Public Romania AML/CFT research preview for retail banking, payments/e-money and crypto, with selected corporate, private-banking and wealth scenarios. National requirements remain under Romanian-language source and applicability review. Directly applicable EU transfer rules are separated from Romanian measures and future EU AML rules. This is not a complete legal handbook, compliance approval or operational workflow test.
Preview of legislation and requirement mapping for Romania
Requirement
Source type
Authority
Supporting provision
Review pending
Classify the Romanian legal entity, actual activity and supervisory category before selecting AML controls.
legislation
Portal Legislativ / Parliament of Romania
Law 129/2019 Article 5(1)(a)-(b), Articles 27(1) and 28(1); OUG 53/2022 Article I item 1 inserting Article 30^2(1)-(2); Order 181/2026 Article I(1)-(2) and replacement Annex. The Law 129 text is the consolidation whose displayed history ends 19 December 2025; later perimeter changes remain under review.
Review pending
Build the control model from the entity's legal scope and documented money-laundering and terrorist-financing risks, not a national risk score copied to each customer.
legislation
Portal Legislativ / Parliament of Romania
Law 129/2019 Articles 1(5)(b), 1(8) and 24(1)-(2) in the consolidation whose history ends 19 December 2025; sector-specific additions and later amendments require revalidation.
Review pending
Map the applicable customer-due-diligence trigger, identify the customer and understand the purpose and intended nature of the relationship.
legislation
Portal Legislativ / Parliament of Romania
Law 129/2019 Article 11(1)(a), (c) and (8), and Article 13(1), in the consolidation whose history ends 19 December 2025; the exact current 2026 text and product-specific limbs remain under review.
Review pending
Record how customer and representative identity was checked, which source was used and why it was suitable for the case.
legislation
Portal Legislativ / Parliament of Romania
Law 129/2019 Article 11(1)(a), (4) and (8), in the consolidation whose history ends 19 December 2025; current accepted methods and sector exceptions require revalidation.
Review pending
Determine whether a customer or beneficial owner falls within the applicable politically exposed person rules and document the resulting measures and approval route.
legislation
Portal Legislativ / Parliament of Romania
Law 129/2019 Article 3(1)-(5), Article 11(3), and Article 17(1)(c), (9)-(10) in the consolidation whose history ends 19 December 2025; later amendments and the full current branch remain under review.
legislation / Review pending
Determine the obliged-entity and supervisor perimeter
Unverified research interpretation
Classify the Romanian legal entity, actual activity and supervisory category before selecting AML controls.
Research explanation under review
A label such as bank, fintech, payments or crypto is not enough to assign the applicable Romanian AML regime. First identify the legal person, its activity and permissions, establishment or branch facts, and the statutory category. Confirm whether BNR, ASF, ONPCSB or another authority has the relevant AML role for that category.
Law 129/2019 Article 5(1)(a)-(b), Articles 27(1) and 28(1); OUG 53/2022 Article I item 1 inserting Article 30^2(1)-(2); Order 181/2026 Article I(1)-(2) and replacement Annex. The Law 129 text is the consolidation whose displayed history ends 19 December 2025; later perimeter changes remain under review.
Source check failed
Portal Legislativ / Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official Portal Legislativ consolidated view reopened 30 September 2026; latest displayed consolidation history is 19 December 2025. That official view states RON-equivalent EUR 10,000 in Article 7(3). A separate 48-page ONPCSB-hosted PDF credits Eurolex and is supplementary reproduction evidence, not an authentic Gazette original. Full 2026 amendment and provision-level currentness review remains open.
The official Portal page is a live consolidated-text view, not a retained source file; its latest displayed consolidation is dated 19 December 2025. Article 7(3) on that official view states RON-equivalent EUR 10,000, matching the retained ONPCSB-hosted Eurolex reproduction and Order 191/2023 Annex 3. This resolves the earlier EUR 15,000 package transcription for the latest displayed consolidation, but does not establish a complete 2026 amendment sweep or current form/channel operation. The separate Article 7(5) EUR 2,000 remittance branch and Article 7(7) three-working-day period remain subject to currentness and applicability review.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Conditions
Apply only after confirming the exact obliged-person class, entity status, activity and territorial facts.
