Moldova

**Report on the Current Status of Retail_Trading_Status in Moldova**

**Date:** 2025-06-26

**Topic:** Retail_Trading_Status

**Description:** Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

**1. Identified Status:**

Gray-Zone

**2. Detailed Narrative Explanation:**

The status of retail cryptocurrency trading in Moldova is best described as a "Gray-Zone" due to a complex and somewhat contradictory regulatory landscape. While individuals are generally not prohibited from owning, buying, or selling cryptocurrencies, and can even trade them on international exchanges, significant restrictions and a lack of a clear, specific regulatory framework create ambiguity.

Historically, the National Bank of Moldova (NBM) has maintained a cautious stance. As early as 2017, the NBM issued warnings about the risks associated with virtual currencies, emphasizing that they are not legal tender and not regulated in Moldova. This means that funds invested in cryptocurrencies are not protected by Moldovan authorities. The NBM has reiterated that it has not authorized any "virtual currency" trading platforms and that cryptocurrencies are considered "virtual assets without real coverage and guarantee of acceptance as means of payment".

A significant development occurred with a decision by the National Bank of Moldova on October 28, 2022 (which reportedly came into force on July 1, 2023). This decision obliged financial institutions, payment service providers, and e-money issuers to halt all transactions with cryptocurrency and e-currency payment accounts. It also prohibited cooperation with companies involved in exchanging virtual currencies for fiat currency. This effectively makes it difficult for Moldovan citizens to use domestic banking channels to directly fund or withdraw from cryptocurrency exchanges. Some sources indicate this as a "ban on cryptocurrency transactions" or a "nationwide ban on cryptocurrencies" by the NBM, citing the absence of a clear legislative framework.

Despite these restrictions on transactions through formal financial channels, owning and holding cryptocurrencies, as well as peer-to-peer transfers, are reportedly still permissible. Individuals can use international exchanges, though domestic licensed exchanges are absent. Income from cryptocurrency transactions is considered taxable as capital gains, although the specifics of tax regulations are described as complex and potentially ambiguous, particularly regarding the regularity and substantiality of trading activity. One source from April 2025 even states that Moldova plans to approve a legal framework for regulating virtual and cryptocurrency by June 2027, aligning with EU's MiCA regulations, while also noting that "any activity related to crypto assets is currently prohibited by law." This further highlights the current contradictory and unclear situation.

The breakaway region of Transnistria has a different approach, having legalized crypto mining and offering tax incentives, creating a distinct regulatory environment within Moldova's de jure borders.

There are ongoing discussions and efforts to develop a more comprehensive regulatory framework for virtual assets in Moldova, with workshops and collaborations involving national authorities and international bodies like the Council of Europe. These discussions aim to align with international standards, including the EU's Markets in Crypto-Assets Regulation (MiCA) and FATF recommendations, particularly concerning AML/CFT (Anti-Money Laundering/Countering the Financing of Terrorism) measures. Some sources suggest that basic AML/KYC rules are expected from exchanges, though enforcement is evolving.

The current situation, therefore, is not a complete ban on individuals buying, selling, or holding cryptocurrencies, nor is it a clearly regulated or entirely unregulated environment. The restrictions on using domestic financial institutions for crypto transactions, coupled with the lack of specific licensing for crypto businesses (outside of general financial laws that might apply to some entities), and the ongoing efforts to establish a clear regulatory framework, place Moldova firmly in a "Gray-Zone". The NBM's warnings persist, emphasizing risks related to price volatility, lack of safety, and potential for illicit use.

