected from the company's own creditors or a shareholder's personal guarantees. Registry Agency: company registration.
Before incorporation, decide who owns the shares, who manages, which decisions require investor consent and how capital enters and leaves. Distinguish paid-in capital, shareholder loans, third-party finance and distributions. Record beneficial ownership through the whole control chain. A nominee or foreign parent does not remove disclosure obligations or a bank's need to understand the natural persons who ultimately own or control the structure.
Compare an asset sale with a share sale, personal use with commercial letting and the consequences of death or disagreement between investors. Funding and exit documents should address those scenarios before the asset is acquired. ARG coordinates the corporate, property and accounting work with the relevant professionals. The structure should solve a defined ownership or governance problem at an acceptable ongoing cost; the label SPV alone gives neither tax relief nor unrestricted access to every category of Bulgarian land.
Tell us where you live, how your business works and what you want to change. We will help you identify the questions to resolve and the next steps to consider.
Enhanced due diligence means additional scrutiny where the legally relevant risk is higher. A politically exposed person, or PEP, is defined by a prominent public function and the applicable statutory categories, with rules also covering specified family members and close associates. PEP status does not imply wrongdoing. It can require senior-management approval, examination of wealth and funds, and stronger continuing monitoring.
Explain the role, country, period of appointment and relationship to the person concerned accurately. A vague statement that the client “knows someone in government” is not a useful classification. Equally, omitting a relevant family or business connection because the funds came from a private company can leave the file incomplete. The institution assesses the statutory category and the actual risk. Bulgarian Measures Against Money Laundering Act.
Complex ownership, remote onboarding, unusual transaction patterns or relevant geographic links can lead to further checks even without a PEP connection. These checks are distinct from sanctions screening. A complete explanation of legitimate wealth does not override a legal restriction on dealing with a designated person or making a prohibited transfer. The applicable restriction must be assessed separately for the people, entities and transaction involved.
Prepare the ownership and control chart, the economic reason for the structure, the source of each material contribution and the expected destination of the funds. If an intermediary or family entity is used, explain its role instead of presenting only the last transfer. ARG helps coordinate a consistent response to specific questions, while the institution decides what additional evidence and approvals are required. Build this review into transaction deadlines before accepting an unconditional payment obligation.
The Bulgarian AML framework can require an institution to refuse an operation or relationship, or end an existing relationship, where it cannot perform the required customer due diligence. This is why a requested transfer can be delayed even after the account has been open for years. Ongoing monitoring compares new activity with the profile and evidence already held; an old account is not a permanent exemption from questions.
When the bank requests information, identify the exact issue: identity, representation, beneficial ownership, purpose, a particular receipt or the broader source of wealth. Respond in one organised package referencing the question and the supporting document. If something cannot be supplied immediately, explain what exists and what is being obtained. Repeatedly sending unrelated documents can make a simple discrepancy harder to resolve. Bulgarian Measures Against Money Laundering Act.
The institution may be legally unable to disclose all reasons for an internal assessment or reporting decision. ARG cannot override that decision or promise a particular outcome. Its practical role is to clarify the facts, correct an inconsistent submission and coordinate a documented response with the client and professional advisers. A complaint about service and a substantive compliance response serve different purposes and should be prepared accordingly.
Before committing to a completion date, ask the bank what it needs to assess the planned payment and whether the recipient or currency creates additional operational requirements. Keep enough time to obtain issuer records and translations. If a relationship ends, establish the lawful route and conditions for dealing with the balance rather than assuming it can immediately be redirected through another person. Any alternative arrangement must accurately disclose the real parties and purpose.
Keep the underlying evidence, not only the explanation submitted for one appointment. A property sale, dividend, inheritance distribution or company restructuring may be relevant again when the funds are reinvested or transferred. The completion file should show who owned the asset, the legal event, the amount received, any tax treatment and the subsequent account movements.
Separate historical evidence from details that need refreshing. An old acquisition deed may remain essential, while an identity document, residence certificate, company extract or authority to act may need an updated version. Keep a dated ownership chart and record changes to control, addresses and tax residence. Do not assume that a file accepted by one bank will be accepted unchanged by another institution or for a different transaction. Bulgarian Measures Against Money Laundering Act.