Exceptions
This row does not decide a named firm's authorisation, AML supervisor or complete non-bank/crypto perimeter.
Evidence diagnostics
Record ID
ro-obliged-entity-perimeter
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Document the entity's AML risk assessment and control governance
Unverified research interpretation
Build the control model from the entity's legal scope and documented money-laundering and terrorist-financing risks, not a national risk score copied to each customer.
Research explanation under review
The package maps the national AML framework to an entity-level risk and governance question. Sector rules may add requirements for the institution's policies, accountable officers, risk assessment, monitoring and testing. The 2026 national-risk update is contextual evidence, not a prescribed customer score or a substitute for the firm's own assessment.
Law 129/2019 Articles 1(5)(b), 1(8) and 24(1)-(2) in the consolidation whose history ends 19 December 2025; sector-specific additions and later amendments require revalidation.
Source check failed
Portal Legislativ / Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official Portal Legislativ consolidated view reopened 30 September 2026; latest displayed consolidation history is 19 December 2025. That official view states RON-equivalent EUR 10,000 in Article 7(3). A separate 48-page ONPCSB-hosted PDF credits Eurolex and is supplementary reproduction evidence, not an authentic Gazette original. Full 2026 amendment and provision-level currentness review remains open.
The official Portal page is a live consolidated-text view, not a retained source file; its latest displayed consolidation is dated 19 December 2025. Article 7(3) on that official view states RON-equivalent EUR 10,000, matching the retained ONPCSB-hosted Eurolex reproduction and Order 191/2023 Annex 3. This resolves the earlier EUR 15,000 package transcription for the latest displayed consolidation, but does not establish a complete 2026 amendment sweep or current form/channel operation. The separate Article 7(5) EUR 2,000 remittance branch and Article 7(7) three-working-day period remain subject to currentness and applicability review.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Conditions
Map the risk and governance duties to the confirmed entity type and supervisor.
Exceptions
No universal risk scale, sector rating, control frequency or customer outcome is asserted.
Evidence diagnostics
Record ID
ro-governance-risk-assessment
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Identify the customer and understand the relationship
Unverified research interpretation
Map the applicable customer-due-diligence trigger, identify the customer and understand the purpose and intended nature of the relationship.
Research explanation under review
Law 129/2019 is the national baseline for customer due diligence, but this package does not yet resolve all trigger conditions, occasional-transaction rules, simplified measures or product-specific exceptions. For a company or legal arrangement, identify the customer separately from its representatives and people who ultimately own or control it.
Law 129/2019 Article 11(1)(a), (c) and (8), and Article 13(1), in the consolidation whose history ends 19 December 2025; the exact current 2026 text and product-specific limbs remain under review.
Source check failed
Portal Legislativ / Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official Portal Legislativ consolidated view reopened 30 September 2026; latest displayed consolidation history is 19 December 2025. That official view states RON-equivalent EUR 10,000 in Article 7(3). A separate 48-page ONPCSB-hosted PDF credits Eurolex and is supplementary reproduction evidence, not an authentic Gazette original. Full 2026 amendment and provision-level currentness review remains open.
The official Portal page is a live consolidated-text view, not a retained source file; its latest displayed consolidation is dated 19 December 2025. Article 7(3) on that official view states RON-equivalent EUR 10,000, matching the retained ONPCSB-hosted Eurolex reproduction and Order 191/2023 Annex 3. This resolves the earlier EUR 15,000 package transcription for the latest displayed consolidation, but does not establish a complete 2026 amendment sweep or current form/channel operation. The separate Article 7(5) EUR 2,000 remittance branch and Article 7(7) three-working-day period remain subject to currentness and applicability review.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Conditions
Confirm the obliged-entity class and the relationship or occasional-transaction trigger before applying a CDD branch.
