Reporting obligations


Among the obligations imposed to the banks, we notice also the automatic reporting, according to the legal framework, towards the National Office for Prevention and Control of Money Laundering (ONPCSB), of certain transactions performed on the accounts of the clients.

The automatic reporting, indiscriminately, by certain types of transactions in RON or in foreign currency, whose minimum limit is the equivalent in RON of EUR 15,000, regardless of the fact that the transaction is made through one or more operations that seem to be connected. These are automatic reporting operations under no suspicion of being connected to the money-laundering phenomenon, but the regulator decided it is compulsory to send them to the competent authority.

Some examples:

  • Cash operations – cash deposits or cash withdrawals, in RON or in foreign currency, whose minimum limit is the equivalent in RON of EUR 15,000, regardless of the fact that the transaction is made through one or more operations that seem to be connected.
  • External transfers into and from accounts for amounts whose minimum limit is the equivalent in RON of EUR 15,000, regardless of the fact that the transaction is made through one or more operations that seem to be connected. The “external transfers into and from accounts” mean trans-border transfers, as they are defined according to the national regulations in the field, as well as the payments made and received between residents and non-residents on the territory of Romania.

Reporting the transactions that, by their nature, raise suspicions related to the activity on the account:
it is compulsory for the banks to report to the competent authorities on the transactions that, due to insufficient substantiation documents, raise suspicions considering the available documents. Namely, in case, apparently, the transaction does not have a legal or economic aim, or if the transaction may raise suspicions considering its nature and/or its unusual feature compared to the activities of the client.

Some examples:

  • The bank suspects that the account owner manages the account for a third party, without declaring it.
  • Transaction with exceptional volume or that brings relevant modifications to the account, without proper supporting documents and performed without a clear reason, under atypical conditions compared to the normal operations registered on the account.

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