Article 67 of the Bulgarian AML Act places record-retention duties on obliged institutions, generally for five years with statutory rules governing the starting point and possible extensions. This is not a direction for an individual to destroy original title, tax or succession records after five years. Those documents may serve different legal purposes for much longer. Retention decisions should reflect the type of record, the responsible person and applicable duties.
Use secure, controlled access and identify who may share documents with a bank, notary, accountant or legal adviser. Where a family member coordinates the administration, provide the necessary authority rather than sharing account passwords. ARG can organise an indexed handover and an update list so future requests can be answered from an accurate record. The client remains able to see which originals exist, where they are held and which items still need clarification.
A document issued abroad has two separate jobs: to establish the relevant fact and to meet the Bulgarian recipient's formal requirements. A company extract may prove representation; a birth or marriage record may prove a family link; a bank statement may prove receipt. Authentication does not make an irrelevant document relevant, and translation does not resolve a contradiction in the original.
Identify the country and issuing authority before ordering an apostille or legalisation. The applicable treaty or EU rule may remove that formality for a particular public document, while another document from the same country still requires it. A private agreement, foreign notarial act and civil-status certificate should not automatically be placed on the same route. Confirm the required form with the institution or professional receiving the document. Notaries and Notarial Practice Act.
Check spelling, transliteration, former names, dates and identity numbers across the complete set. If a marriage record uses a former surname and the property deed uses another, include the connecting evidence. For a foreign company, documents may need to establish not just that it exists but who can bind it, whether additional approval is required and whether its representative's authority remains current.
Keep originals, authentication pages and translations together. Agree whether the recipient accepts a certified copy, electronic extract or original, and how current the record must be for that purpose. ARG coordinates the document list and sequencing with the Bulgarian lawyer, notary, bank or accountant. The client supplies accurate source information and signs personal declarations where required. This avoids paying for a translation or courier shipment before finding that the underlying record does not establish the fact the transaction needs.
A company's bank balance belongs to the company. A shareholder needs a lawful basis for receiving money: a dividend, remuneration, loan repayment, reimbursement or another properly documented transaction. Each has different corporate, accounting and personal-tax consequences. Describing a transfer as an owner's withdrawal does not determine its treatment.
For individual dividend income, the Bulgarian Personal Income Tax Act provides a five-percent final-tax rate under Article 46(3), subject to the relevant domestic and treaty analysis. The supplementary definition of dividend also connects to concealed profit distribution. Payments to an owner or related person that do not reflect a genuine business purpose or market terms can therefore require review even where no formal dividend was declared. NRA: dividend definitions and tax.
Before distributing, confirm the available distributable result, the competent corporate decision and any restrictions arising from financing or the company's position. The company and the individual have different tax and reporting responsibilities. A Bulgarian-resident individual's foreign dividend may require personal reporting even though a Bulgarian company ordinarily handles withholding on its own distribution. Preserve gross amounts and foreign tax evidence, not only the net bank receipt.
For the bank file, connect the shareholder's ownership to the company accounts, distribution decision, tax treatment and payment. For a shareholder loan, keep the original loan agreement and movements showing that the amount repaid was actually advanced. ARG coordinates these records with the accountant and legal adviser so that the source-of-funds explanation and financial statements agree. This is especially useful before a property purchase: the company may have sufficient cash while the individual has not yet lawfully received funds available to complete.
A portfolio can produce dividends, interest, capital gains, distributions, redemptions and income from cryptoassets. These categories can have different tax bases, exemptions, acquisition dates and reporting routes. The broker's single profit figure may combine realised and unrealised changes, fees, currencies and returns that Bulgarian law treats differently. Start from the underlying transactions, not from the amount withdrawn to your bank.
For financial-asset disposals, Article 33 of the Personal Income Tax Act provides the relevant calculation framework for an individual outside the business regime. Article 13 contains exemptions for specified financial-instrument transactions meeting the statutory conditions. An instrument being listed somewhere, or an app describing it as an ETF, does not automatically establish that the actual disposal occurred on a qualifying market or within another permitted exemption. NRA: disposal income and exemptions.