Exceptions
This mapping does not provide a universal identity-document package or amount threshold.
Evidence diagnostics
Record ID
ro-cdd-identification-purpose
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
cdd
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Verify identity using the applicable reliable evidence
Unverified research interpretation
Record how customer and representative identity was checked, which source was used and why it was suitable for the case.
Research explanation under review
The Romanian CDD provisions require identity-related measures, but the retained research inventory does not establish a current exhaustive Romanian list of acceptable documents or electronic verification methods. The applicable method depends on the person, activity, channel and statutory exceptions.
Law 129/2019 Article 11(1)(a), (4) and (8), in the consolidation whose history ends 19 December 2025; current accepted methods and sector exceptions require revalidation.
Source check failed
Portal Legislativ / Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official Portal Legislativ consolidated view reopened 30 September 2026; latest displayed consolidation history is 19 December 2025. That official view states RON-equivalent EUR 10,000 in Article 7(3). A separate 48-page ONPCSB-hosted PDF credits Eurolex and is supplementary reproduction evidence, not an authentic Gazette original. Full 2026 amendment and provision-level currentness review remains open.
The official Portal page is a live consolidated-text view, not a retained source file; its latest displayed consolidation is dated 19 December 2025. Article 7(3) on that official view states RON-equivalent EUR 10,000, matching the retained ONPCSB-hosted Eurolex reproduction and Order 191/2023 Annex 3. This resolves the earlier EUR 15,000 package transcription for the latest displayed consolidation, but does not establish a complete 2026 amendment sweep or current form/channel operation. The separate Article 7(5) EUR 2,000 remittance branch and Article 7(7) three-working-day period remain subject to currentness and applicability review.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Conditions
Separate information collected from the process and evidence used to verify it.
Exceptions
No Romanian identity-document list or eID method is approved by this draft.
Evidence diagnostics
Record ID
ro-cdd-verification
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
verification
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Assess PEP exposure and apply the relevant enhanced-diligence branch
Unverified research interpretation
Determine whether a customer or beneficial owner falls within the applicable politically exposed person rules and document the resulting measures and approval route.
Research explanation under review
The Romanian definition, family-member and close-associate scope, former-PEP treatment, approval requirements and source-of-wealth/funds measures must be checked against the current Romanian text and the customer's facts. A screening alert alone is not a confirmed PEP determination, and PEP status alone is not a rejection decision.
Law 129/2019 Article 3(1)-(5), Article 11(3), and Article 17(1)(c), (9)-(10) in the consolidation whose history ends 19 December 2025; later amendments and the full current branch remain under review.
Source check failed
Portal Legislativ / Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official Portal Legislativ consolidated view reopened 30 September 2026; latest displayed consolidation history is 19 December 2025. That official view states RON-equivalent EUR 10,000 in Article 7(3). A separate 48-page ONPCSB-hosted PDF credits Eurolex and is supplementary reproduction evidence, not an authentic Gazette original. Full 2026 amendment and provision-level currentness review remains open.
The official Portal page is a live consolidated-text view, not a retained source file; its latest displayed consolidation is dated 19 December 2025. Article 7(3) on that official view states RON-equivalent EUR 10,000, matching the retained ONPCSB-hosted Eurolex reproduction and Order 191/2023 Annex 3. This resolves the earlier EUR 15,000 package transcription for the latest displayed consolidation, but does not establish a complete 2026 amendment sweep or current form/channel operation. The separate Article 7(5) EUR 2,000 remittance branch and Article 7(7) three-working-day period remain subject to currentness and applicability review.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Conditions
Confirm the PEP definition, relationship, role and duration against the current national text before deciding the case.
Exceptions
No automatic decline, risk score or universal evidence list is asserted.
