Moldova -- AML/CFT Compliance Regulatory Overview

**Law No. 308 of 22 December 2017 on preventing and combating money laundering and terrorist financing (Legea Nr. 308 din 22.12.2017 privind prevenirea și combaterea spălării banilor și finanțării terorismului):**

This is Moldova's primary AML/CFT law.

It defines the general obligations for reporting entities, the role of the Financial Intelligence Unit (FIU), and the overall framework for AML/CFT compliance.

**Crucially, this law was amended to include VASPs as "reporting entities" (subiecți raportori) following the adoption of Law No. 182.**

**Law No. 182 of 21 July 2022 on the regulation of virtual assets (Legea Nr. 182 din 21.07.2022 privind reglementarea activelor virtuale):**

This is the cornerstone legislation specifically addressing virtual assets and VASPs in Moldova.

It transposed relevant provisions of the EU's 5th AML Directive (5AMLD) concerning virtual assets and aligns with FATF Recommendation 15 on new technologies.

**Key aspects of Law No. 182:**

**Defines "virtual assets"** and "virtual asset service providers" (VASPs).

**Establishes a licensing regime** for VASPs.

**Designates the National Bank of Moldova (BNM) as the supervisory authority** for VASPs.

**Mandates VASPs to comply with AML/CFT obligations** as per Law No. 308.

**Identification and Verification of Identity:**

**Natural Persons:** Obtain and verify the customer's name, date of birth, address, and an identification number (e.g., passport, ID card number). Verification must be based on reliable, independent source documents, data, or information.

**Legal Entities:** Obtain and verify the legal entity's name, legal form, address, registration number, and the names of directors/authorized persons.

**Beneficial Ownership (UBO):** Identify and verify the identity of the ultimate beneficial owner(s) of the customer, understanding the ownership and control structure.

**Purpose and Intended Nature of the Business Relationship:** Understand the reasons for the customer's transactions and the expected activity.

**Ongoing Monitoring:** Continuously monitor the business relationship and transactions to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile. This includes scrutinizing transactions to ensure they are not suspicious.

VASPs must classify customers and transactions based on their assessed AML/CFT risk (low, medium, high).

**Simplified Due Diligence (SDD):** May be applied in specific low-risk situations, with reduced intensity of CDD measures.

**Enhanced Due Diligence (EDD):** Must be applied in higher-risk situations, including:

Transactions involving politically exposed persons (PEPs).

Complex, unusually large transactions, or unusual patterns of transactions.

Business relationships with customers from high-risk third countries (as identified by FATF or the European Commission).

Situations where the customer is not physically present for identification (non-face-to-face relationships).

Transactions involving privacy-enhancing virtual assets.

**Sanctions Screening:** Screen customers and transactions against national and international sanctions lists.

**Obligation to Report:** VASPs are obligated to report any suspicious transactions or activities, or attempts thereof, to the Moldovan Financial Intelligence Unit (FIU).

**Content of Report:** Reports must include comprehensive details about the customer, the transaction, and the reasons for suspicion.

**Timing:** Reports must be submitted promptly, without undue delay, as soon as the suspicion arises.

**"No Tipping-Off" Rule:** VASPs, their directors, and employees are prohibited from disclosing to the customer or third parties that a suspicious transaction report has been or will be submitted to the FIU.

**Customer Due Diligence Records:** All documents and information obtained during the CDD process (identification documents, UBO information, risk assessments).

**Transaction Records:** Details of all transactions, including amounts, currencies (fiat and virtual), sender and recipient information, dates, and account numbers/virtual asset addresses.

**Business Correspondence:** Records of business correspondence related to the customer relationship and transactions.

**Retention Period:** Records must generally be kept for a period of **5 years** after the termination of the business relationship or the date of the occasional transaction. This period can be extended by specific request from authorities.

**Primary Regulator and Supervisor for VASPs: National Bank of Moldova (Banca Națională a Moldovei - BNM)**

Under Law No. 182 of 2022, the BNM is specifically designated as the licensing authority and prudential and AML/CFT supervisor for virtual asset service providers.

The BNM is responsible for issuing licenses, setting specific regulatory requirements for VASPs, conducting on-site and off-site inspections, and imposing sanctions for non-compliance.

**Official URL:** https://www.bnm.md/ (Official website of the National Bank of Moldova)

**Financial Intelligence Unit (FIU): Serviciul Prevenire și Combatere a Spălării Banilor (SPCSB) - Service for Prevention and Combating Money Laundering**

The SPCSB acts as Moldova's central national authority for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other financial intelligence.

