Bulgaria Licensed Circles Pixcell and Landmark Exports to Ten Regimes 2018-2023 via Ministry of Economy Records

The records originate from the Bulgarian Ministry of Economy and Industry dual-use licensing unit. They document repeated approvals despite the 2021 EU Dual-Use Regulation requiring human-rights risk assessments before any transfer of SS7 or location-exploitation systems. Circles, co-founded by Tal Dilian, received these licenses while Intellexa affiliates faced Greek court convictions for targeting journalists and politicians.

EU member states retain sole licensing authority under Regulation 2021/821, yet the Commission has taken no enforcement action against documented patterns of exports to states with documented spyware abuse records. This mirrors earlier cases where French, Israeli and Cypriot firms routed similar SS7 tooling through Bulgarian or Polish intermediaries to evade scrutiny, a structural gap procurement databases and court filings continue to expose.

Bulgaria claims zero-tolerance policy but supplied no post-2023 data. Continued licensing would extend real-time mobile tracking and call interception capability to additional authoritarian purchasers. Independent technical attribution of active SS7 exploitation in the listed countries remains the threshold for any future enforcement trigger.