Bulgarian Coronavirus Payment Moratorium And Its Effect On Cross-border Financial Transactions

The Moratorium was not self-proclaimed by the Bulgarian Parliament as an overriding mandatory piece of law so the courts discretion in cross-border scenarios has been retained

1 Emergency and temporary character of the Moratorium in Bulgaria

On 24 March 2020 in the State Gazette of Bulgaria, the Measures during the Emergency Situation Act [Закон за мерките и действията по време на извънредното положение, обявено с решение на Народното събрание от 13 март 2020 г.] (the "Act") was published, whereby the Parliament of Bulgaria inter alia imposed various measures (most of them being applicable as of 24 March 2020, but some having a retroactive effect – see below) that can affect financial transactions, which will be briefly reviewed in this update (collectively referred to as the "Moratorium"). The Moratorium will apply only for the duration of the emergency [coronavirus] situation which was in turn imposed via resolution of the Parliament of Bulgaria for