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Moldova

Retail_Trading_Status

Gray-Zone High Confidence
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Analysis ID
#729
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Created
2025-12-12 04:52
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Executive Summary

Cryptocurrency in Moldova occupies a restrictive legal gray area where individual ownership and trading are permitted and taxed, but the provision of virtual asset services (VASP) is explicitly prohibited by law. While the National Bank of Moldova (NBM) and the National Commission for Financial Markets (NCFM) allow citizens to hold digital assets as property, using them for payments is banned. Recent amendments to AML legislation in July 2023 criminalized the operation of crypto exchanges within the country, and banks are restricted from processing large transfers to foreign crypto platforms.

Key Pillars

National Bank of Moldova (NBM): Regulates the financial system, enforces the ban on crypto payments, and oversees bank compliance regarding transfers to crypto platforms.
National Commission for Financial Markets (NCFM): Investigates unauthorized issuance of digital assets and enforces the prohibition on VASP activities.
Service for Prevention and Combating of Money Laundering (SPCSB): Monitors suspicious financial flows and enforces AML/CFT compliance under Law No. 308/2017.
State Tax Service: Collects a 12% capital gains tax on profits derived from cryptocurrency trading.

Landmark Laws

Law on Prevention and Combating of Money Laundering and Terrorist Financing (Amended) (Law No. 308/2017 (Amended by Law No. 66/2023)) - Enacted: 2023-07-01
- Defined 'virtual assets' for the first time but explicitly prohibited the provision of services related to virtual assets on the territory of Moldova. It mandates that banks report suspicious crypto-related transactions.
- Source

Tax Code of the Republic of Moldova (Title II, Chapter 1)
- Establishes that income from the sale of capital assets (including virtual currency) is subject to income tax. The standard rate for capital gains is 12%.
- Source

Law on Payment Services and Electronic Money (Law No. 114/2012) - Enacted: 2012-05-18
- Establishes that virtual currencies are not recognized as legal tender or electronic money, effectively banning their use for payments for goods and services.
- Source

Considerations

VASP Ban: Operating a crypto exchange or custodial service within Moldova is currently illegal under the 2023 AML amendments.
Payment Ban: It is illegal to accept cryptocurrency as payment for goods or services.
Bank Restrictions: Banks are prohibited from processing transactions to foreign crypto providers if the cumulative volume exceeds 50,000 MDL (approx. €2,500) per month.
Taxation: Individuals must declare crypto profits and pay a 12% capital gains tax.
Future Regulation: Moldova aims to align its framework with the EU's MiCA regulation by 2027.

Notes

The breakaway region of Transnistria has historically had a different, more permissive approach to crypto mining, but this analysis focuses on the Republic of Moldova's official legal framework. The current 'ban on services' combined with 'taxation of profits' is a common interim measure in jurisdictions preparing for EU alignment.

Remaining Uncertainties

  • The specific timeline for the transition from the current ban to the MiCA-aligned licensing regime (targeted for 2027).
  • The extent of enforcement on individuals using foreign exchanges below the 50,000 MDL limit.
  • Whether 'provision of services' ban applies strictly to centralized exchanges or also to self-custody wallet developers operating locally.

Detailed Explanation

The Republic of Moldova's cryptocurrency regulatory status is definitively a restrictive legal gray-zone. While individual ownership and trading of digital assets are permitted, the framework is characterized by significant prohibitions on commercial and payment activities. The legal landscape is shaped by three key regulatory bodies: the National Bank of Moldova (NBM), which regulates the financial system and enforces the ban on using cryptocurrency for payments; the National Commission for Financial Markets (NCFM), which investigates unauthorized digital asset issuance and enforces the prohibition on virtual asset service provider (VASP) activities; and the Service for Prevention and Combating of Money Laundering (SPCSB), which monitors suspicious financial flows. The State Tax Service also plays a critical role by collecting capital gains tax on crypto profits.