Evidence diagnostics
Record ID
ro-pep-and-edd
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Separate sanctions screening, asset freezes and AML suspicion decisions
Unverified research interpretation
Identify the applicable sanctions measure and competent authority before deciding whether to block, report, seek authorisation or take another action.
Research explanation under review
Romania's sanctions framework is in Emergency Ordinance 202/2008 as amended. The official text states that specified UN and EU measures are binding and directly applicable, while national authorities have measure-specific roles. ONPCSB Order 64/2026 is identified as current supervisory norms for its covered entities; Order 17/2026 concerns specified transfer notices and authorisations. HG 269/2026 repealed the earlier HG 603/2011 supervision norms. This is not a live sanctions-list check or a complete freeze, ownership/control, derogation or release procedure.
OUG 202/2008 Articles 1, 3 and 8-12 in the consolidation whose history ends 19 December 2025. HG 269/2026 Articles 1-2 record the repeal/transition from HG 603/2011. Order 64/2026 is limited to entities supervised or controlled by ONPCSB; Order 17/2026 concerns specified transfer notices/authorisations. None is a universal supervisor route.
Source check failed
Government of Romania / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official consolidation shows amendments through 19 December 2025; check later instruments and exact competent-authority routes.
SHA-256
Not recorded
Source notes
The live official text confirms the national framework for implementing international sanctions and records amendments through 19 December 2025. Article 3 states that the specified UN and EU measures are binding and directly applicable. Competence and derogations are measure-specific.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Conditions
Determine the applicable UN/EU measure, person/asset nexus, ownership or control, authority route and any permission before action.
Exceptions
This package does not determine a match, authorise a transfer, direct a freeze or resolve a release request.
Evidence diagnostics
Record ID
ro-sanctions-controls
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
reporting / Review pending
Assess and submit the applicable report to ONPCSB
Unverified research interpretation
Assess the statutory suspicion test separately from threshold reports and other information requests; confirm the applicable STR form and route.
Research explanation under review
The observed Law 129 text addresses suspicious-transaction reports in Articles 6, 8 and 9. Order 191/2023 Article 1(1)(a) and Annex 1 concern the suspicious-transaction report form; its Annex 2-4 threshold reports are a different lane. Order 192/2023 approves a separate regulation on transmitting other information to ONPCSB and is not an STR form. Current forms, amendments, confidentiality details and filing routes remain under review; no live reporting operation is represented.
Law 129/2019 Articles 6(1)-(3), 8(1)-(7) and 9(1), and Order 191/2023 Article 1(1)(a) / Annex 1. Order 261/2023 postponed Order 191 Article 3's effective date to 22 November 2023. This is a 19 December 2025 law snapshot plus the observed 2023 form order, not confirmation of 2026 currentness or channel operation.
Source check failed
Portal Legislativ / Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official Portal Legislativ consolidated view reopened 30 September 2026; latest displayed consolidation history is 19 December 2025. That official view states RON-equivalent EUR 10,000 in Article 7(3). A separate 48-page ONPCSB-hosted PDF credits Eurolex and is supplementary reproduction evidence, not an authentic Gazette original. Full 2026 amendment and provision-level currentness review remains open.
