Bulgaria allowed the controversial surveillance technology firm Circles to export its monitoring products to law enforcement and intelligence agencies in multiple countries with documented records of human rights abuses, according to a new report from the nonprofit Human Rights Watch (HRW).
The Export Licensing Records
HRW researchers obtained Bulgarian government export licensing documents covering a five-year period from 2018 through 2023. The records reveal that Bulgarian authorities granted export approvals enabling Circles to sell its surveillance capabilities to agencies in several nations that international watchdogs have repeatedly flagged for:
- Arbitrary detention and torture of political opponents
- Suppression of journalists and civil society groups
- Surveillance targeting ethnic and religious minorities
- Use of monitoring technologies against activists and dissidents
Who Is Circles?
Circles is an Israeli-founded surveillance technology company that developed tools capable of exploiting the global SS7 (Signaling System 7) telecommunications protocol — the aging backbone of mobile networks worldwide. SS7-based surveillance tools can:
- Track the real-time location of any mobile phone globally without the target's knowledge
- Intercept SMS messages and calls
- Operate silently with no malware installation required on the target device
Circles was previously linked to the NSO Group ecosystem and has been documented by the Citizen Lab at the University of Toronto as selling its capabilities to governments with poor human rights track records.
Bulgaria's Role
By approving the export licenses, Bulgaria served as a legal conduit for technology transfer to governments that would likely face stricter scrutiny under U.S. or EU dual-use export controls applied by other jurisdictions. The report suggests:
- Bulgarian export review processes may have been insufficient to evaluate end-use risks
- The approvals potentially violated the spirit — if not the letter — of EU export control regulations governing dual-use surveillance technology
- Foreign policy considerations may have taken precedence over human rights impact assessments
Broader Context: The Surveillance Tech Export Problem
The Circles case is part of a wider pattern documented by civil society organizations and journalists. Multiple EU member states have approved exports of surveillance tools that were subsequently used to target dissidents, journalists, and opposition politicians in authoritarian states.
Notable precedents:
- Italy and Germany have faced scrutiny over exports of FinFisher/FinSpy spyware components
- France approved exports of network monitoring equipment used in political repression
- The EU's updated dual-use regulation (2021) tightened controls but enforcement remains inconsistent
What Happens Next
Human Rights Watch is calling on:
- Bulgarian authorities to conduct an independent review of export licensing decisions made during the covered period
- EU institutions to investigate whether member state export approvals complied with EU dual-use regulations
- The European Parliament to strengthen oversight mechanisms for surveillance technology exports
- Circles to publicly disclose its full customer list and end-use commitments
The revelations add to growing international pressure for binding export controls specifically targeting commercial surveillance technology — an area where regulatory frameworks have persistently lagged behind the industry's growth.