New Rules on Customer Due Diligence – Law 86/2025

Law no. 86/2025, amending Law no. 129/2019 on the prevention of money laundering and terrorist financing, was published in the Official Gazette no. 483 on May 23, 2025.

This law introduces new rules on customer due diligence (CDD) and sets out new obligations for NGOs.

Additional Customer Due Diligence Measures

  1. Real estate transactions:
  • Real estate agents must apply CDD measures for both the seller and the buyer of a property.
  1. Casinos:
  • Casinos must identify all customer transactions and match them with the customer profile created through CDD.

New Thresholds for Certain Sectors

Currency exchange offices:

  • Must apply standard CDD for transactions over EUR 2,000 (or RON equivalent), whether it’s a single operation or linked transactions.

Crypto service providers:

  • Must apply the same CDD rules for transactions of EUR 1,000 or more (RON equivalent), regardless of how many operations are involved.

Simplified CDD – New Limitations

  • Reporting entities must always identify and verify the identity of the client and the beneficial owner.
  • Simplified CDD is not allowed if there are suspicions of money laundering.

NGOs – Enhanced Monitoring

  • The National Office for the Prevention and Control of Money Laundering (ONPCSB) will monitor NGOs based on risk assessment.
  • NGOs must provide information on request to ONPCSB as part of their legal obligations.

Lawyers – Professional Secrecy Maintained

  • Although the initial draft proposed removing lawyer-client privilege, this exception has been maintained.
  • Lawyers continue to apply Law 129/2019 while respecting professional confidentiality rules.