The official Portal page is a live consolidated-text view, not a retained source file; its latest displayed consolidation is dated 19 December 2025. Article 7(3) on that official view states RON-equivalent EUR 10,000, matching the retained ONPCSB-hosted Eurolex reproduction and Order 191/2023 Annex 3. This resolves the earlier EUR 15,000 package transcription for the latest displayed consolidation, but does not establish a complete 2026 amendment sweep or current form/channel operation. The separate Article 7(5) EUR 2,000 remittance branch and Article 7(7) three-working-day period remain subject to currentness and applicability review.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Source check failed
ONPCSB / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
reporting
Version
Order dated 28 June 2023 and published in Official Gazette no. 625 on 10 July 2023. Article 3's 120-day commencement was postponed by Order 261/2023 to 22 November 2023. The 23-page ONPCSB-hosted Gazette issue copy was retrieved 29 September 2026; later portal nomenclature and form changes are not archived
Order 191 Article 1 and Annexes 1-5 separate suspicious reports, cash reports, external-account transfer reports, remittance reports and transmission methodology. The external-transfer annex is limited to credit and financial institutions and uses the Law 129 Article 7(3) EUR 10,000 equivalent/linked-operations wording; the cash branch is separately scoped to reporting entities. Annex 5 says reports are transmitted electronically through the ONPCSB reporting portal. Order 261/2023 postponed commencement to 22 November 2023.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Conditions
Apply only after the entity is confirmed within Law 129 Article 5 and the facts meet the Article 6 suspicion test or another specifically applicable statutory branch.
Exceptions
This row is not the cash, external-transfer or remittance reporting lane; it does not establish a live channel, accepted filing, or the current 2026 form.
Evidence diagnostics
Record ID
ro-suspicious-reporting
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Resolve incomplete CDD before starting, continuing or exiting a relationship
Unverified research interpretation
Escalate an inability to complete required CDD, determine the statutory restriction and reporting consequences, and document any separate exit decision.
Research explanation under review
The research inventory identifies Law 129/2019 CDD and reporting provisions but does not establish an independently checked Romanian failure-to-complete branch for every entity and product. Do not turn this draft into a universal automatic-closure rule. A CDD restriction, suspicious-report decision, sanctions freeze and contractual exit are distinct decisions that may interact.
Law 129/2019 Article 11(8)-(9), with the conditional suspicious-report branch in Article 6(1), in the consolidation whose history ends 19 December 2025. Current 2026 wording and separate contract, consumer, sanctions and exit consequences require review.
Source check failed
Portal Legislativ / Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official Portal Legislativ consolidated view reopened 30 September 2026; latest displayed consolidation history is 19 December 2025. That official view states RON-equivalent EUR 10,000 in Article 7(3). A separate 48-page ONPCSB-hosted PDF credits Eurolex and is supplementary reproduction evidence, not an authentic Gazette original. Full 2026 amendment and provision-level currentness review remains open.
The official Portal page is a live consolidated-text view, not a retained source file; its latest displayed consolidation is dated 19 December 2025. Article 7(3) on that official view states RON-equivalent EUR 10,000, matching the retained ONPCSB-hosted Eurolex reproduction and Order 191/2023 Annex 3. This resolves the earlier EUR 15,000 package transcription for the latest displayed consolidation, but does not establish a complete 2026 amendment sweep or current form/channel operation. The separate Article 7(5) EUR 2,000 remittance branch and Article 7(7) three-working-day period remain subject to currentness and applicability review.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Conditions
Apply Article 11(9) only where the reporting entity is unable to apply the CDD measures required in the case; assess Article 6 suspicion separately.
Exceptions
The observed snapshot bars opening an account, starting or continuing the relationship, or carrying out the occasional transaction when CDD cannot be applied. It does not establish a blanket account-closure script, residual-balance treatment, customer notice or universal STR: Article 11(9) ties an STR to reasons for suspicion.
Evidence diagnostics
Record ID
ro-failed-cdd-offboarding
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
needs review
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Apply the EU payer/payee information rules to covered fund transfers
Unverified research interpretation
For a covered funds transfer, identify the payment-service-provider role and apply the corresponding payer/payee information and missing-data procedures.
Research explanation under review
Regulation (EU) 2023/1113 applies from 30 December 2024 and is directly applicable in Member States. Its requirements differ by payer, payee and intermediary provider role and by transfer route. Article 5 contains a specific intra-Union rule; do not replace the role-specific provisions with a single data checklist. Romanian competent-authority and product mapping remain under review.
