Moldova

**Report: Retail Cryptocurrency Trading Status in Moldova**

**1. Identified Status:** Gray-Zone

**2. Narrative Explanation:**

The status of retail cryptocurrency trading in Moldova is complex and best described as a 'Gray-Zone'. While there isn't an outright, explicit ban on *owning* cryptocurrencies as personal assets, the regulatory environment actively discourages and severely restricts most practical activities related to trading, transacting, and integrating cryptocurrencies with the formal financial system.

Historically, the National Bank of Moldova (NBM) has consistently issued warnings about the risks associated with virtual currencies since at least 2017, highlighting their unregulated nature and potential for illicit use [5, 6, 10, 11]. The NBM explicitly stated that virtual currencies are not legal tender, not a form of electronic money under Moldovan law, and activities related to them are not supervised by state authorities [5, 6, 11].

A significant development occurred with Law No. 66 of March 30, 2023, which, according to some interpretations, effectively prohibited individuals and legal entities from *dealing* with cryptocurrencies starting July 1, 2023 [2]. This law reportedly makes it impossible to use crypto for payments, transfers, and other transactions within the formal system [2]. Further reinforcing this restrictive stance, the NBM instructed banks and payment service providers (PSPs) in October 2022 to stop facilitating payments to/from crypto platforms and cease collaboration with companies involved in exchanging virtual currencies for fiat [3]. This effectively cuts off the main channel for Moldovan residents to buy or sell cryptocurrencies using Moldovan bank accounts or cards [4].

Despite these restrictions, holding cryptocurrencies as an investment or savings asset appears to remain permissible, although acquiring them legally within Moldova is described as practically impossible [2]. Peer-to-peer transfers between private wallets might still occur, but integrating these assets with the formal Moldovan banking system is blocked [4]. Income derived from crypto investments is subject to a 12% income tax, creating a paradoxical situation where holding and profiting is taxed, but legally acquiring the asset within the country is severely hindered [2].

Moldova's Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) framework (Law No. 308 of 22.12.2017, updated effective July 1, 2023) now includes provisions related to virtual assets and virtual asset service providers (VASPs) [13, 17]. Amendments in 2021 also require individuals subject to asset declarations to report virtual assets exceeding a certain threshold [3]. However, the overarching policy seems focused on prohibiting domestic VASP activities and limiting interactions with foreign VASPs under strict conditions, primarily to mitigate risks like sanctions evasion [3].

Recent discussions (March 2025) involving Moldovan authorities and the Council of Europe indicate ongoing efforts to develop a regulatory and supervisory framework for VASPs that aligns with EU (MiCA) and FATF standards [7]. This suggests a potential future shift towards regulation, but currently, the environment remains highly restrictive, discouraging active trading and use within the formal economy, while not completely banning private ownership. This ambiguity and the practical impossibility of legal acquisition and exchange through official channels place Moldova in a 'Gray-Zone'.

**3. Supporting Excerpts:**

*   **National Bank of Moldova (NBM) (2017):** "The use of virtual currencies is not regulated in the Republic of Moldova. They do not represent a form of electronic money within the meaning of the Law on payment services and electronic money no.114 of 18 May 2012 and the activity on their issuance and transaction is not subject to the competent authority's supervision." [6, 11] "The National Bank of Moldova warns the payment service users on the fact that virtual currencies and related exchange methods are not subject to regulation on the territory of the Republic of Moldova. Respectively, the users' funds are not protected." [6, 11]
*   **TechDoor (Mar 2024):** "From 1 July 2023, individuals and legal entities in Moldova are prohibited from dealing with cryptocurrencies. According to Law No. 66 of 30.03.23. In practice, making it impossible to use crypto for payments, transfers and any other transactions. The only use is to hold digital coins as an investment or savings asset. However, a paradox arises. Moldovan citizens cannot legally purchase or exchange cryptocurrency for subsequent storage." [2]
*   **UPay Blog (Dec 2024):** "Adoption Status: Cryptocurrency is banned for payments in Moldova, but ownership and conversion through exchanges remain legal." [4] "For everyday users, this decision means they can no longer fund or withdraw cryptocurrency holdings through Moldovan bank accounts or cards... However, the BNM's decision does not extend to private cryptocurrency holdings or peer-to-peer transfers. Individuals can still hold cryptocurrencies and conduct direct transfers between personal wallets, but integrating these assets with the formal banking system in Moldova is now blocked." [4]
*   **Money Laundering / Terrorist Financing National Risk Assessment (Dec 2024):** "Currently, Moldova's regulatory landscape remains restricted, primarily focusing on prohibiting domestic VASP activities and limiting interactions with authorized foreign VASPs under stringent conditions." [3] "Prior to the adoption of the 2023 amendments to the AML/CFT Law, the National Bank issued another circular on October 28, 2022, instructing banks and PSPs to cease any facilitating/intermediating payments from/to their accounts for crypto platforms involved in buying/selling virtual currencies and to cease collaboration with companies engaged in exchanging virtual currencies for fiat currency." [3]
*   **Council of Europe Office in Chisinau (Mar 2025):** "A workshop... provided a platform for the representatives of national authorities to discuss best practices, international standards, and the country's strategy for licensing and supervising Virtual Assets Service Providers (VASPs)." [7]

**4. Source URLs:**

*   **National Bank of Moldova (Warnings):**
    *   [https://www.bnm.md/en/content/virtual-currency-and-its-associated-risks](https://www.bnm.md/en/content/virtual-currency-and-its-associated-risks) [6, 11]
*   **TechDoor (Law No. 66 Interpretation):**
    *   [https://techdoor.md/en/article/cryptocurrency-regulation-in-moldova](https://techdoor.md/en/article/cryptocurrency-regulation-in-moldova) [2]
*   **UPay Blog (Status Summary):**
    *   [https://upay.net/blog/crypto-adoption-around-the-world-moldova/](https://upay.net/blog/crypto-adoption-around-the-world-moldova/) [4]
*   **Money Laundering / Terrorist Financing National Risk Assessment:**
    *   [https://www.osce.org/files/f/documents/5/9/561899.pdf](https://www.osce.org/files/f/documents/5/9/561899.pdf) (Note: This link is inferred from the search result content mentioning the OSCE and World Bank involvement in the NRA) [3]
*   **Council of Europe (VASP Workshop):**
    *   [https://www.coe.int/en/web/chisinau/-/national-authorities-in-the-republic-of-moldova-discuss-the-regulatory-and-supervisory-approach-to-virtual-asset-service-providers](https://www.coe.int/en/web/chisinau/-/national-authorities-in-the-republic-of-moldova-discuss-the-regulatory-and-supervisory-approach-to-virtual-asset-service-providers) [7]
*   **Bitbon Space (Legal Analysis):**
    *   [https://www.bitbon.space/en/republic-of-moldova-digital-assets](https://www.bitbon.space/en/republic-of-moldova-digital-assets) [5]
*   **MoldovaLive.md (BNM Ban Report):**
    *   [https://moldovalive.md/the-national-bank-made-an-important-decision-with-regard-to-cryptocurrencies-10884/](https://moldovalive.md/the-national-bank-made-an-important-decision-with-regard-to-cryptocurrencies-10884/) [9]
*   **CEE Legal Matters (AML Developments):**
    *   [https://ceelegalmatters.com/moldova/25481-recent-aml-developments-in-moldovan-s-financial-services-sector](https://ceelegalmatters.com/moldova/25481-recent-aml-developments-in-moldovan-s-financial-services-sector) [17]