Based on these findings it was concluded that, overall, Bulgaria is meeting expectations in relation to sorting, preparing and validating the information. It was also noted that there is room for improvement with respect to properly preparing and formatting the information. Bulgaria is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Bulgaria should review its systems and procedures for sorting, preparing and validating the information to send to its exchange partners, to ensure they meet the requirements of the AEOI Standard.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Bulgaria linked to the CTS and the CCN, which is used for exchanges within the EU.
Based on these findings it was concluded that Bulgaria is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Bulgaria is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
Feedback from Bulgaria’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Bulgaria and therefore with respect to Bulgaria’s implementation of this requirement.
Based on these findings it was concluded that Bulgaria is fully meeting expectations in relation to exchanging the information in a timely manner. Bulgaria is encouraged to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Bulgaria’s exchange partners did not raise any concerns with Bulgaria’s use of the agreed transmission methods and therefore with Bulgaria’s implementation of this requirement.
Based on these findings it was concluded that Bulgaria is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Bulgaria is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
Findings:
Feedback from Bulgaria’s exchange partners did not raise any concerns with respect to Bulgaria’s receipt of the information and therefore with Bulgaria’s implementation of these requirements.
Based on these findings it was concluded that Bulgaria is fully meeting expectations in relation to the receipt of the information. Bulgaria is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
Bulgaria appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by Bulgaria’s exchange partners and therefore with respect to Bulgaria’s implementation of these requirements.
Based on these findings it was concluded that Bulgaria appears to be fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Bulgaria is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.