Anti-money-laundering obligations in Moldova sit on a single statute that has been amended steadily since enactment to keep pace with European Union directives. For a societate cu răspundere limitată with foreign shareholders, the practical effect is that the entity is both a subject of the regime and, depending on its activity, an obliged entity within it. Founders entering the market through a new SRL need to understand which side of that line they sit on, what registration obligations attach at Agenția Servicii Publice, and what the supervisor expects in the first twelve months.
What Law 308/2017 requires
Law 308/2017 on preventing and combating money laundering and terrorist financing is the central Moldovan AML statute. It was drafted to align with the EU's 4th Anti-Money Laundering Directive, has since been amended to incorporate the 5th AMLD, and is now in a phased alignment with the 6th AMLD. The supervisor is SPCSB, the Service for Preventing and Combating Money Laundering, which sits under the Government of Moldova.
The law has two functions. It establishes the universal framework (UBO transparency, record-keeping, and the predicate offences) that applies to every legal entity formed in Moldova. It also designates classes of obliged entities (financial institutions, payment service providers, currency exchange offices, accountants, lawyers in specific contexts, real-estate professionals, and others) that bear active customer due diligence and reporting obligations. A standard trading SRL with foreign shareholders falls into the first category. A licensed payment institution, an investment firm, or a fintech with crypto-asset permissions falls into both.
Moldova is currently subject to MONEYVAL enhanced follow-up, the Council of Europe's mutual evaluation programme, and is not on the FATF grey list or any of its successor public lists. Since 2024 the country has participated in the OECD Common Reporting Standard for automatic exchange of financial-account information. The combined effect, for a foreign founder, is that beneficial ownership of a Moldovan SRL is transparent to the tax and AML authorities of the founder's country of residence on the timetable each treaty partner has agreed.
A Moldovan SRL is not a privacy vehicle. The CRS feed and the UBO register make beneficial ownership visible to residence-state authorities on a known timetable.
Customer due diligence: standard and enhanced
For obliged entities, Law 308/2017 mandates customer due diligence at three trigger points: establishing a business relationship, executing an occasional transaction above the statutory thresholds, and on any reasonable suspicion of money laundering or terrorist financing. The standard process identifies the customer, the beneficial owner, the purpose and intended nature of the relationship, and an ongoing monitoring obligation that extends throughout the relationship.
Enhanced due diligence applies to higher-risk situations. The statute names three categories explicitly: politically exposed persons (PEPs), customers and beneficial owners from high-risk third countries, and complex or unusual transactions or ownership structures without an apparent economic or lawful purpose. For PEPs, enhanced measures include senior-management approval for the relationship, establishment of the source of wealth and source of funds, and enhanced ongoing monitoring. For high-risk jurisdictions the measures are similar in substance, with additional document collection on the customer's regulatory environment.
For a standard trading SRL with foreign shareholders the practical exposure is different. The SRL is the customer in its bank's due-diligence process, not the entity conducting it. Banks in Moldova apply enhanced due diligence to most non-resident-shareholder structures by default. The documents requested at account opening (UBO declarations, source-of-funds evidence, business-purpose memoranda) are the bank's discharge of its Law 308/2017 obligations on the SRL. The detail of what banks ask, and why, is set out in the business bank account guide.
UBO declaration at ASP
Beneficial ownership transparency in Moldova runs through Agenția Servicii Publice, the company registrar. UBO obligations are anchored in Law 308/2017 itself and cross-referenced in the corporate statute Law 135/2007. At formation, every SRL must declare its ultimate beneficial owners: natural persons holding 25% or more of capital or voting rights, directly or indirectly, or otherwise exercising control. The declaration is filed alongside the constitutional documents and entered into the ASP register. Changes in beneficial ownership must be notified to ASP within 15 days of the change taking effect.
The 25% threshold is the EU 4th AMLD standard and applies to both direct and indirect holdings. Indirect control through nominee arrangements, layered holding companies, or trust structures must be unwound to the natural person. Where no individual reaches 25%, the senior managing official (typically the administrator) is declared as the controlling person and the file documents the absence of a 25% beneficial owner. Nominee shareholders without beneficial-owner status are not acceptable substitutes for the natural-person declaration.
For non-resident founders, the UBO declaration is generally prepared and signed during the formation file. Supporting documents include passport copies of all UBOs and, where indirect ownership is involved, a structure chart showing the chain to the ultimate natural person. The declaration is not a one-off event: changes in the cap table, transfer of shares, or a change in the administrator who is the declared controlling person all require an ASP notification within the 15-day window. Penalties for late or inaccurate declaration are administrative and can be material in repeated cases.
Record-keeping requirements
Law 308/2017 requires obliged entities to retain customer due diligence documentation, transaction records, and internal AML correspondence for at least five years from the end of the business relationship or the date of the occasional transaction. The retention period can be extended by SPCSB direction in specific cases, typically connected to an ongoing investigation.
For a standard trading SRL the practical record-keeping load is on the bank, the accountant, and any other obliged entity in the supply chain. The SRL itself retains its corporate records (minutes, financial statements, contracts) under the general accounting and tax statute, with the standard period running to seven years for most documents under the accounting and tax law. The AML-specific retention overlay applies to material the SRL has produced as a customer of an obliged entity: UBO declarations, source-of-funds memoranda, KYC questionnaires returned to banks.
