In the present Bulgarian legal framework, cryptocurrencies (Bitcoin, altcoins) are still perceived, audited and declared before NRA (National Revenue Agency) as a financial asset. Their legal status got some development with the amendment to the Anti-money Laundering Act (AML Act) from November 2019. Generally, its importance, which we have discussed here, is in the following three aspects:
• cryptocurrency-related service providers are among the obliged subjects under AML Act (Art. 4, p. 38 and 39), which means that they have to adjust their activity to the legal requirements for prevention against money laundering, otherwise sanctions may follow;
• for the very first time a legal definition of virtual currencies has been provided, namely “any digital representation of value that is not issued or guaranteed by a central bank or a public authority, is not necessarily attached to a legally established currency and does not possess a legal status of currency or money, but is accepted by natural or legal persons as a means of exchange and which can be transferred, stored and traded electronically”;
• a registration regime with NRA is set in place as mandatory for some cryptocurrency-related service providers (those under the AML Act).
Thus, in August last year, the Ministry of Finance issued Ordinance No.…