Regulation (EU) 2023/1113 Articles 4-8 and 40; Article 5 has the intra-Union funds-transfer rule. Apply the provider-role and transaction branch in the official text.
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document e2fc7eb8eff7
: unchanged, document e2fc7eb8eff7
: unchanged, document e2fc7eb8eff7
: unchanged, document e2fc7eb8eff7
: unchanged, document e2fc7eb8eff7
Conditions
The service must be a covered funds transfer and the institution must be acting in the role addressed by the cited provision.
Exceptions
Applicable derogations and payment-system-specific rules must be checked; account-number treatment under Article 5 is not a universal rule for every transfer.
Official Portal Legislativ consolidated view reopened 30 September 2026; latest displayed consolidation history is 19 December 2025. That official view states RON-equivalent EUR 10,000 in Article 7(3). A separate 48-page ONPCSB-hosted PDF credits Eurolex and is supplementary reproduction evidence, not an authentic Gazette original. Full 2026 amendment and provision-level currentness review remains open.
The official Portal page is a live consolidated-text view, not a retained source file; its latest displayed consolidation is dated 19 December 2025. Article 7(3) on that official view states RON-equivalent EUR 10,000, matching the retained ONPCSB-hosted Eurolex reproduction and Order 191/2023 Annex 3. This resolves the earlier EUR 15,000 package transcription for the latest displayed consolidation, but does not establish a complete 2026 amendment sweep or current form/channel operation. The separate Article 7(5) EUR 2,000 remittance branch and Article 7(7) three-working-day period remain subject to currentness and applicability review.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
Emergency Ordinance 10/2025 amending the Romanian AML framework
Source check failed
Government of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official instrument identified in the 28 September 2026 source inventory; approval disposition and provision-level commencement require reconciliation.
SHA-256
Not recorded
Source notes
Do not treat an official consolidation annotation about approval or rejection as an approval outcome.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
Law 86/2025 amending Law 129/2019 and related AML provisions
Source check failed
Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Published 23 May 2025; staged commencement and exact current wording require provision-by-provision review.
SHA-256
Not recorded
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
Law 164/2025 approving and modifying Emergency Ordinance 123/2022
Source check failed
Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Published 23 October 2025; exact amendment schedule and commencement remain to be reconciled to Law 129/2019.
SHA-256
Not recorded
Source notes
The source inventory identifies an added fiduciary beneficial-owner declaration duty in Law 129/2019 Article 57^1. Do not operationalise it until exact wording, affected fiduciaries and commencement have been reviewed.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
Law 224/2025 amending international-sanctions legislation and related enactments
Source check failed
Parliament of Romania
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Published 16 December 2025; later sanctions amendments and allocation of competent authorities require revalidation.
SHA-256
Not recorded
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
Emergency Ordinance 53/2022 inserting Law 129/2019 Article 30^2 activity notification
Source check failed
Government of Romania / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official act text identifies Article 30^2(1)-(2); its current text and any later amendments require revalidation.
SHA-256
Not recorded
Source notes
The inserted Article 30^2(1) applies to Law 129/2019 Article 5(1)(g)-(k) entities, not by its text to the credit/financial-institution classes in Article 5(1)(a)-(b). The original 2022 insertion is not proof of 2026 form/currentness.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
Emergency Ordinance 202/2008 on implementing international sanctions - official consolidated text
Source check failed
Government of Romania / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Official consolidation shows amendments through 19 December 2025; check later instruments and exact competent-authority routes.
SHA-256
Not recorded
Source notes
The live official text confirms the national framework for implementing international sanctions and records amendments through 19 December 2025. Article 3 states that the specified UN and EU measures are binding and directly applicable. Competence and derogations are measure-specific.
Published in Official Gazette no. 1126 on 5 December 2025; adds Article 1(3) and Articles 8^5-8^6 to OUG 202/2008.
