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Compliance, AML & GDPR in Romania

Regulatory compliance · anti-money laundering · GDPR data protection · sector licensing compliance

Build Your Compliance Framework

Every business operating in Romania is subject to a layer of compliance obligations — data protection rules under EU GDPR, anti-money laundering requirements under Romanian AML law, and sector-specific regulatory frameworks that apply to financial services, real estate, gambling, transport, healthcare and other regulated industries.

Romania For Business SRL provides English-speaking compliance, AML and GDPR services for international businesses operating in Romania — helping companies understand which obligations apply, build the policies and procedures required to meet them, and respond effectively when regulatory authorities (ANSPDCP for data protection, ONPCSB for AML) conduct inspections or issue enforcement notices.

GDPR fines can reach 4% of global annual turnover — non-compliance is a business risk, not just a legal formality

The EU General Data Protection Regulation applies to every company operating in Romania that processes personal data — regardless of size, sector or the nationality of the company’s owners. ANSPDCP (the Romanian data protection authority) has the power to impose fines of up to €20 million or 4% of global annual turnover, whichever is higher. Romanian companies processing personal data without a lawful basis, without a privacy policy, or without a data processing agreement with service providers are exposed to enforcement action.

Three Compliance Areas — What Applies to Your Business

Compliance obligations in Romania fall into three overlapping categories. Understanding which apply to your company depends on your sector, activities and the personal data you process.

GDPR

Data Protection

Applies to:

  • Every company processing personal data
  • Companies with EU customers
  • E-commerce, SaaS, HR-intensive businesses
  • Businesses using cloud services / processors

Authority: ANSPDCP
Max fine: €20M or 4% global turnover

AML / CFT

Anti-Money Laundering

Applies to:

  • Financial services, payment institutions
  • Real estate agents and developers
  • Accountants, lawyers, tax advisers
  • Gambling, crypto/virtual asset service providers

Authority: ONPCSB
Criminal liability for non-compliance

Regulatory

Sector Compliance

Applies to:

  • Licensed / regulated sector operators
  • Companies subject to industry codes
  • Environmental and health & safety obligations
  • Labour law and employment compliance

Authority: Sector-specific regulators
Licence withdrawal + significant fines

Compliance, AML & GDPR Services We Provide

Romania For Business SRL provides compliance services across six areas. Each is described in detail in the sections that follow.

GDPR Compliance Audit

Gap analysis of your company’s current data protection position against EU GDPR and Romanian national requirements.

  • Data inventory & mapping
  • Lawful basis analysis
  • Privacy notice review
  • Processor agreement review
  • Gap analysis report

GDPR Documentation

Complete GDPR documentation package — privacy policies, data processing agreements and internal procedures.

  • Privacy policy (external)
  • Cookie policy
  • Record of processing activities (ROPA)
  • Data retention schedule
  • DSAR response procedure

Data Breach Response

Breach response planning, 72-hour ANSPDCP notification protocol and post-breach remediation.

  • Breach response procedure
  • ANSPDCP notification (72hr)
  • Communication templates
  • Regulatory interaction support
  • Post-breach remediation

AML Policy & Procedures

Anti-money laundering compliance for regulated entities — risk assessment, CDD framework and ONPCSB reporting.

  • Business-wide risk assessment
  • AML policy manual
  • CDD / EDD procedures
  • PEP & sanctions screening
  • STR reporting to ONPCSB

AML Compliance Officer

Designating and supporting the AML compliance officer — a legal requirement for Romanian obliged entities.

  • Compliance officer designation
  • Role description & authority
  • Training programme
  • Ongoing compliance calendar
  • ONPCSB liaison support

Regulatory Compliance

Sector-specific compliance frameworks for regulated businesses — from licence compliance to labour law.

  • Sector compliance audit
  • Regulatory gap analysis
  • Policy & procedure drafting
  • Labour law compliance
  • Compliance monitoring system

GDPR Compliance for Companies Operating in Romania

The EU General Data Protection Regulation (GDPR) — Regulation (EU) 2016/679 — applies to every company that processes personal data of individuals in the EU, regardless of where the company is incorporated. For Romanian companies and foreign-owned companies with Romanian operations, GDPR compliance is not optional — it is a legal requirement enforced by ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal).

