Romania's anti-money laundering regime has undergone a material tightening. Supervisory authorities – including the Oficiul National de Prevenire si Combatere a Spalarii Banilor (National Office for Preventing and Combating Money Laundering. Known as ONPCSB) – have issued updated guidance that sharpens obligations across a broad range of obliged entities. International companies operating in Romania, or accessing Romanian financial channels, face real exposure if their internal compliance programmes have not been updated to reflect these changes.
Romania's AML legislation has been strengthened through amendments aligning national rules with the EU's anti-money laundering directives, with the updated obligations now in force. The changes expand the categories of obliged entities, introduce stricter know-your-customer (KYC) requirements, and lower certain thresholds that trigger enhanced due diligence. Companies with Romanian operations, correspondent banking relationships, or plans for bank account opening in Romania must act promptly to assess and update their compliance posture.
This alert identifies the key regulatory changes, the business categories most directly affected, and the immediate action items your organisation should prioritise.
What changed – the regulatory development and its effective date
Romania transposed successive EU anti-money laundering directives through its primary AML legislation, with the most recent reinforcing amendments entering into force in 2025. The supervisory authority ONPCSB has issued supplementary guidance clarifying how obliged entities must interpret and apply these rules in practice.
The principal changes are as follows. First, the definition of beneficial owner has been tightened. Entities must now conduct more granular verification of ultimate beneficial ownership chains, including where ownership is held through intermediary holding structures or foreign vehicles. The threshold that triggers mandatory beneficial owner identification has been reinforced, and reliance on self-declaration without independent verification is no longer considered sufficient by supervisory examiners.
Second, KYC standards for high-risk customers have been elevated. Enhanced due diligence is now required not only for politically exposed persons but also for clients from jurisdictions identified on EU and FATF monitoring lists, and for transactions that lack an obvious commercial rationale. The updated rules specify that obliged entities must document the purpose and intended nature of every business relationship at inception – not retrospectively.
Third, the rules on correspondent banking have been tightened. Romanian credit institutions maintaining correspondent banking relationships with foreign counterparties must now conduct more rigorous assessments of those counterparties' own AML controls. This directly affects the ease with which foreign banks and international businesses can access Romanian payment channels.
Fourth, the supervisory authority has signalled a more active enforcement posture. Administrative penalties under Romania's AML legislation can be significant. Supervisory inspections are more frequent. Findings of inadequate controls – even without proven money laundering – can result in public sanctions and restrictions on business activity.
For companies considering capital markets activity in Romania, it is worth noting that these AML obligations apply with equal force to investment services firms, fund managers, and intermediaries – not only to banks.
Who is affected – threshold criteria and business categories
Romania's AML legislation covers a wide range of obliged entities. The following categories face direct compliance obligations under the updated rules.
- Credit institutions and payment service providers – including foreign branches operating in Romania
- Investment firms, fund managers, and insurance companies
- Accountants, auditors, tax advisers, and notaries
- Real estate agents and property developers handling transactions above the prescribed cash threshold
- Trust and company service providers, including those assisting with corporate structuring
- Legal professionals handling financial transactions or acting on behalf of clients in commercial or real estate matters
International companies are affected in two principal ways. First, any foreign entity establishing a Romanian subsidiary or branch becomes an obliged entity in its own right if its activity falls within the categories above. Second, any foreign business that is a customer of a Romanian obliged entity. for example, seeking a credit facility. Opening a bank account. Alternatively, using a Romanian payment service provider. will be subject to more demanding KYC checks by that entity. Failure to provide compliant documentation will block access to financial services.
The beneficial owner disclosure obligation is particularly relevant for international holding structures. Romanian obliged entities are required to verify the identity of every natural person holding, directly or indirectly, more than a defined ownership or control percentage. Structures with multiple layers of foreign holding companies, or with nominee arrangements, will face heightened scrutiny.
To discuss how these changes affect your company's operations or planned transactions in Romania, contact us at info@ferrazwhitmore.com.
What to do now – immediate actions and compliance timeline
Companies affected by these changes should treat the following as priority actions. The supervisory authority has indicated that it will not apply a grace period for entities that were already subject to AML obligations before the amendments.
First, audit your current KYC files. Review all existing customer and counterparty files against the updated standards. Files that were adequate under prior rules may now be deficient. Pay particular attention to beneficial owner verification documentation and the evidence trail for source-of-funds determinations.
Second, update your internal AML policy. Ensure your written procedures reflect the current legal requirements. including the expanded categories of high-risk customers, the enhanced due diligence triggers, and the documentation standards for correspondent banking relationships. Policies drafted before the 2025 amendments are likely out of date.
Third, retrain relevant staff. AML training must be current and specific to the Romanian regulatory context. Generic EU-level training is not sufficient for demonstrating compliance to ONPCSB during a supervisory examination.
Fourth, prepare a compliant beneficial owner disclosure package. If your company is seeking bank account opening, a credit facility. Alternatively. Any other financial service in Romania, assemble documentation that clearly traces the ownership and control chain to natural persons. This should include notarised corporate documents, shareholder registers, and director identification – translated and apostilled as required.
Fifth, review correspondent banking arrangements. If your organisation uses Romanian financial institutions as intermediaries or maintains correspondent relationships with Romanian banks. Assess whether those institutions' enhanced due diligence requests are now likely to increase in scope or frequency.
For comprehensive support on AML compliance and banking regulation in Romania, our team is available through our banking and finance practice in Romania. You may also wish to review the comparable requirements in Portugal, where similar EU-driven AML updates have taken effect – see our alert on AML updates in Portugal for a cross-border comparison.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our banking and finance practice covers AML compliance, KYC structuring, bank account opening strategies, and regulatory advisory for international companies operating in Romania and across the EU. We work with institutional investors, multinational groups, and in-house legal teams that need results-oriented counsel on cross-border regulatory matters. Our attorneys have advised on AML compliance matters across both civil law and common law systems, including before Romanian and EU supervisory authorities. As an international law firm in Romania, Ferraz & Whitmore brings direct experience of ONPCSB supervisory expectations alongside broader EU regulatory context. To discuss your AML compliance position, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.