SHA-256
Not recorded
Source notes
The official text adds OUG 202/2008 Article 1(3) and Articles 8^5-8^6 for specified unilateral sanctions of other states that are not binding on Romania but have effects there. This contextual mechanism does not convert those measures into Romanian or EU sanctions obligations.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
Government Decision 269/2026 repealing Government Decision 603/2011 sanctions-supervision norms
Source check failed
Government of Romania / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Government Decision dated 23 April 2026; published in Official Gazette no. 344 on 29 April 2026.
The official text makes HG 269/2026 the repealing instrument: Article 1 repeals HG 603/2011 and Article 2 preserves unfinished legal situations through their duration. The act was published on 29 April 2026. Its commencement and interaction with successor procedures have not been independently reconciled; it is not itself marked superseded.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
Government Decision 603/2011 former ONPCSB sanctions-supervision norms
Source check failed
Government of Romania / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
legislation
Version
Historical instrument; HG 269/2026 Article 1 expressly repeals it. Portal history shows a consolidation entry on 19 March 2021.
SHA-256
Not recorded
Source notes
Retained only to identify the repealed predecessor and explain the sanctions-supervision transition. Do not apply its former norms as current controls.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
ONPCSB Order 64/2026 and norms on implementing international sanctions
Source check failed
ONPCSB / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
supervision
Version
Order dated 4 May 2026; published in Official Gazette no. 389 on 8 May 2026. Exact scope and interaction with each sanctions regime require independent review.
No mapped requirement is available in this selected reading view.
ONPCSB Order 17/2026 on notices and authorisation requests for specified fund transfers
Source check failed
ONPCSB / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
reporting
Version
Order dated 9 February 2026; published in Official Gazette no. 120 on 12 February 2026. The full annex and activity-specific scope remain to be mapped.
No mapped requirement is available in this selected reading view.
ONPCSB Order 181/2026 amending the Article 30^2 obliged-entity activity notification form
Source check failed
ONPCSB
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
Not recorded
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
reporting
Version
Order dated 21 July 2026, published in Official Gazette no. 601 on 23 July 2026. Complete Order I and replacement notification form retained as an exact extract of Gazette pages 6-7; unrelated issue pages were excluded. The annex lists activities tied to Law 129 Article 5(1)(g)-(k), including conditional real-estate, goods and art activity branches. The extract does not establish the current electronic filing channel or live notification workflow.
Order 181 Article I(1) repeals Order 145/2022 Article 2(b)-(c), and Article I(2) replaces its annex. The form requests entity, contact, parent, notification type and activity fields. Its activity list is limited to the selected conditions under Article 5(1)(g)-(k), not the Article 5(1)(a)-(b) credit/financial-institution classes; it is not a general bank or payment-institution notification. The Gazette extract does not specify the current submission channel; do not infer one from the form's 'submit notification' label.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 36fadac9d9ec
: unchanged, document 36fadac9d9ec
: unchanged, document 36fadac9d9ec
: unchanged, document 36fadac9d9ec
: unchanged, document 36fadac9d9ec
Mapped requirements
No mapped requirement is available in this selected reading view.
ONPCSB Order 191/2023 on the form and content of reports under Law 129/2019
Source check failed
ONPCSB / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
reporting
Version
Order dated 28 June 2023 and published in Official Gazette no. 625 on 10 July 2023. Article 3's 120-day commencement was postponed by Order 261/2023 to 22 November 2023. The 23-page ONPCSB-hosted Gazette issue copy was retrieved 29 September 2026; later portal nomenclature and form changes are not archived
Order 191 Article 1 and Annexes 1-5 separate suspicious reports, cash reports, external-account transfer reports, remittance reports and transmission methodology. The external-transfer annex is limited to credit and financial institutions and uses the Law 129 Article 7(3) EUR 10,000 equivalent/linked-operations wording; the cash branch is separately scoped to reporting entities. Annex 5 says reports are transmitted electronically through the ONPCSB reporting portal. Order 261/2023 postponed commencement to 22 November 2023.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
ONPCSB Order 192/2023 and regulation on submitting other information to ONPCSB
Source check failed
ONPCSB / Portal Legislativ
Source diagnostics
Lifecycle
Source check failed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
failed
Evidence review
verification-unavailable
Type
reporting
Version
Order dated 28 June 2023 and published in Official Gazette no. 625 on 10 July 2023; the 120-day commencement date shown by the official Portal is 7 November 2023. Official Portal Legislativ text and ONPCSB's linked attachment were checked 29 September 2026; the attachment returned as a blank one-page PDF, so no valid source file is retained.