While BNM supervises VASP compliance with AML obligations, the SPCSB is the ultimate recipient of all STRs from VASPs and other reporting entities.

**Official URL:** https://www.spcsb.gov.md/ (Official website of the SPCSB)

**Law No. 308/2017 on the prevention and combating of money laundering and terrorist financing (AML/CFT Law)** (Legea nr. 308 din 22.12.2017 cu privire la prevenirea şi combaterea spălării banilor şi finanţării terorismului).

**Official Source (Moldovan Parliament):** Legis.md - Legea nr. 308 din 22.12.2017 (in Romanian)

**VASP Definition:** Law No. 308/2017 defines "Virtual Asset Service Providers" (VASPs) and lists the activities that fall under this category. This typically includes:

Exchange between virtual assets and fiat currencies.

Exchange between one or more forms of virtual assets.

**Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets (i.e., custody services).**

Participation in and provision of financial services related to an issuer's offer and/or sale of a virtual asset.

**Registration Requirement:** Entities intending to provide VASP services, including custody, are required to register with or obtain authorization from the relevant supervisory authority responsible for AML/CFT.

**Regulatory Authority:** The primary authority for the supervision of VASPs for AML/CFT purposes in Moldova is the **Service for Prevention and Combatting Money Laundering and Terrorist Financing (SPCSB)** (Serviciul Prevenire și Combatere a Spălării Banilor).

**SPCSB Website:** SPCSB.gov.md (in Romanian)

**Application Process:** The registration process typically involves:

Demonstrating robust AML/CFT policies and procedures (e.g., Know Your Customer - KYC, Customer Due Diligence - CDD, transaction monitoring, suspicious activity reporting).

Establishing internal controls and risk assessment frameworks.

Providing information about the company's structure, management, and beneficial owners.

Ensuring that key personnel meet "fit and proper" criteria.

**Implicit vs. Explicit:** Moldova's AML/CFT Law does not explicitly detail specific, granular rules for the technical segregation of client virtual assets from the VASP's own assets in the way that traditional financial regulations (e.g., MiFID II for securities) do.

**General Principle:** However, the general principles of financial services and sound corporate governance would implicitly require a VASP, acting as a custodian, to protect client assets from insolvency or misuse. Robust internal controls and risk management, which are required for AML/CFT compliance, would typically include measures to safeguard client assets.

**Best Practice:** Segregation of client assets is considered a fundamental best practice for any legitimate custodian to prevent commingling and protect clients in case of the custodian's insolvency or operational issues. While not a direct mandate in the AML law, a responsible custodian would implement such measures.

**No Specific Mandate:** There are currently no explicit, specific legal requirements in Moldova's AML/CFT framework for VASPs offering custody services to hold dedicated insurance policies or bonding to cover potential losses of client virtual assets (e.g., from hacks, operational errors, or theft).

**General Business Insurance:** Like any business, VASPs would be expected to hold general business insurance, but this typically does not specifically cover the unique risks associated with digital asset custody.

**Best Practice:** Reputable custodians globally often obtain specialized crypto-native insurance or build up reserve funds to cover potential losses, but this is usually a market-driven decision for risk management and client confidence rather than a regulatory mandate in Moldova.

**No Explicit Mandate:** Moldova's current AML/CFT regulations do not explicitly mandate the use of cold storage for virtual assets held in custody. The focus of the law is on financial crime prevention rather than specific technological security measures.

**Implied Best Practice:** However, a VASP's internal risk management and security policies, which are part of its broader operational framework for AML/CFT compliance and sound business practice, would naturally lead to the adoption of secure storage solutions, including cold storage for a significant portion of client assets. Demonstrating robust security measures would be crucial for the "fit and proper" assessment and ongoing operational integrity.

**Not Applicable:** The term "qualified custodian" is typically specific to jurisdictions like the United States (under SEC regulations) where investment advisers must custody client assets with financial institutions that meet specific criteria.

**Moldova's Framework:** Moldova's current regulatory framework does not employ this specific terminology or impose equivalent specific qualifications *beyond* the general VASP registration and AML/CFT compliance requirements. VASPs providing custody are expected to be registered and compliant, but there isn't a separate designation of a "qualified" custodian for specific types of investors or assets.

