A two-day training course on “Making effective use of circumstantial evidence in money laundering and terrorist financing investigations in Bulgaria” took place in Sofia on 3–4 June 2026. The event was organised as part of the joint efforts of the Council of Europe and the European Commission, and aimed to support Bulgarian competent authorities in addressing shortcomings identified in the 2022 MONEYVAL Mutual Evaluation Report and implementing its recommendations. Specifically, the training responded to calls for enhanced capacity building and specialisation of law enforcement, prosecutors, and other relevant staff in the effective use of circumstantial evidence in money laundering and terrorist financing (ML/TF) cases.
In this regard, the course opened with an overview of the crucial role circumstantial evidence plays in both money laundering and terrorist financing (ML/TF) cases, particularly where direct evidence is limited or unavailable. Sessions focused on distinguishing between direct and circumstantial evidence, dispelling misconceptions, and examining international best practices.
Legal standards and evidentiary thresholds under Bulgarian law were discussed, including the concepts of unexplained wealth and illicit enrichment, with insights drawn from both national and comparative case law. Experts highlighted various typologies encountered in ML/TF cases – such as complex ownership structures, unusual financial transactions, and behavioural indicators – equipping participants with practical knowledge to enhance their investigative work.
The training combined expert-led presentations with interactive group exercises, including identifying circumstantial evidence from real-case excerpts, developing evidentiary narratives, and analytical techniques for building clear evidentiary chains. Participants also practiced transforming suspicion into proof and converting intelligence into admissible evidence, culminating in a mock court exercise simulating the presentation and assessment of circumstantial evidence.
Key sessions addressed the role of the judiciary, evidentiary standards in self-laundering and stand-alone money laundering cases, and operational recommendations for day-to-day investigations. The course reinforced the importance of robust institutional coordination and provided participants with a checklist of good practices and potential pitfalls in ML/TF cases.
The event fostered practical skills development and inter-agency dialogue, supporting the further strengthening of Bulgaria’s response to financial crime and terrorist financing.
The activity was organised within the framework of the Technical Support Instrument (TSI) project on “Enhancing the anti-money laundering and countering the financing of terrorism (AML/CFT) framework in Bulgaria”, co-funded by the European Union and the Council of Europe, and implemented by the Council of Europe.