Republic of Moldova stands at a historic juncture toward combating money laundering (ML) and terrorist financing (TF) in 2025. The latest Council of Europe MONEYVAL report also appreciated the major action Moldova has taken by improving the suggestions made in its Financial Action Task Force (FATF) in areas like customer due diligence, politically exposed persons, and targeted financial sanctions.
Nevertheless, the report indicates continued susceptibilities especially to regulation and virtual asset control of virtual assets (VAs) and virtual asset service providers (VASPs). The burden of digital finance and emerging technologies is increasingly what challenges Moldova especially because it is developing closer ties with the EU and is undertaking to offer protection to its financial system.
Moldova’s Compliance: Where Progress Has Been Made
Upgraded FATF Ratings and Legislative Reforms
The February 2025 MONEYVAL follow-up report details Moldova’s improved compliance with FATF standards. The country is now rated:
- Compliant: 9 recommendations
- Largely compliant: 25 recommendations
- Partially compliant: 6 recommendations
- Overall: 0 recommendations
These upgrades are indicative of the way Moldova is widening the scope of obligated entities and has strengthened CDD requirements & continues to enhance scrutiny of PEPs and high-risk countries. Moldova’s ratings for FATF Recommendations 6 and 7 (targeted financial sanctions for terrorism and proliferation) were upgraded to “largely compliant,” which is a sign of progress in the fight against terror financing.
Stakeholder Statements on Progress
MONEYVAL’s official statement underscores this momentum:
“The Republic of Moldova has strengthened its legal and institutional framework to combat money laundering and the financing of terrorism, but it still needs to address several shortcomings… Progress in targeted financial sanctions (Recommendations 6–7) is notable, but virtual assets (Recommendation 15) lag.”
Falk Lange, Head of the Council of Europe Office in Chișinău, also affirmed this:
“Moldova has demonstrated commitment to democracy and the rule of law. Addressing money laundering and terrorism financing is pivotal to sustaining these principles.”
The Virtual Assets Challenge: A Persistent Weakness
National Risk Assessment and Regulatory Gaps
Despite these advances, Moldova’s regulatory and supervisory framework for virtual assets and VASPs remains underdeveloped. The December 2024 National Risk Assessment (NRA) on VAs and VASPs, conducted by Moldovan authorities with support from the OSCE and World Bank, found that the country’s financial system is increasingly vulnerable to exploitation by criminal groups using digital finance channels.
The assessment recognized six primary VASP channels, starting with wallet providers, exchange and payment processors, that need immediate regulatory attention.
One of the most critical findings was the deficiency of a complete risk assessment for VAs and VASPs and is required by FATF Recommendation 15. This lack of assessment presents Moldova with new and emerging risks of ML/TF, contravenes the integrity of the financial system, and creates additional challenges in meeting international standards.
MONEYVAL’s Downgrade on Virtual Assets
Reflecting these shortcomings, MONEYVAL downgraded Moldova’s rating for FATF Recommendation 15 from “largely compliant” to “partially compliant” in 2024, and in some assessments even “non-compliant”. The report notes:
“Due to identified deficiencies, Moldova’s rating on the implementation of this updated Recommendation has been downgraded… Moldova is expected to report back to MONEYVAL on further progress to strengthen its implementation of anti-money laundering and counter terrorist financing (AML/CFT) measures in one year’s time.”
Regulatory Developments and International Partnerships
Legislative Steps and International Support
Moldova’s initial regulatory response to virtual assets began in 2017, with warnings from the National Bank of Moldova about the risks of virtual currencies. Subsequent amendments to asset declaration laws and AML/CFT legislation have expanded reporting obligations for virtual assets and increased scrutiny of financial institutions’ involvement in VA activities
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International projects have played a crucial role. The Council of Europe, with U.S. funding, has supported asset recovery, corruption prosecution, and AML/CFT capacity building. The UK-funded UNODC goAML platform has enhanced the operational capacity of Moldova’s Financial Intelligence Unit (FIU), improving the detection and analysis of suspicious transactions.