**EU MiCA Regulation:** The **Markets in Crypto-Assets (MiCA) Regulation** is a comprehensive EU framework that will introduce detailed and harmonized rules for crypto-asset markets, including specific provisions for crypto-asset service providers (CASPs), which encompass custodians.

**Key MiCA Provisions for Custodians:** MiCA will introduce explicit requirements for CASPs providing custody, such as:

Authorization requirements (beyond just AML registration).

Organizational requirements (e.g., robust governance, internal controls, operational continuity).

Prudential requirements (e.g., own funds/capital requirements).

**Arrangements for restitution of client crypto-assets.**

Robust IT systems and security protocols.

**Official EU Source for MiCA:** EUR-Lex - Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA)

**Moldova's Alignment:** As an EU candidate country, Moldova is committed to aligning its legislation with the EU *acquis communautaire*. Therefore, it is highly probable that Moldova will eventually transpose or adapt its national laws to reflect MiCA's requirements. This would lead to a significantly more detailed and robust regulatory framework for crypto custody than currently exists, moving beyond just AML/CFT compliance to include prudential and conduct-of-business rules.

**Law No. 25 of 22.02.2016 on International Restrictive Measures (Legea nr. 25 din 22.02.2016 privind măsurile restrictive internaționale):** This is the primary law governing the implementation of UN and EU sanctions in Moldova. It establishes the framework for applying, freezing assets, and enforcing international restrictive measures.

**Reference:** Legea nr. 25 din 22.02.2016 privind măsurile restrictive internaționale (Romanian, Official Gazette)

**Law No. 308 of 22.12.2017 on Preventing and Combating Money Laundering and Terrorist Financing (Legea nr. 308 din 22.12.2017 privind prevenirea și combaterea spălării banilor și finanțării terorismului):** This is Moldova's core AML/CFT law. Crucially, it has been amended to include "virtual assets" and "virtual asset service providers" (VASPs) among the reporting entities subject to its provisions. This means VASPs are treated similarly to traditional financial institutions for AML/CFT and sanctions compliance purposes.

**Reference:** Legea nr. 308 din 22.12.2017 privind prevenirea și combaterea spălării banilor și finanțării terorismului (Romanian, Official Gazette)

**Regulatory Authority:** The **Service for Prevention and Combating Money Laundering (SPCSB - Serviciul Prevenirea și Combaterea Spălării Banilor)**, Moldova's Financial Intelligence Unit (FIU), is the primary authority responsible for overseeing AML/CFT compliance, including sanctions implementation, for reporting entities.

**UN Sanctions:** Moldova, as a UN member, is legally bound to implement UN Security Council resolutions. VASPs must screen customers and transactions against the **UN Consolidated Sanctions List**. Any assets belonging to or controlled by designated individuals or entities must be immediately frozen, and the SPCSB must be informed.

**EU Sanctions:** Moldova aligns its foreign policy with the EU and implements EU restrictive measures through Law No. 25/2016. Therefore, VASPs must screen against the **EU Consolidated Financial Sanctions List**. Similar to UN sanctions, asset freezing and reporting obligations apply.

**EU Consolidated List:** https://sanctions-map.eu/ (interactive map) or https://data.europa.eu/euodp/en/data/dataset/consolidated-list-of-persons-groups-and-entities-subject-to-eu-financial-sanctions (data download)

**OFAC Sanctions (U.S.):** While Moldovan law does not directly *implement* OFAC sanctions as its own, OFAC (Office of Foreign Assets Control) sanctions have extraterritorial reach. Moldovan VASPs that:

Deal with U.S. persons (citizens, residents, entities).

Handle transactions denominated in U.S. dollars.

Use U.S.-based service providers or infrastructure.

Engage in activities that touch the U.S. financial system.

**Implement a Risk-Based Approach:** Identify, assess, and understand their money laundering and terrorist financing risks, including sanctions risks.

**Customer Due Diligence (CDD):** Conduct robust KYC on all customers and beneficial owners, verifying their identities.

**Screening:** Screen all new and existing customers, beneficial owners, and, where appropriate, transaction counterparties against the UN and EU sanctions lists (as per Law No. 25/2016 and Law No. 308/2017). Best practice extends this to OFAC lists.

**Ongoing Monitoring:** Continuously monitor customer relationships and transactions for any red flags, including potential links to sanctioned entities or jurisdictions.

**Reporting:** Promptly report any hits against sanctions lists or suspicious activities to the SPCSB.

**Asset Freezing:** Immediately freeze any virtual assets (or other assets) belonging to or controlled by sanctioned individuals or entities upon identification, and report the action to the SPCSB.