The regulatory framework is anchored by specific landmark legislation. The amended Law on Prevention and Combating of Money Laundering and Terrorist Financing (Law No. 308/2017, amended by Law No. 66/2023), which took effect on July 1, 2023, is pivotal. This law defined 'virtual assets' for the first time in Moldovan law but explicitly prohibited the provision of services related to virtual assets within the country, effectively criminalizing the operation of crypto exchanges. It also mandates that banks report suspicious crypto-related transactions. Furthermore, the Law on Payment Services and Electronic Money (Law No. 114/2012) establishes that virtual currencies are not recognized as legal tender or electronic money, solidifying the ban on their use for payments for goods and services. For taxation, the Tax Code subjects income from the sale of capital assets, including virtual currency, to a 12% capital gains tax.

Consequently, the compliance environment is restrictive. Individuals must declare and pay tax on trading profits, but they face major limitations. It is illegal to operate a VASP like an exchange or custodial service within Moldova. It is also illegal for merchants to accept cryptocurrency as payment. Banks are restricted from processing large transfers to foreign crypto platforms, specifically prohibited from processing transactions if the cumulative volume exceeds 50,000 MDL (approximately €2,500) per month. Looking forward, Moldova aims to align its regulatory framework with the European Union's Markets in Crypto-Assets (MiCA) regulation by 2027, suggesting the current prohibitive stance may be an interim measure during this transition period.

Summary Points

Cryptocurrency Regulatory Analysis: Moldova

I. Regulatory Status

  • Gray-Zone with a restrictive character.
  • Individual ownership and trading are permitted and taxed.
  • Provision of virtual asset services (VASP) is explicitly prohibited.
  • Use of cryptocurrency for payments is banned.

II. Key Regulatory Bodies

  • National Bank of Moldova (NBM)
    • Regulates the financial system.
    • Enforces the ban on crypto payments.
    • Oversees bank compliance regarding transfers to crypto platforms.
  • National Commission for Financial Markets (NCFM)
    • Investigates unauthorized issuance of digital assets.
    • Enforces the prohibition on VASP activities.
  • Service for Prevention and Combating of Money Laundering (SPCSB)
    • Monitors suspicious financial flows.
    • Enforces AML/CFT compliance under Law No. 308/2017.
  • State Tax Service
    • Collects capital gains tax on cryptocurrency trading profits.

III. Important Legislation

  • Law on Prevention and Combating of Money Laundering and Terrorist Financing (Amended) (Law No. 308/2017, amended by Law No. 66/2023)
    • Enacted: July 1, 2023.
    • First legal definition of 'virtual assets' in Moldova.
    • Explicitly prohibits the provision of services related to virtual assets on Moldovan territory.
    • Mandates banks to report suspicious crypto-related transactions.
  • Tax Code of the Republic of Moldova (Title II, Chapter 1)
    • Establishes that income from the sale of capital assets (including virtual currency) is subject to income tax.
    • Standard capital gains tax rate is 12%.
  • Law on Payment Services and Electronic Money (Law No. 114/2012)
    • Enacted: May 18, 2012.
    • Establishes that virtual currencies are not recognized as legal tender or electronic money.
    • Effectively bans the use of cryptocurrency for payments for goods and services.

IV. Compliance Requirements

  • Individuals must declare profits from cryptocurrency trading.
  • A 12% capital gains tax must be paid on declared profits.

V. Notable Restrictions or Limitations

  • VASP Ban: Operating a crypto exchange or custodial service within Moldova is illegal under the 2023 AML amendments.
  • Payment Ban: It is illegal to accept cryptocurrency as payment for goods or services.
  • Bank Restrictions: Banks are prohibited from processing transactions to foreign crypto providers if the cumulative volume exceeds 50,000 MDL (approx. €2,500) per month.

VI. Recent Developments or Notes

  • The 2023 amendments to the AML law represent a significant hardening of the regulatory stance, explicitly criminalizing domestic VASP operations.
  • Moldova aims to align its cryptocurrency regulatory framework with the EU's MiCA regulation by 2027.
  • The current model of 'ban on services' combined with 'taxation of profits' is viewed as a common interim measure for jurisdictions preparing for EU alignment.
  • Note: The breakaway region of Transnistria has a different, more permissive approach to crypto mining, but this analysis focuses on the Republic of Moldova's official legal framework.