Up to €10M

Tier 1 fine — less serious violations

Up to €20M

Tier 2 fine — serious violations

Up to 2% turnover

Tier 1 — % of global annual turnover

Up to 4% turnover

Tier 2 — % of global annual turnover

GDPR fines are the higher of the absolute amount or the percentage of global annual turnover — so a company with €50 million global revenue could face a Tier 2 fine of up to €2 million. ANSPDCP can also issue temporary or permanent bans on data processing, which can halt business operations entirely.

GDPR requirement What it means for your Romanian company
Lawful basis for processing Every data processing activity must have a lawful basis under GDPR Art. 6 — consent, contract performance, legal obligation, vital interests, public task or legitimate interests. Processing personal data without a lawful basis is a violation regardless of whether the data subject is aware.
Privacy policy (informare) Every company collecting personal data must provide a privacy notice — in clear, plain language — explaining what data is collected, why, how long it is retained, who it is shared with and how data subjects can exercise their rights. The privacy notice must be accessible before data is collected.
Record of processing activities (ROPA) Companies processing personal data must maintain an internal record of all processing activities — describing the categories of data, the purposes, the retention periods and the recipients. ANSPDCP can request the ROPA at any time during an inspection.
Data processor agreements When a company shares personal data with a service provider — a cloud provider, payroll processor, marketing agency, HR software provider or accountant — a written data processing agreement (DPA) is legally required under GDPR Art. 28. Processing without a DPA exposes both the controller and processor to fines.
Data subject rights GDPR gives individuals rights: to access their data (DSAR), to correct it, to erase it (right to be forgotten), to restrict processing, to data portability and to object. Companies must have documented procedures to respond to these requests within 1 month of receipt.
Data breach notification If a personal data breach occurs — a security incident that results in accidental or unlawful access to, disclosure, alteration or loss of personal data — the company must notify ANSPDCP within 72 hours of becoming aware. If the breach poses a high risk to individuals, those individuals must also be notified without undue delay.
Data Protection Officer (DPO) Companies that process large volumes of sensitive data or conduct systematic monitoring of individuals are required to appoint a Data Protection Officer. Romania For Business SRL advises on DPO obligation triggers and can assist with DPO designation and documentation.
International data transfers Transferring personal data outside the EU/EEA requires a legal mechanism — adequacy decision, Standard Contractual Clauses (SCCs) or other GDPR-approved safeguards. Companies using US cloud services, overseas payroll providers or non-EU contractors should verify the transfer mechanism for each.

GDPR Compliance Audit — What We Review

01

Data inventory & mapping

02

Lawful basis analysis

03

Privacy notices reviewed

04

DPA agreements checked

05

ROPA completeness

06

Breach procedure review

07

Gap analysis report

AML and CFT Compliance — Who Is Obliged and What Is Required

Romanian AML law (Law No. 129/2019, implementing EU Directive 2018/843 — the 5th AML Directive) designates specific categories of business as ‘obliged entities’ (entități raportoare) — subject to anti-money laundering obligations including customer due diligence (CDD), suspicious transaction reporting (STR) and the maintenance of written AML policies and procedures.

Obliged entity category Examples of affected businesses Key AML obligation
Credit institutions & financial services Banks, payment institutions, EMIs, credit firms, investment firms, leasing companies Full CDD/EDD programme; AML policy; compliance officer; ONPCSB reporting
Virtual asset service providers (VASPs / CASPs) Crypto exchanges, wallet providers, token issuers, NFT platforms operating in Romania Registration with ASF/BNR; CDD; transaction monitoring; STR reporting
Real estate professionals Estate agents, real estate developers, property managers, notaries involved in property transactions CDD on buyer/seller; PEP checks; cash transaction monitoring; STR reporting
Accounting professionals Accountants, auditors, tax advisers, bookkeepers — when providing certain services CDD on clients; risk assessment; STR reporting to ONPCSB
Lawyers & notaries When acting as trustee, forming companies, managing client accounts, handling real estate or business transactions CDD; STR reporting through Romanian Bar (for lawyers); ONPCSB
Gambling operators Online and physical casino operators, betting companies, gaming machine operators Player identity verification (CDD); cash limits; ONPCSB reporting
Dealers in high-value goods Art dealers, auction houses, precious metals/gems dealers — cash transactions ≥ €10,000 CDD on customers; cash transaction record-keeping; STR reporting
AML non-compliance carries criminal liability for company directors

In Romania, failure to implement AML procedures, failure to appoint a compliance officer, or failure to report suspicious transactions to ONPCSB can result in criminal liability for the company director personally — not just administrative fines. For regulated entities, AML compliance is a personal obligation of the director, not merely a company compliance matter.