**Sanctioned Jurisdictions:** Transactions with individuals or entities in countries or regions subject to comprehensive UN or EU sanctions (e.g., North Korea, Iran, specific regions associated with conflict) are generally prohibited or heavily restricted.

**High-Risk Jurisdictions:** While not strictly "sanctioned," transactions involving entities or individuals from jurisdictions identified as high-risk for AML/CFT by FATF (Financial Action Task Force) or the EU carry enhanced due diligence requirements and may face increased scrutiny or rejection by Moldovan VASPs.

**Local Considerations (Transnistria):** While not an internationally sanctioned *state*, the unrecognized breakaway region of Transnistria within Moldova is considered a high-risk area for financial crime. Transactions linked to this region are subject to enhanced scrutiny under general AML/CFT rules, even if not under a specific sanctions regime.

**Administrative Fines:** Substantial monetary penalties can be imposed on institutions and their management for non-compliance, including failure to conduct due diligence, report suspicious transactions, or freeze assets. Law No. 308/2017 outlines various fines.

**Reference (Law 308/2017, Articles 41-43):** https://www.legis.md/cautare/getResults?doc_id=106881&lang=ro (Romanian)

**Operational Restrictions:** The SPCSB can impose temporary or permanent restrictions on a VASP's operations.

**License Revocation:** For licensed or registered VASPs, severe or repeated non-compliance could lead to the revocation of their operational license or registration.

**Criminal Liability:** Individuals responsible for serious or intentional breaches of AML/CFT and sanctions regulations, particularly those involving active participation in money laundering or terrorist financing, may face criminal charges, including imprisonment, as outlined in the Moldovan Criminal Code.

**Reference (Criminal Code of the Republic of Moldova, Article 243 for Money Laundering):** https://www.legis.md/cautare/getResults?doc_id=129596&lang=ro (Romanian)

**Electronic Money (E-Money) / Payment Tokens:**

A stablecoin that maintains a stable value against a fiat currency (e.g., Moldovan Leu, EUR, USD), is issued on receipt of funds, and accepted as a means of payment by persons other than the issuer, could potentially be classified as **electronic money**.

The primary legislation governing this is **Law No. 114/2012 on Payment Services and Electronic Money** (Legea Nr. 114 din 18.05.2012 privind serviciile de plată şi moneda electronică).

Article 4, point 16 of this law defines "electronic money" as "monetary value stored electronically, including magnetically, representing a claim on the issuer, issued on receipt of funds for the purpose of making payment transactions, and accepted by a natural or legal person other than the electronic money issuer."

**Implication:** If a stablecoin fits this definition, it would be subject to stringent regulations applicable to electronic money institutions.

The key legislation here is **Law No. 171/2012 on the Capital Market** (Legea Nr. 171 din 11.07.2012 privind piaţa de capital).

Article 2, point 16 of this law defines "financial instruments" to include transferable securities, money market instruments, units in collective investment undertakings, and derivatives. If a stablecoin falls under the definition of "transferable securities" (e.g., shares, bonds), it would be regulated by the National Commission for Financial Markets (NCFM).

**Implication:** Issuance and trading would be subject to prospectus requirements, market integrity rules, and potentially the supervision of the NCFM.

**Virtual Assets (General Classification for AML/CFT Purposes):**

Regardless of whether they are e-money or securities, stablecoins are generally considered "virtual assets" under **Law No. 308/2017 on Preventing and Combating Money Laundering and Terrorist Financing** (Legea Nr. 308 din 22.12.2017 cu privire la prevenirea şi combaterea spălării banilor şi finanţării terorismului).

Article 4, point 27¹ of this law defines "virtual asset" as "a digital representation of value that can be digitally traded or transferred and used for payment or investment purposes; it does not include fiat currencies, securities or other financial assets already covered by other specific legislation."

**Implication:** This classification primarily subjects stablecoin issuers and service providers (exchanges, custodians) to AML/CFT obligations, including customer due diligence (CDD), transaction monitoring, and reporting suspicious activities.

**For E-money Classified Stablecoins:** If a stablecoin is classified as electronic money under Law No. 114/2012, its issuer would be considered an Electronic Money Institution (EMI).

**Article 16** of Law No. 114/2012 requires EMIs to safeguard funds received in exchange for electronic money. This typically means holding the corresponding amount in a segregated bank account at the National Bank of Moldova (BNM) or another credit institution, or investing it in low-risk assets. This effectively mandates 100% backing.

