1. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012

2.  To protect the stability and reputation of the financial sector and the single market  To ensure the freedom of capital movements and the freedom to supply financial services  To protect public morals and prevent fraud

3. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012

4.  the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting  the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity;  the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity;

5. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012  Article 2 Politically exposed persons - natural persons who are or have been entrusted with prominent public functions:  -heads of State, heads of government, ministers and deputy or assistant ministers;  members of parliaments;  members of supreme courts, of constitutional courts or of other high-level judicial bodies

6. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012  ambassadors, chargés d'affaires and high- ranking officers in the armed forces;  members of the administrative, management or supervisory bodies of State-owned enterprises  Members States to comply with till 15 December 2007

7. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012 Anti-Money Laundering Rules Data Protection

8. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012  44 recommendations concerning privacy and data protection related to the prevention of money laundering and terrorist financing  WORKING PARTY ON THE PROTECTION OF INDIVIDUALS WITH REGARD TO THE PROCESSING OF PERSONAL DATA set up under Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995

9. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012  more EU harmonization  readable public data protection policies  clear information for visible AML/CFT measures such as questionnaires and the limitation of services  the strict and clear application of the purpose limitation principle in AML/CFT laws

10. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012  the adoption of public and documented privacy and data protection compliance policies by reporting entities, FIUs and financial supervisors  balanced data sharing schemes  balanced view on data retention mechanisms  balanced view of the prohibition of tipping off that respects data protection rights

11. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012  the provision of appropriate safeguards for every profiling operation  continuous data accuracy assessments the storage of data  source and date for all AML/CFT data and assessments  internal, confidential data protection policies  the prevention of identity theft  the use of FIU disclaimers for the use of typologies

12.  Contributions by sector of business  Financial services 34 -54%  Gambling sector 14 -22%  Auditors/Accountants 4 -6%  Legal sector 6 -9%  Real estate agents 1- 2%  TCSPs 1- 2%  Other sectors 3 -5%  Total contributions 63 - 100%

13. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012 1. National data protection rules hinder an effective intra-group transfer of information - under the current data protection regime - there are serious restrictions on disclosure and transfer of personal data to third country public authorities.

14. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012  2. Difficulties with respect to data retention periods  3. General Data Protection Regulation - is not clear how widely the "lawful processing" justification will be interpreted

15. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012 financial intelligence unit of the Republic of Bulgaria - It performs functions of detection and prevention against money laundering and financing of terrorism, as well as with regard to capital flows, corruption, bribery in international trade transactions and confiscation closely interacts with the Bulgarian security and public order services and its foreign counterparts -works in a close collaboration with FATF and MONEYVAL Committee through a Financial Intelligence Directorate holds responsibility for the protection of the shared intelligence on the website of Egmont Group and the security of the site itself

16. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012  Statement No 124/2008 of Commission for Personal Data Protection, Bulgaria on the application of Law on Measures against Money Laundering in accordance with Law for personal data protection on request of the director of the State Agency for National Security

17. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012 Conclusions Privacy and data protection are established within the EU as a human right and should always be applied on the grounds of legitimate interest or the consent of the data subject. They should always be addressed and developed in this area in a positive way. The principles and obligations in this area should be dealt with in a balanced way

18. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012 Prior assessment of AML/CFT laws, procedures and projects Continued and improved cooperation amongst different stakeholders and the different supervising authorities such as DPAs, FIUs and Financial Regulators

19. Workshop on Privacy of Public Figures and Freedom of Information - Skopje, 9-10 October 2012  Desislava Borisova Senior Legal Adviser Commission for Personal Data Protection, Bulgaria dborisova@cpdp.bg