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Romania's AML obligations for crypto service providers: GEO 111/2020 to MiCA

By Szilaghi Editorial TeamPublished Updated 3 min

Key takeaways

  • GEO 111/2020, adopted on 1 July 2020, amended Law 129/2019 so that crypto-to-fiat exchange services and custodian wallet providers became AML reporting entities in Romania, implementing EU Directive 2018/843 (AMLD5).
  • GEO 111/2020 also required crypto providers to be authorized or registered through the Ministry of Public Finance, but the procedure was never adopted and OUG 10/2025 dropped the requirement.
  • OUG 10/2025, in force since 13 March 2025, aligned Law 129/2019 with MiCA (Regulation (EU) 2023/1114), classed crypto-asset service providers as financial institutions and made ASF their main supervisor.
  • Since 1 July 2026, crypto-asset service providers without a MiCA authorization can no longer serve clients in Romania, and from 2026 they must report users' transactions to ANAF under GEO 71/2025 (DAC8).

In July 2020 Romania brought crypto businesses inside its anti-money laundering law. Government Emergency Ordinance (GEO) 111/2020, adopted on 1 July 2020, amended Law 129/2019 so that providers exchanging virtual currencies for fiat money and custodian wallet providers became AML reporting entities. Despite our original headline, the rules targeted service providers, not token issuers. Six years on, that national regime has been absorbed into the EU’s MiCA framework: since 1 July 2026, a crypto-asset service provider needs a MiCA authorization to serve Romanian clients.

Why the rules came in

The EU’s fifth AML directive, Directive (EU) 2018/843, extended AML duties to virtual-currency exchanges and wallet providers. The concern was the ease of opening anonymous accounts, converting illicit funds and moving them across borders.

Figures cited at the time, in a Deloitte Romania analysis, showed the scale. A US analytics firm estimated that criminal organizations moved about $2.8 billion in Bitcoin through exchanges in 2019, up from roughly $1 billion in 2018. A separate study of 45 million transactions on 20 leading exchanges, covering January 2009 to September 2018, put laundered Bitcoin at about 380,000 BTC, then worth some $2.5 billion.

What GEO 111/2020 required

Under Law 129/2019 as amended, three groups had to apply AML/CFT rules to their activity in Romania:

  • providers of exchange services between virtual currencies and fiat currencies;
  • custodian (digital) wallet providers;
  • e-money and payment institutions from other EU member states providing services in Romania.

Their core duties were customer due diligence, including an assessment of how the service could be misused; identification of beneficial owners; and monitoring and reporting of suspicious transactions to ONPCSB, Romania’s financial intelligence unit.

Exchanges and wallet providers also had to be authorized or registered through a process coordinated by the Ministry of Public Finance. E-money and payment institutions had to bind their Romanian agents and distributors contractually to Law 129/2019 and verify compliance.

The broader framework is covered in our post on how Romania transposed the EU money laundering directive.

What happened to the registration regime

The Ministry of Finance authorization procedure was never adopted by government decision, so the registration requirement in Law 129/2019 did not work in practice. Providers notified ONPCSB and operated as reporting entities without a Romanian license. Our earlier post on Romanian cryptocurrency legislation describes that period.

What applies now (2026)

MiCA licensing

Regulation (EU) 2023/1114 (MiCA) created a single EU license for crypto-asset service providers. Romania implemented it through OUG 10/2025, in force since 13 March 2025. The key points:

  • Supervisors. ASF, the Financial Supervisory Authority, authorizes and supervises crypto-asset service providers. The National Bank of Romania supervises banks and e-money issuers that offer crypto services.
  • Transition. Providers registered with ONPCSB before 30 December 2024 could continue under national rules until 1 July 2026. Since that date, only MiCA-authorized providers, licensed by ASF or passported from another member state, may serve Romanian clients.
  • Cross-border providers. An EU provider operating in Romania without a branch must name a central contact point for ASF or BNR.

AML after OUG 10/2025

OUG 10/2025 replaced “virtual currency” and “digital wallet provider” in Law 129/2019 with MiCA’s “crypto-asset” and “crypto-asset service provider”, and classed these providers as financial institutions. It also:

  • applied the EU travel rule, Regulation (EU) 2023/1113, to crypto transfers;
  • required risk assessment of transfers to and from unhosted wallets;
  • added enhanced checks for correspondent relationships with non-EU providers;
  • lowered the due-diligence threshold for occasional transfers of funds to €1,000.

The old Ministry of Finance registration requirement was removed.

Tax reporting

GEO 71/2025 transposed the EU DAC8 directive. Crypto-asset service providers and operators must report users’ transactions to ANAF each year, starting with 2026 transactions due by 15 March 2027. Fines run from RON 20,000 to 150,000. The rate at which individuals are taxed on crypto gains has itself been the subject of repeated legislative change since 2025, so check the current rule before filing.

Crypto and gambling in Romania

For our iGaming clients, two points follow. Payment providers serving ONJN licensees are themselves supervised for AML, and payment rails into Romania now have to come from authorized providers. And offshore crypto betting remains unlicensed in Romania: ONJN has blacklisted crypto platforms, including Polymarket, as we report in Polymarket blacklisted in Romania.

Our payments and compliance teams help operators and suppliers map their payment providers to MiCA and Law 129/2019. Contact us for a review.

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Frequently asked questions

Who regulates crypto exchanges in Romania in 2026?

The Financial Supervisory Authority (ASF) is the main competent authority under MiCA for crypto-asset service providers, while the National Bank of Romania supervises credit institutions and e-money issuers that provide crypto services. ONPCSB remains Romania's financial intelligence unit for suspicious-transaction reports.

Do crypto platforms need a license to serve Romanian clients?

Yes. The MiCA transitional period for providers registered before 30 December 2024 ended on 1 July 2026. From that date, a provider needs a MiCA authorization from ASF or from another EU member state's regulator, passported into Romania.

Do crypto exchanges report to ANAF?

Yes. GEO 71/2025, which transposes the EU DAC8 directive, requires crypto-asset service providers and operators to report users' transactions to ANAF annually. The first report covers 2026 and is due by 15 March 2027; fines range from RON 20,000 to 150,000.

Alex Szilaghi

Reviewed by Alex Szilaghi

Founder of Szilaghi Consulting. More than twenty years in gambling licensing and corporate structuring across EU, UK, Canadian and offshore jurisdictions, based in Romania and working before ONJN on Class 1 and Class 2 files. We act as Romanian representative and local director for foreign ONJN licensees and file their monthly regulatory reports, so these guides reflect how the rules are applied in practice, not only how they read.

Last legal review . Updated 9 October 2026. General information, not legal advice.

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