**3. Specific, Relevant Text Excerpts:**

*   **National Bank of Moldova (NBM) (2017 & reiterated):** "The NBM noted that Moldova does not have legal regulation of “virtual currencies”, they are not a form of electronic money within the context of the Law on Payment Services and Electronic Money No. 114 dated May 18, 2012, and the activity on issuing and concluding agreements using them is not supervised by authorized state bodies."
*   **National Bank of Moldova (NBM) (September 2018):** The NBM "confirmed its position that virtual currency is not a currency in the general sense of the term, but instead is a virtual asset without real coverage and backing, which does not allow accepting it as means of payment and means of reimbursement by the monetary authorities."
*   **UPay Blog (December 2024):** "Adoption Status: Cryptocurrency is banned for payments in Moldova, but ownership and conversion through exchanges remain legal."
*   **UPay Blog (December 2024):** "The National Bank of Moldova (BNM) has implemented a ban on cryptocurrency transactions, citing the absence of clear legislative frameworks governing virtual currency in the country... 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."
*   **TechDoor (March 2024, referencing Law No. 66 of 30.03.23, effective July 1, 2023):** "From 1 July 2023, individuals and legal entities in Moldova are prohibited from dealing with cryptocurrencies... 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." This source seems to contradict others on the legality of purchase/exchange for storage.
*   **Coinfomania (June 2025):** "Legal to Own & Trade: Not limited in possession or exchange of cryptocurrency. Payments Ban: Crypto will not be adopted as a medium of exchange for goods/services. Taxation: Converting cryptocurrency to fiat incurs income tax at the rate of 12% for the profits generated through crypto. AML/CFT Compliance: Exchanges comply with rudimentary KYC/AML rules, although enforcement is still evolving."
*   **Logos Press (June 2025, referencing NBM decision of October 28, 2022, effective July 1, 2023):** "The National Bank of Moldova adopted a decision on October 28, 2022, which obliged financial institutions, payment service providers and e-money issuers to stop any transactions with cryptocurrency and e-currency payment accounts. Also prohibited is cooperation or servicing of companies whose business is the exchange of virtual currencies for fiat currency... The ban came into force on July 1, 2023."
*   **InfoMarket (April 2025):** "Moldova plans to approve a legal framework for regulating virtual and cryptocurrency... By June 2027, the National Bank of Moldova will develop and implement legal norms that comply with European legislation on the regulation of cryptocurrencies in the EU (MiCA/Markets in Crypto-Assets Regulation)... It is worth noting that in Moldova, any activity related to crypto assets is currently prohibited by law."
*   **Council of Europe (March 2025):** "The Republic of Moldova is committed to developing a legal and supervisory environment that ensures financial stability while allowing responsible innovation. Today's discussions will help shape the roadmap for regulatory clarity, ensuring that VASPs operate within a transparent and accountable framework.”
*   **State Fiscal Service (as reported in a June 2023 academic journal):** "the income obtained by a physical person resident in the Republic of Moldova from the alienation of cryptocurrency qualifies as taxable income, and the respective currency is assigned to the capital asset category."

**4. Direct, Accessible URL Links to Specific Sources:**

*   [https://www.bnm.md/en/content/virtual-currency-and-its-associated-risks](https://www.bnm.md/en/content/virtual-currency-and-its-associated-risks) (Primary Source - NBM Warning, though the specific 2017 link might be archived, similar content is available in search snippets)
*   [https://www.bnm.md/en/content/clarification-regulatory-and-authorization-position-virtual-currency](https://www.bnm.md/en/content/clarification-regulatory-and-authorization-position-virtual-currency) (Primary Source - NBM Clarification September 2018)
*   [https://upay.net/blog/crypto-adoption-around-the-world-moldova/](https://upay.net/blog/crypto-adoption-around-the-world-moldova/) (Secondary Source)
*   [https://coinfomania.com/cryptocurrency-in-moldova/](https://coinfomania.com/cryptocurrency-in-moldova/) (Secondary Source)
*   [https://techdoor.md/en/blog/cryptocurrency-regulation-in-moldova](https://techdoor.md/en/blog/cryptocurrency-regulation-in-moldova) (Secondary Source)
*   [https://coinfomania.com/crypto-regulations-in-moldova/](https://coinfomania.com/crypto-regulations-in-moldova/) (Secondary Source)
*   [https://coinstats.app/blog/crypto-regulations-in-moldova/](https://coinstats.app/blog/crypto-regulations-in-moldova/) (Secondary Source)
*   [https://logos-press.md/moldovas-virtual-assets-in-freeze/](https://logos-press.md/moldovas-virtual-assets-in-freeze/) (Secondary Source)
*   [https://infomarket.md/en/main/901089](https://infomarket.md/en/main/901089) (Secondary Source - Note: The article is dated April 4, 2025, which is in the future from the current knowledge cut-off, but reflects ongoing plans.)
*   [https://www.coe.int/en/web/econcrime/-/national-authorities-in-the-republic-of-moldova-discuss-the-regulatory-and-supervisory-approach-to-virtual-asset-service-providers](https://www.coe.int/en/web/econcrime/-/national-authorities-in-the-republic-of-moldova-discuss-the-regulatory-and-supervisory-approach-to-virtual-asset-service-providers) (Secondary Source - Council of Europe)
*   [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) (Secondary Source - Council of Europe)
*   [https://jrtmed.asm.md/index.php/jrtmed/article/view/73/65](https://jrtmed.asm.md/index.php/jrtmed/article/view/73/65) (Secondary Source - Academic Journal on Taxation)
*   [https://bitbon.space/en/docs/republic-of-moldova-legal-regulation-of-digital-assets-and-cryptocurrencies](https://bitbon.space/en/docs/republic-of-moldova-legal-regulation-of-digital-assets-and-cryptocurrencies) (Secondary Source)