**Specifics:** The funds must be protected from claims by other creditors of the EMI, particularly in case of insolvency.

**For Securities Classified Stablecoins:** Reserve requirements as such are not directly applicable in the same way as for e-money. Instead, capital market laws would focus on issuer solvency, capital adequacy, and disclosure requirements to inform investors about the assets backing the security.

**For Algorithmic Stablecoins:** There are no specific reserve requirements, as they are not backed by traditional fiat or low-risk assets. They would generally be treated as other virtual assets for AML/CFT purposes, without specific prudential regulation.

**For E-money Classified Stablecoins:** An entity intending to issue stablecoins classified as electronic money would require a **license from the National Bank of Moldova (BNM)** to operate as an Electronic Money Institution (EMI) under **Law No. 114/2012**.

**Articles 8-15** of Law No. 114/2012 detail the strict authorization and supervisory requirements for EMIs, including minimum initial capital, fit and proper assessments for management, robust governance arrangements, and risk management procedures.

**For Securities Classified Stablecoins:** Issuers would need to comply with the authorization and disclosure requirements of the **National Commission for Financial Markets (NCFM)** under **Law No. 171/2012 on the Capital Market**. This typically involves prospectus approval, registration, and ongoing reporting obligations.

**For Virtual Asset Service Providers (VASP):** Entities providing services related to stablecoins (e.g., exchanges facilitating trading, custodians storing them) would be considered Virtual Asset Service Providers (VASPs).

Under **Law No. 308/2017 (AML/CFT)**, VASPs are subject to registration and supervision by the **Public Services Agency (ASP)** and the **National Anticorruption Center (NAC)** for AML/CFT compliance. This is a registration for AML purposes, not a prudential license for issuance.

**For E-money Classified Stablecoins:** If classified as electronic money, **Article 17** of Law No. 114/2012 grants holders of electronic money the right to redeem it at par value (1:1) at any time.

The EMI must redeem the electronic money upon request, unless the amount is below a certain threshold (e.g., 10 EUR) and the contract specifies that redemption is only possible if the amount is higher.

Any fees for redemption must be proportionate and agreed upon in the contract.

**For Securities Classified Stablecoins:** Redemption rights would be determined by the terms and conditions of the specific security, as outlined in its prospectus or offering document, subject to capital market regulations.

**For Algorithmic Stablecoins:** There are no statutory redemption rights at par value, as their stability mechanism is based on algorithms and market incentives, not direct backing by fiat currency or assets. Redemption would be governed solely by the smart contract or protocol rules.

**Law No. 114/2012 on Payment Services and Electronic Money** (Legea Nr. 114 din 18.05.2012 privind serviciile de plată şi moneda electronică):

Available (in Romanian) via the official legislative portal: https://www.legis.md/cautare/getResults?doc_id=101036&lang=ro

(Note: English translations of Moldovan laws are often unofficial or available through paid services. The official version is in Romanian.)

**Law No. 171/2012 on the Capital Market** (Legea Nr. 171 din 11.07.2012 privind piaţa de capital):

**Law No. 308/2017 on Preventing and Combating Money Laundering and Terrorist Financing** (Legea Nr. 308 din 22.12.2017 cu privire la prevenirea şi combaterea spălării banilor şi finanţării terorismului):

**National Bank of Moldova (BNM) Website:** For official statements, regulations, and licensing procedures related to payment services and e-money:

Specifically, look for sections on "Legislație" (Legislation) and "Supraveghere" (Supervision).

**National Commission for Financial Markets (NCFM) Website:** For regulations and supervision related to the capital market:

**Partial/Developing:** Moldova does not have a comprehensive, dedicated law specifically for virtual assets and VASPs, nor a full ban. It operates in a "grey area" where certain activities are implicitly covered by existing AML/CFT laws, but there's no clear licensing or regulatory regime for crypto businesses.

**Emphasis on AML/CFT:** Compliance with international FATF recommendations is a key driver.

**Consumer Protection Focus:** Regulatory bodies frequently issue warnings about the risks associated with virtual assets.

**Future EU Alignment:** As an EU candidate country, Moldova is expected to eventually adopt regulations similar to the EU's Markets in Crypto-Assets (MiCA) regulation.

**National Commission for Financial Markets (CNPF)**

**Role:** This is the primary body responsible for regulating and supervising non-banking financial markets. It has been the most vocal regarding virtual asset risks and is actively involved in drafting future legislation. It issues warnings and recommendations related to virtual assets.