AML Compliance Programme — Core Components

AML component What it covers and why it is required
Business-wide AML risk assessment A documented analysis of the money laundering and terrorist financing risks faced by the business — by product, service, customer type, geography and delivery channel. Required under Law 129/2019 for all obliged entities. Must be updated whenever significant changes occur and reviewed at least annually.
AML policy and procedure manual A written internal policy covering: CDD/EDD requirements, PEP screening, sanctions checking, cash transaction monitoring, correspondent banking controls (where applicable), record-keeping obligations and the process for escalating and reporting suspicious transactions.
Customer due diligence (CDD) All obliged entities must apply CDD to their customers — verifying identity, verifying the nature of the business relationship, and understanding the source of funds for higher-risk customers. Enhanced due diligence (EDD) applies to PEPs, high-risk countries and high-risk transaction types.
Compliance officer (ofițer AML) Romanian law requires obliged entities to designate a compliance officer responsible for AML implementation. The compliance officer must have sufficient authority and independence. Romania For Business SRL assists with designation, job description, training and ongoing support.
Suspicious transaction reporting When an obliged entity suspects that a transaction or funds are related to money laundering or terrorist financing, it must report to ONPCSB (Oficiul Național de Prevenire și Combatere a Spălării Banilor). Romania For Business SRL supports the STR preparation and filing process.
Record-keeping CDD records, transaction records and STR records must be retained for 5 years from the end of the business relationship (10 years in some circumstances). Records must be available to ONPCSB on request within defined timelines.

Regulatory Compliance for Businesses in Romania

Beyond GDPR and AML, companies operating in regulated sectors in Romania face sector-specific compliance obligations — from financial services licensing conditions to environmental requirements, labour law standards and consumer protection rules. Romania For Business SRL designs compliance programmes that address the full regulatory perimeter of the client’s Romanian operations.

Compliance area What we provide
Financial services & fintech Compliance framework design for payment institutions, e-money institutions, credit firms and crypto/VASP companies — BNR and ASF regulatory requirements, ongoing reporting obligations, licence condition compliance and governance frameworks.
Labour law compliance Employment contract compliance review, REVISAL registration procedures, working time and leave entitlement compliance, disciplinary procedure frameworks and termination process review. Integrated with our Contract Law service.
Consumer protection B2C compliance review — consumer contract fairness under Romanian and EU consumer law, distance selling requirements, right of withdrawal documentation, warranty obligations and consumer dispute resolution procedures.
Environmental compliance Basic environmental compliance review for companies with environmental obligations — permit conditions, waste management requirements and environmental reporting obligations. For complex environmental matters, we refer to specialist environmental consultants.
Competition law compliance Basic competition law compliance review — identifying potential horizontal or vertical agreement risks, dominant position concerns and merger control notification thresholds. Specialist competition counsel engaged for complex matters.
Corporate compliance programme A holistic compliance framework covering all relevant regulatory areas — policies, training materials, monitoring procedures, escalation processes and a compliance calendar. Designed for companies that need a structured approach to managing all compliance obligations in Romania.

COMPLIANCE, AML & GDPR SERVICES IN ROMANIA

from €400
fixed fees below

COMPLIANCE, AML & GDPR SERVICES PACKAGE INCLUDES:

  • GDPR compliance audit — gap analysis against EU GDPR and Romanian national requirements
  • GDPR documentation package — privacy policy, cookie policy, ROPA, retention schedule
  • Data processing agreement (DPA / DPA) — between controller and processor
  • Data subject rights procedure — DSAR process, response templates, record-keeping
  • Data breach response procedure — 72-hour ANSPDCP notification protocol
  • AML risk assessment — business-wide AML/CFT risk assessment document
  • AML policy and procedure manual — CDD, EDD, PEP screening, suspicious transaction reporting
  • AML compliance officer designation and training materials
  • ONPCSB suspicious transaction report (STR) support
  • Regulatory compliance audit — sector-specific (financial services, real estate, gambling, etc.)
  • Compliance programme design — policies, training, monitoring and escalation framework
  • ANSPDCP inspection support — document preparation and authority communication

INDICATIVE FIXED FEES — STANDARD COMPLIANCE PACKAGES

  • GDPR compliance audit — gap analysis report (SME, single entity) from €800
  • GDPR documentation package — privacy policy + cookie policy + ROPA from €600
  • Data processing agreement (standard bilateral) from €300
  • GDPR / AML combined compliance audit (SME) from €1,200
  • AML policy and procedure manual (standard — non-regulated sectors) from €600
  • AML policy — regulated sector (financial services, gambling, etc.) from €1,000
  • AML risk assessment document from €500
  • Data breach response plan and notification procedure from €400
  • ANSPDCP inspection preparation from €600
  • Compliance programme design (full framework — policies + training) from €2,000

All fees confirmed in writing before engagement. Large enterprise compliance programmes, multi-jurisdiction frameworks and sector-specific regulatory engagements are quoted after scoping. Fees may be subject to Romanian VAT.

