Bulgaria’s government proposes getting into line by criminalising busting of EU sanctions

Bulgaria’s government, at a meeting on August 27, proposed making busting of European Union sanctions a serious crime – a step to get into line with April 2024 EU rules.

This was announced by the Bulgarian government information service, which said that the draft amendment to the Criminal Code proposes that violations of EU restrictive measures, as well as circumventing them, would become serious crimes, punishable not only by imprisonment but also by serious fines and the possibility of deprivation of rights.

The deadline for transposing EU into local law expired on May 20 2025 and an infringement procedure has been initiated against Bulgaria by the European Commission.

The draft provides for the creation of a new chapter in the Criminal Code “Crimes against the restrictive measures of the European Union”.

The amendments, subject to approval by the National Assembly, criminalise breaches of prohibitions or restrictions on concluding or continuing transactions of any kind, including public procurement and concession contracts.

Other offences would cover breaches of bans on providing financial services or carrying out financial activities, such as financing, financial assistance, investments, investment services and deposit-taking.

The provision of non-financial services in violation of EU restrictive measures, including legal advisory, trust, accounting and auditing services, would also be criminalised.

Circumvention of EU restrictive measures would constitute a separate offence. One example would be sanctioned individuals or companies transferring funds or economic resources they own to third parties.

Drawing on an option provided by the EU directive, the bill sets a threshold of 10 000 euro. Breaches involving funds, economic resources, goods or transactions below that amount would not constitute criminal offences.

Providing humanitarian assistance to people in need in accordance with the principles of impartiality, humanity, neutrality and independence would not constitute a criminal offence, according to the Bulgarian government information service statement.

Legal counsel defending or representing clients in criminal, civil or administrative proceedings would also be exempt, including when providing legal advice on instituting or avoiding such proceedings.

(Photo: Clive Leviev-Sawyer)

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