SHA-256
Not recorded
Source notes
Order 192 approves a separate regulation for information requested under Law 129 Article 33(1), not the Article 6/7 reporting forms governed by Order 191. Regulation Articles 2-3 cover reporting entities under Article 5(1) and public/private authorities or institutions from which ONPCSB requests information; Articles 4-7 require electronic transmission, generally within 15 days for non-urgent requests or the specified deadline for urgent requests. Reporting entities send via the ONPCSB reporting-system messaging function; public/private authorities and institutions send a password-protected archive and signed forwarding letter by email to onpcsb@onpcsb.ro. Exact present system behavior and any later amendments remain unverified.
Status basis
The latest source check failed.
Recent document checks
: failed
: failed
: failed
: failed
: failed
Mapped requirements
No mapped requirement is available in this selected reading view.
ONPCSB update of Romania's national ML/TF risk assessment for 2021-2024
Source changed
ONPCSB
Source diagnostics
Lifecycle
Source changed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
risk assessment
Version
Official ONPCSB landing page and 2026-cover report identified; the adoption instrument and exact publication date are not stated in the inventory.
No mapped requirement is available in this selected reading view.
Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA)
Source changed
European Union / EUR-Lex
Source diagnostics
Lifecycle
Source changed
Language
ro
Retrieved
29 Sept 2026
Extraction
Not recorded
Latest automated check
12 Oct 2026
Check outcome
changed
Evidence review
requires-revalidation
Type
legislation
Version
EU act identity and the 1 July 2026 outer date in Article 143(3) were found in the official EUR-Lex text; Romanian transition, authorisation and current consolidated amendments require revalidation.
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document c697f5275885
: unchanged, document c697f5275885
: unchanged, document c697f5275885
: unchanged, document c697f5275885
: unchanged, document c697f5275885
Mapped requirements
No mapped requirement is available in this selected reading view.
Country authority or guidance body
Oficiul Național de Prevenire și Combatere a Spălării Banilor (ONPCSB)
Romania
Role and responsibilities
Romania's Financial Intelligence Unit and an AML supervisor for the entity categories allocated to it by law. The exact reporting and supervisory route depends on the regulated person and activity.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Banca Națională a României (BNR)
Romania
Role and responsibilities
Sector supervisor for the categories assigned to BNR by Law 129/2019; this package does not decide the status or permissions of a named institution.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Autoritatea de Supraveghere Financiară (ASF)
Romania
Role and responsibilities
Sector supervisor for the categories assigned to ASF by Romanian law; investment and crypto-asset activity must be mapped to the actual legal entity, permissions and current rules.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Oficiul Național pentru Jocuri de Noroc (ONJN)
Romania
Role and responsibilities
Sector supervisor for gambling categories under the Romanian AML framework. Gambling-specific duties are outside this package's selected business lines.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Oficiul Național al Registrului Comerțului (ONRC)
Romania
Role and responsibilities
Administrator of the company beneficial-owner register for the relevant Romanian legal persons; register access and the effect of a register result require separate review.
Related sources in this handbook
Country authority or guidance body
European Union / EUR-Lex
Romania
Role and responsibilities
Official publication of directly applicable EU regulations and EU directives. National applicability, competent-authority routing and transposition remain distinct questions.