Frequently Asked Questions — Compliance, AML & GDPR in Romania

Yes. GDPR applies to any company that processes personal data of individuals located in the EU — regardless of where the company is incorporated or who owns it. A Romanian SRL owned by a US, UK or non-EU parent is subject to GDPR for all personal data processing activities conducted through the Romanian entity. Foreign-owned Romanian companies must comply with both the EU GDPR and the additional requirements set by Romanian national law implementing GDPR.

ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal) is the Romanian data protection supervisory authority. It has the power to: conduct inspections of companies’ data processing activities, issue warnings and reprimands, impose temporary or permanent bans on data processing, and levy administrative fines of up to €20 million or 4% of global annual turnover. ANSPDCP is an active enforcement authority — Romanian companies have been fined for violations including inadequate data security, unlawful processing and failure to respond to data subject requests.

At a minimum: a privacy policy (external-facing, on your website or shared with customers); a cookie policy (if your website uses cookies); a Record of Processing Activities (ROPA — internal document); data processing agreements with all service providers who process personal data on your behalf; a data breach response procedure; and documented data subject rights procedures. Companies processing large volumes of sensitive data may also need a Data Protection Officer (DPO).

AML obligations in Romania apply to designated categories of business — called obliged entities (entități raportoare). These include: credit institutions and financial services companies; virtual asset service providers (crypto, NFT, wallet services); real estate agents and developers; accountants, auditors and tax advisers; lawyers and notaries (in certain circumstances); gambling operators; and dealers in high-value goods (art, precious metals, luxury goods) for cash transactions above €10,000. If your business falls into one of these categories, AML compliance is mandatory.

Yes, if your company is an obliged entity under Romanian AML law. An AML compliance officer (ofițer de conformitate AML) must be designated — a person with sufficient authority, independence and resources to implement the AML compliance programme. For smaller companies, this role may be combined with other management functions. Romania For Business SRL assists with designation, job description documentation and initial training.

An STR (raport de tranzacție suspectă) is a mandatory report to ONPCSB (the Romanian anti-money laundering authority) filed when an obliged entity suspects that a transaction or funds are connected to money laundering or terrorist financing. STRs must be filed before the transaction is executed where possible — or immediately after where prior notification is not possible. Failure to file a required STR is a criminal offence in Romania.

Customer due diligence (CDD) requires obliged entities to verify the identity of their customers, understand the nature of the business relationship and assess the risk of money laundering. Basic CDD applies to all customers; enhanced due diligence (EDD) applies to politically exposed persons (PEPs), customers from high-risk countries and high-value or unusual transactions. Romania For Business SRL designs CDD frameworks adapted to the client’s specific customer base and risk profile.

Generic GDPR templates may provide a starting point but are rarely sufficient for a specific business’s compliance needs. A privacy policy that does not accurately reflect the company’s actual data processing activities is itself a GDPR violation. ANSPDCP has fined companies for using inadequate or misleading privacy notices. Romania For Business SRL drafts GDPR documentation based on a data mapping exercise specific to the client’s operations — not from generic templates.

72 hours. From the moment a company becomes aware of a personal data breach, it has 72 hours to notify ANSPDCP — regardless of whether it is a working day or weekend. If notification is not possible within 72 hours, the notification must be made as soon as possible with an explanation of the delay. Late notification is itself a GDPR violation. A documented breach response procedure — prepared in advance — is the most effective way to ensure the 72-hour deadline is met.

Yes. Romanian AML law is set out in Law No. 129/2019 on preventing and combating money laundering and terrorist financing, which implements the EU 5th AML Directive (Directive 2018/843). Romania has also enacted additional national requirements beyond the minimum EU standards in certain areas. ONPCSB issues guidance and secondary legislation that obliged entities must monitor and implement. Romania For Business SRL tracks regulatory developments and advises clients on updates to their compliance programmes.