For obliged-entity SRLs (payment institutions, exchanges, fintech with crypto permissions), the record-keeping framework is substantially heavier. Customer files, transaction logs, monitoring rule outputs, and STR working papers must be retrievable on demand. The CNPF (Comisia Națională a Pieței Financiare) supervises certain financial-services entities directly and inspects record-keeping during routine and event-driven examinations. BNM (Banca Națională a Moldovei) does the same for credit institutions and payment-service providers within its supervisory perimeter.
Reporting suspicious transactions to SPCSB
Obliged entities under Law 308/2017 must report suspicious transactions to SPCSB without delay, with the operational benchmark being submission within 24 hours of the suspicion forming. The report, a suspicious transaction report (STR), is filed through SPCSB's secure channels and contains the transaction detail, the parties involved, the trigger for suspicion, and any supporting documentation. SPCSB acknowledges receipt and may direct the obliged entity to freeze the transaction pending further analysis.
The statute protects the reporting entity. Filing an STR in good faith does not expose the entity or its employees to civil, criminal, or administrative liability for breach of confidentiality. Tipping off the customer, that is informing them that an STR has been or is about to be filed, is a separate offence carrying its own penalties.
For a standard trading SRL the STR pathway is theoretical: the SRL is not an obliged entity and has no obligation to file STRs on its counterparties. Its exposure to the regime runs through its bank, which will file STRs on the SRL's transactions if the bank's monitoring rules flag them. Founders sometimes ask whether a flagged transaction is a problem in itself; ordinarily it is not, provided the underlying activity is genuine and documented. Banks expect to see contracts, invoices, and counterparty information for material transactions, and the due diligence guide sets out the documentary trail that smooths review.
For obliged-entity SRLs the STR pathway is operational. Internal AML policies must define the suspicion threshold, escalation routing, internal training cadence, and the named Money Laundering Reporting Officer (MLRO). SPCSB inspects these policies during examinations and can impose administrative penalties for material deficiencies. Criminal liability is reserved for serious breaches: willful failure to report, deliberate facilitation of laundering, or breach of the tipping-off prohibition.
Recent and upcoming changes
The AML statute is on a continuous-amendment trajectory driven by EU accession. Negotiations on EU membership were opened on 25 June 2024 with a target to close the substantive chapters by early 2028, and AML alignment falls within the chapters on financial services and judicial cooperation in criminal matters. The current legislative priority is full transposition of the 6th AMLD, which introduces an expanded predicate-offence list, more granular corporate-liability provisions, and a harmonised sanctions regime across member states. The full enlargement timeline is tracked in the EU accession status note.
Two related developments are also in train. Moldova's sanctions enforcement framework, implementing UN and EU restrictive measures, has been progressively strengthened, and obliged entities are expected to maintain real-time screening against the consolidated EU sanctions list and the UN sanctions list. Separately, the country joined SEPA on 6 October 2025, which has tightened payment-related KYC at the banks because the SEPA participation framework imports additional payer/payee verification requirements.
For new SRLs the practical upshot is that AML obligations will only grow over the next two to three years, both in scope and in enforcement intensity. The current baseline (UBO declaration at ASP, change notification within 15 days, robust source-of-funds documentation for banking, awareness of the obliged-entity perimeter) is the floor, not the ceiling. Founders planning a regulated-activity entity should build the AML function into the operating model from day one rather than treating it as a post-licensing add-on. The AML advisory page sets out how Incorpore approaches that work for new structures.
A Moldovan SRL set up in 2026 with the intention to operate through 2030 should plan its AML function against the 6th AMLD baseline, not the 4th.
For specific structuring (UBO disclosure, obliged-entity scoping, AML policy drafting), review the company formation overview and arrange a call through the contact form. AML scoping is part of the first advisory conversation for any structure with foreign shareholders or regulated activity.
Frequently asked questions
What is Law 308/2017?
Law 308/2017 is the central Moldovan AML and counter-terrorist-financing statute. It aligns with the EU 4th and 5th AMLDs and is being progressively aligned with the 6th AMLD. The supervisor is SPCSB, and the law covers UBO transparency, customer due diligence by obliged entities, record-keeping, and suspicious-transaction reporting.
Who is the AML supervisor in Moldova?
The supervisor is SPCSB, the Service for Preventing and Combating Money Laundering, which sits under the Government of Moldova. SPCSB receives STRs, supervises obliged entities, and coordinates with sectoral supervisors including BNM for credit institutions and CNPF for non-bank financial services.
What is the UBO threshold for a Moldovan SRL?
The threshold is 25% of capital or voting rights, direct or indirect, or otherwise exercising control. UBOs are declared at ASP at formation and changes must be notified within 15 days. Where no individual reaches 25%, the senior managing official is declared as the controlling person.
Is Moldova on the FATF grey list?
No. Moldova is not on the FATF grey list. The country is in MONEYVAL enhanced follow-up, the Council of Europe's mutual evaluation programme, which is a different mechanism with a different threshold. Moldova has also participated in the OECD Common Reporting Standard since 2024.
What records must an obliged entity keep?
Customer due diligence documents, transaction records, and internal AML correspondence must be kept for at least five years from the end of the business relationship or the date of the occasional transaction. SPCSB can extend the period in connection with ongoing investigations.
What is the timeline for filing an STR?
The operational benchmark is submission to SPCSB within 24 hours of the suspicion forming. STRs are filed through SPCSB's secure channels. Reporting in good faith does not expose the entity or its employees to liability, and tipping off the customer about the report is a separate offence.