Full Analysis Report

The regulatory status of cryptocurrency in Moldova is currently defined by a 'restrictive tolerance' approach. As of late 2025, the country permits individuals to own and trade cryptocurrencies as investment assets, but it has erected significant barriers to the industry's operation. The pivotal moment came with the July 1, 2023, amendments to Law No. 308/2017 on preventing money laundering. While these amendments introduced the legal definition of 'virtual assets,' they simultaneously prohibited the provision of services related to virtual assets on Moldovan territory. This effectively bans local crypto exchanges and custodial services, placing the sector in a 'Gray-Zone' where usage is legal but local infrastructure is illegal.

The National Bank of Moldova (NBM) maintains a strict stance against the use of crypto for payments. Virtual currencies are not recognized as legal tender, and their use in commerce is prohibited. The NBM has repeatedly issued warnings regarding the high risks of volatility and lack of consumer protection. Furthermore, the regulator has imposed operational restrictions on the banking sector; financial institutions are reportedly barred from processing transfers to foreign crypto service providers if the monthly volume exceeds 50,000 MDL, forcing active traders to rely on foreign fintech solutions or peer-to-peer markets.

Despite the prohibition on local service providers, the State Tax Service actively treats cryptocurrency as a taxable asset. Profits realized from the sale of crypto are categorized as capital gains and taxed at a rate of 12%. This creates a paradoxical situation where the state derives revenue from an activity it refuses to license locally. Enforcement is visible; in late 2025, the National Commission for Financial Markets (NCFM) launched investigations into local entities attempting to issue tokens (e.g., 'Double Case Token'), citing the statutory ban on VASP services.

Looking ahead, Moldova is in a transitional phase. As an EU candidate country, it has committed to harmonizing its financial legislation with European standards, specifically the Markets in Crypto-Assets (MiCA) regulation. Authorities have indicated a target date of 2027 for a comprehensive framework that would likely replace the current ban with a licensing regime. Until then, the environment remains hostile for crypto businesses but accessible, albeit restricted, for individual retail investors.

Source Evidence

Primary and secondary sources cited in this analysis

"Virtual currencies... are not currencies in the common sense of the term... [and] are not fit for being used as payment means."

"The provision of services related to virtual assets is prohibited on the territory of the Republic of Moldova."

2025-11-07

"According to Law 308/2017... the provision of services related to virtual assets is prohibited on the territory of the Republic of Moldova."

2025-11-03

"Moldova has not yet implemented the EU Regulation (MiCA)... Law 308/217 prohibits the provision of services related to virtual assets on the territory of Moldova, but not their possession."

PwC Moldova Tax & Legal Alert secondary (analysis)
2023-07-01

"The provision of services related to virtual assets is prohibited in the Republic of Moldova, and fines are provided for cases of non-compliance."

Web Sources (8)

Sources discovered via web search grounding

Search queries used (5)
  • Moldova crypto tax legislation
  • National Bank of Moldova virtual currency warning
  • Moldova Law on Prevention of Money Laundering virtual assets amendment
  • Moldova cryptocurrency regulation status 2024 2025
  • National Commission for Financial Markets Moldova crypto license
lightspark.com

https://www.lightspark.com/knowledge/is-crypto-legal-in-moldova

mexc.com

https://blog.mexc.com/wiki/are-there-any-taxes-for-crypto-in-moldova/

techdoor.md

https://techdoor.md/en/cryptocurrency-regulation-in-moldova/

pwc.com

https://www.pwc.com/md/en/tla/tla2023/Amendments-to-the-Law-on-preventing-and-combating-money-laundering-and-terrorist-financing-3.html

logos-pres.md

https://logos-pres.md/en/news/ncfm-launched-an-investigation-into-the-launch-of-the-first-moldovan-cryptocurrency/

coinfomania.com

https://coinfomania.com/crypto-regulations-in-moldova/

logos-pres.md

https://logos-pres.md/en/article/cryptocurrency-is-not-recognized-but-taxed/

infotag.md

http://www.infotag.md/finances-en/259729/

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