UNODC Expert Perspective
A UNODC expert commented:
“goAML isn’t just software—it’s about building a sustainable, intelligence-driven approach to combat financial crime. Moldova’s FIU is now better positioned to disrupt illicit finance.”
Latest Money Laundering and Terror Financing Instances (2025)
Regional and Local Cases
Feb 2025: Moldova law enforcement, with the assistance of Europol, took down a transnational money laundering network through cryptocurrency exchanges involved in money laundering cyber-fraud and drug trafficking. The scheme entailed treaching money using decoy VASPs across Moldova and other neighbouring jurisdictions and the exploitation of outstanding loopholes.
April 2025: A highest ranked registered shell firm in Moldova was involved in financing the logistics of a terrorist cell that was suspected in the Balkans. Their money movement that is traced using the transfer of virtual assets helped establish the failure of beneficial ownership transparency and VA regulation.
May 2025: Moldova FIU, having outlined an increase in suspicious activity, worth more than 200 million euro, related to peer-to-peer VA platforms, both of local and international organized crimes.
The urgency of sealing the loopholes in the regulation, and better monitoring of the activities involving the virtual assets is highlighted by these cases.
Ongoing Deficiencies and MONEYVAL’s Expectations
Remaining Gaps
While Moldova has addressed many deficiencies, several issues persist:
- Virtual assets and VASPs: Lack of a comprehensive risk assessment and tailored regulatory framework for VAs and VASPs.
- Customer due diligence: Some minor gaps remain, including the definition of close associates of PEPs and CDD requirements in certain sectors.
- Implementation in Practice: MONEYVAL notes that while legislative changes are positive, the degree of practical implementation remains to be fully assessed.
MONEYVAL’s Deadline and Enhanced Follow-Up
Moldova remains under enhanced follow-up and must report back to MONEYVAL within one year (by June 2025) on progress in addressing outstanding technical compliance deficiencies. MONEYVAL urges Moldovan authorities to prioritize the regulation of virtual assets and ensure that AML/CFT measures keep pace with technological innovation.
Stakeholder Critiques and Policy Recommendations
International Observers and National Authorities
International observers generally praise Moldova’s progress but emphasize the need for a more robust approach to digital finance. The U.S. Department of State and European partners continue to support Moldova’s reform agenda, especially as the country seeks EU accession.
The December 2024 NRA on VAs/VASPs outlines several key objectives for Moldova:
- Identify and assess ML/TF risks from VA and VASP activities
- Strengthen the regulatory framework with a risk-based approach
- Mitigate identified risks through supervision and monitoring
- Allocate resources effectively for regulatory and enforcement priorities2
MONEYVAL’s Closing Statement
MONEYVAL’s report concludes:
“Moldova has improved measures to combat money laundering and terrorist financing, demonstrating good progress in the level of compliance with the FATF standards… However, further progress is needed, especially regarding new technologies and virtual assets.”
Moldova’s Path Forward
The experience of Moldova on the way towards strong anti-money laundering and counter-terrorist financing standards provides a good balance between the areas of activities that show substantial improvement, including traditional sources of the financial sector and sanctions targeting. However, due to the increased growth of the digital economy, virtual assets comprise the latest risk zone. A key weakness of the country is its partial FATF Recommendation 15 since this aspect exposes the country to the perils of its financial system being abused by organized crime gangs and terror groups.
To keep the pace and work towards the full level of compliance, Moldova has to move faster on its road to the creation and adoption of a comprehensive regulatory framework on virtual assets and VASPs. This is through risk-based supervision, super enhanced due diligence and international cooperation. The incident of 2025, which involved money laundering and terror funding through online means, shows that the bar is very high.
Moldova’s success in this domain will not only secure its financial system but also strengthen its case for deeper integration with the European Union and the global financial community. The next year will be decisive in determining whether Moldova can turn regulatory promise into practical resilience.