**National Bank of Moldova (BNM)**

**Role:** As the central bank, the BNM is responsible for monetary policy, financial stability, and supervision of the banking sector and payment systems. While not the primary crypto regulator, its oversight extends to any interactions between traditional financial institutions and virtual assets. It has also issued warnings regarding crypto risks.

**Prevention and Combatting Money Laundering and Terrorist Financing Service (SPCSB)**

**Role:** This is Moldova's Financial Intelligence Unit (FIU) and is crucial for enforcing AML/CFT regulations, which are currently the most direct legal framework applicable to virtual asset activities.

**Date:** Enacted December 22, 2017, with subsequent amendments.

**Role:** This is the most crucial piece of legislation currently applicable to virtual asset activities. While it doesn't explicitly define or regulate "virtual assets," its broad scope requires entities dealing with "assets" and financial transactions to implement AML/CFT measures. VASPs, even if not explicitly defined, are generally expected to comply with these obligations as part of Moldova's commitment to FATF recommendations.

**Reference (Official Monitor):** Can typically be found on the official website of Moldova's Parliament (Parlamentul Republicii Moldova) or the Official Monitor (Monitorul Oficial al Republicii Moldova), though direct public URL links to specific laws can change. Search "Legea Nr. 308/2017" on official Moldovan legal databases.

**Draft Law on Virtual Assets:** The CNPF, in cooperation with other bodies, has been working on a draft law to introduce a comprehensive regulatory framework for virtual assets and VASPs, aiming for alignment with EU MiCA regulations. This draft has been under discussion for some time (since around 2021-2022) but has not yet been enacted. Its specific details are subject to change until adopted.

**Not Explicitly Banned:** There is no outright ban on owning, trading, or using cryptocurrencies for individuals in Moldova.

**"Grey Area" for Exchanges and VASPs:**

**No Specific Licensing:** Currently, there is no dedicated licensing or registration regime for cryptocurrency exchanges or other Virtual Asset Service Providers (VASPs) to operate legally *as crypto businesses*. This means any entity offering such services operates without a specific, tailored regulatory framework.

**AML/CFT Obligations:** Despite the lack of specific crypto regulation, any entity facilitating transactions involving virtual assets is generally expected to comply with the existing **Law No. 308 of 22.12.2017 on Preventing and Combatting Money Laundering and Terrorist Financing**. This would include customer due diligence, transaction monitoring, and suspicious activity reporting.

**Consumer Warnings:** Both the CNPF and BNM have issued public warnings highlighting the high risks associated with virtual assets (volatility, scams, lack of investor protection, anonymity challenges).

**Future Outlook:** The eventual adoption of a comprehensive law, likely inspired by MiCA, will introduce specific licensing requirements, operational rules, and consumer protection measures for crypto trading platforms and service providers.

**No, not yet.** Moldova's AML/CFT legislation currently does not explicitly cover virtual assets or VASPs. The MONEYVAL report concluded that there is a significant gap in the legal framework regarding these areas. Moldova was rated "Non-Compliant" (NC) for FATF Recommendation 15 (New Technologies) and implicitly cannot implement Recommendation 16 (Wire Transfers, i.e., the Travel Rule) for VAs.

Since the framework has not been adopted, there is **no effective date** for the FATF Travel Rule in Moldova.

As there is no specific legislation governing VASPs for AML/CFT purposes, there are **no defined threshold amounts** for the Travel Rule.

Currently, **no VASPs are explicitly covered** by specific AML/CFT obligations related to virtual assets and the Travel Rule. There is no licensing or registration regime for VASPs.

As there is no legal framework or effective date, there are **no technical implementation requirements** for VASPs concerning the Travel Rule.

Since there is no specific VASP regulatory framework or Travel Rule implementation, there are **no specific penalties for non-compliance** with the Travel Rule. However, general AML/CFT legislation would apply to any financial institution (traditional or otherwise) involved in illicit activities, but this does not cover the specific VASP-related obligations of the Travel Rule.

**MONEYVAL Mutual Evaluation Report on Moldova (December 2022):**

**Key finding (Excerpt from the Report Summary):** "Legal persons and arrangements providing services in the virtual assets sector (VASPs) are not yet covered by the AML/CFT legislative framework and do not fall under the supervision of AML/CFT purposes. Authorities are in the process of developing a regulatory framework for VASPs."