Legislative changes regarding the supervision of implementation of international sanctions by reporting entities

Order no. 64/2026 of the President of the National Office for the Prevention and Combating of Money Laundering (Official Gazette, Part I, no. 389) was published in the Official Gazette on 8 May 2026, thereby approving the Norms for the Application of Emergency Government Ordinance no. 202/2008 on the supervision of the implementation of international sanctions, in particular measures for the freezing of funds and economic resources by reporting entities under the supervision of the National Office for the Prevention and Combating of Money Laundering (ONPCSB). The Norms clarify the role of the ONPCSB as the supervisory authority in this field and introduce new compliance obligations for the entities in question.

The main changes include the following:

• Strict compliance with international sanctions regarding operations. Entities overseen by the ONPCSB must undertake all necessary diligence, using the information and tools available, to ensure that any transaction or operation carried out does not breach international sanctions regimes, including obligations to freeze funds and economic resources. These requirements must be observed in line with relevant international guidelines, ensuring the full application of the provisions of Emergency Government Ordinance no. 202/2008 with respect to sanctions.

• Internal procedures and monitoring systems. Reporting entities are required to adopt dedicated internal policies, procedures and processes, as well as monitoring systems to ensure continuous compliance with national and international sanctions-related legislation. Internal compliance documentation must provide mechanisms for the proactive identification of designated persons and entities (subject to sanctions) and of transactions subject to restrictions, including the consulting of updated EU and UN sanctions lists. Furthermore, internal procedures must detail the practical implementation of freezing measures and the immediate reporting to the ONPCSB of the application of sanctions, as well as the recording and retention of data regarding sanctioned persons/entities. The management of these entities will need to approve these procedures, communicate them to all staff and review them periodically.
• Obligation to immediately freeze and report. Upon identifying funds or economic resources that fall under international sanctions, reporting entities must immediately freeze such funds and report without delay the measures taken to the ONPCSB. Reporting is carried out via an official form (appended to the Order) that is to be submitted forthwith by email to the dedicated address (sanctiuni@onpcsb.ro).
• Full cooperation with the ONPCSB. Upon request, reporting entities are required to provide the ONPCSB with all the information they hold regarding designated persons or entities (subject to sanctions), with no right to invoke professional secrecy or confidentiality. Thus, the ONPCSB may request and obtain data from entities, in accordance with the law, in order to verify the manner in which sanctions are being implemented.
• The role of the ONPCSB in supervision and training. The ONPCSB is the national authority responsible for supervising how reporting entities implement freezing sanctions with respect to funds and economic resources. In exercising this function, ONPCSB staff with supervisory responsibilities may carry out verifications and compliance inspections at the entities in question, imposing remedial measures and issuing recommendations where irregularities are identified. At the same time, the ONPCSB will periodically hold training sessions for reporting entities, in order to provide them with guidance in fulfilling their obligations regarding international sanctions.
• Sanctions for non-compliance. Failure to comply with the new obligations regarding the implementation of international sanctions constitutes an administrative offence, in accordance with the sanctioning regime provided for by Emergency Government Ordinance no. 202/2008. The Norms confirm the power of authorised representatives of the ONPCSB to inspect and apply administrative sanctions to entities that do not fulfil their legal obligations with respect to sanctions (for example, fines and other measures provided for by the normative act).

Source: Order no. 64 of 4 May 2026 approving the Norms for the application of the provisions of Emergency Government Ordinance no. 202/2008 on the implementation of international sanctions, with regard to the supervision of the implementation of international sanctions consisting of the freezing of funds and economic resources by entities supervised and inspected by the National Office for the Prevention and Combatting of Money Laundering – Official Gazette, Part I, no. 389, of 8 May 2026.