Retain acquisition and disposal confirmations, asset identifiers, trading venue, dates, quantity, price, fees and currency information. Transfers between your own brokers need a carried-forward cost record. Corporate actions, inherited or gifted assets and a missing acquisition price can require a different calculation. Cryptoasset records should distinguish purchases, disposals, exchanges and transfers between wallets you own; a wallet transfer and a sale are not the same event.
For cross-border income, obtain foreign withholding evidence and test the applicable treaty and Bulgarian relief route. A tax paid overseas is not automatically creditable in any amount or against any Bulgarian liability. ARG coordinates the transaction history and the professional tax analysis before a planned exit or distribution. The deliverable should identify taxable events, available exemptions and evidence needed for the return, while preserving the separate investment decision for the client and appropriately authorised adviser.
A gift transfers value without repayment; a loan creates an obligation to repay; inheritance arises because of death. These legal causes should match both the documents and the parties' actual intention. A transfer reference saying “family support” does not by itself establish which rules apply. This matters for municipal gift tax, bank evidence, the donor's estate plan and the recipient's later sale of an asset.
Under the Bulgarian Local Taxes and Fees Act, gifts between spouses and relatives in the direct line are exempt from gift tax. Direct line means, for example, parent and child or grandparent and grandchild. It does not automatically include siblings, cousins, an unmarried partner or a company owned by a family member. For taxable gifts, the municipality applies the legally permitted rate and valuation rules. A gift of real estate must also meet the required conveyancing form and registration procedure. NRA: gift-tax rules.
Prove the qualifying relationship with civil-status records, including the complete chain where a grandparent or a name change is involved. Establish any authentication and translation needed for foreign documents. A tax exemption does not eliminate notarial, registration or other transaction expenses. The inheritance-tax regime is separate and must be assessed against the heirs, assets and applicable rules rather than assuming all transfers within a family are identical.
For a loan, document the lender, borrower, amount, disbursement, repayment terms and any interest, then consider relevant tax-reporting duties. For a gift, preserve the donor's funding evidence as well as the recipient's receipt. ARG coordinates the choice and documentation with the professional adviser before the transfer, so the bank explanation, tax treatment and family plan describe the same transaction.
A family office is an organisational arrangement for a family's affairs, not a single Bulgarian licence covering every professional activity. It can coordinate documents, reporting, property administration, tax advisers, lawyers and banking requests. The mandate should state who makes decisions, who may sign and which professional is responsible for each legal, tax or investment task.
Personal recommendations about particular financial instruments, discretionary portfolio management and receiving or transmitting investment orders can fall within regulated investment services. The MiFID II definitions and Annex I distinguish these activities from general administration. Calling the work family-office support, charging it within a broader package or obtaining a wide power of attorney does not automatically create an exemption. Where an authorisation or a precisely applicable exemption is needed, that must be established before the activity begins. MiFID II: definitions and investment services.
Keep client assets with the appropriate bank or custody provider under the proper mandate. Identify which instructions require the owner, which need two approvals and what happens during incapacity, travel or a family dispute. A consolidated asset report should distinguish legal ownership, market estimates, borrowing, restrictions and available cash. An estimated property value is not money available to meet next month's tax liability.
ARG can coordinate a practical responsibility map, document requests and the handover between professional advisers. Agree a calendar for recurring returns, corporate decisions, lease renewals, insurance and bank updates, with a named owner for each task. Record decisions and supporting advice so the family can see why an action was taken and which facts would require it to be revisited. This creates continuity without suggesting that one coordinator exercises every regulated professional function.
Article 2(1)(k) of MiFID II contains a specific exclusion for investment advice provided in another professional activity outside the Directive where that advice is not specifically remunerated. It is not a general permission for a family office to sell investment recommendations within an undifferentiated fee. The actual professional activity, advice, remuneration and other services must fit the exclusion. It does not automatically cover portfolio management, executing orders or custody. Record the proposed activities and fee structure for the regulatory assessment before describing a mandate as exempt.
Compare the related procedures in this category, including their requirements and the stage at which you need them.
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