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Cover: "129/2019", the Romanian anti-money-laundering law behind the source-of-funds check

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Where did the money come from? What a Romanian notary and bank will ask you to prove

Notaries, banks and developers in Romania must check where a buyer's money comes from. What Law 129/2019 requires, and the documents that explain each source of money.

7 min full read · 30 sec short versionFrom: Source of funds for a property in Romania: the document pack a notary and a bank will ask for17.10.2026
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129/2019the anti-money-laundering law

Banks, notaries, lawyers, developers and real estate agents are all reporting entities under Romania's Law 129/2019 (Art. 5).

€10,000the routine reporting threshold

Cash transactions and international bank transfers of €10,000 or more are reported to ONPCSB automatically (Art. 7). It is not a sign of suspicion.

3working days to report

Routine reports on cash and international transfers go to ONPCSB within 3 working days of the transaction (Art. 7(7)).

Art. 11(9)no checks, no transaction

A reporting entity that cannot complete its customer checks must not carry out the transaction. A missing document can stop a signing.

8sources of money, one paper trail

Salary, a property sale, a gift, an inheritance, a loan, business income, a fund withdrawal or crypto: each needs its own documents.

Source of funds in Romania: the short answer

When you buy property in Romania, the notary, the bank and the developer or agent are all "reporting entities" under Law 129/2019 on preventing money laundering. Each of them must identify you, understand the purpose of the transaction and, where the risk calls for it, check where the money comes from. If they cannot complete these checks, the law tells them not to carry out the transaction.

The law does not contain a list of documents. Each bank and notary sets its own. What they all want is the same thing: a clear paper trail from the source of the money to the account it is paid from.

Put simply: the question is not whether you have the money. It is whether you can show, on paper, how you got it.

Our guide to transferring money to Romania covers the transfer itself: accounts, exchange rates and cash limits. This article covers the file that comes before it.

Who checks your money, and under which rule

Who Why they check Rule in Law 129/2019
The Romanian bank that receives or sends the money Credit institutions are reporting entities Art. 5(1)(a)
The notary who signs the deal Notaries are reporting entities when they handle the sale or purchase of real estate Art. 5(1)(f)
A lawyer who assists with the purchase Lawyers are covered on the same terms as notaries Art. 5(1)(f)
The developer or real estate agent Real estate agents and developers are reporting entities Art. 5(1)(h)

So the same question may come from three directions. That is not a sign of suspicion. It is a duty that applies to each of them separately, in every deal.

Reports go to Romania's financial intelligence unit, the National Office for the Prevention and Control of Money Laundering (ONPCSB).

What the law actually requires

Article 11 of Law 129/2019 sets the standard checks ("know your customer"). In plain terms, the reporting entity must:

  1. Identify you and verify your identity from reliable, independent documents, before the transaction.
  2. Identify the beneficial owner. If you buy through a company, they will want to know who stands behind it.
  3. Understand the purpose and nature of the transaction.
  4. Check that the transaction fits what they know about you, including, where relevant, the source of funds.
  5. Check anyone acting for you. If a representative signs under a power of attorney, they verify that person too.

Article 17 adds enhanced checks where the risk is higher. Two cases matter for property buyers:

  • Unusually large or complex transactions, or ones that do not fit the usual pattern, must have their context and purpose examined.
  • Politically exposed persons (senior public office holders), their family members and close associates: the reporting entity must establish both the source of funds and the source of wealth. This continues for at least 12 months after the person leaves office.

The law also lists factors that raise the risk. One of them is payments received from unknown or unassociated third parties. That is why the money should come from your own account.

And if the checks cannot be completed? Under Article 11(9), the reporting entity must not carry out the transaction and, where there are grounds for suspicion, must file a suspicious transaction report. In practice, a missing document can stop a signing.

Routine reports are not suspicion

Some reports are automatic, and they say nothing about you:

  • Cash of €10,000 or more: reporting entities report cash transactions at or above the lei equivalent of €10,000, including linked operations (Art. 7(1)).
  • International transfers of €10,000 or more: banks report external transfers into and out of accounts at or above that amount (Art. 7(3)).
  • Deadline: these reports go to ONPCSB within 3 working days of the transaction (Art. 7(7)).

A property purchase from abroad will almost always cross the transfer threshold. The report is filed whether or not anything is unusual. What makes a difference is whether your file answers the questions before they are asked.

Reporting entities must keep the documents from these checks for 5 years after the business relationship ends or the transaction is completed (Art. 21(2)).

The question is not whether you have the money. It is whether you can show, on paper, how you got it.

The document pack, by source of money

The table below is a practical guide, not a legal list. Each bank and notary decides what it needs. Ask both for their list in writing, early.

Where the money comes from What usually explains it
Salary and savings Payslips or an annual salary statement (in Israel, Form 106), and bank statements showing the savings building up
Sale of a property The sale contract, and the bank statement showing the proceeds arriving in your account
A gift from family A signed gift letter, the giver's bank statement showing the transfer, and a document showing the relationship
An inheritance The inheritance order or probate order, with an apostille and certified translation, and a statement showing the funds received
A loan or a mortgage on a home you own The loan agreement and the lender's confirmation that the loan was paid out
Business income or dividends Financial statements, the dividend decision and an accountant's confirmation
A pension or savings fund withdrawal The fund's statement confirming the withdrawal
Cryptoassets Exchange account statements showing when the assets were bought, sold and converted, and the transfer from the exchange to your bank account

Three rules apply to every row:

  • Follow the money, not just the balance. A large deposit with no explanation is the most common question. Explain every significant one.
  • Translate only what is needed. Ask the notary and bank which documents they need translated into Romanian, and which need an apostille. We list the common Israeli documents in our guide to apostilles.
  • Expect more questions on crypto. Exchange records are less familiar to banks than a payslip. Prepare the full trail, and confirm with the receiving bank in advance that it accepts funds of this origin.

How to prepare the file from abroad: 6 steps

  1. Map the money. Write one page: how much, from which source, through which accounts, on which dates.
  2. Pay from one account in your name. The buyer in the contract and the account holder should be the same person. A payment from a relative or a company opens a new question.
  3. Ask for written lists. From the receiving bank, the notary and, if you take a mortgage, the lender.
  4. Collect and translate. Order the documents, apostilles and certified translations the lists ask for. Start early: this is usually the slowest part.
  5. Keep transfer confirmations. Keep the SWIFT confirmation (MT103) for every payment. It proves the money left your own account.
  6. Have a lawyer of your own check the file. The notary is neutral, and the developer's lawyer represents the developer. An independent lawyer works only for you.

If you finance part of the price, the bank will also check your income. A Romanian bank may finance up to 70% of the price, so your equity is at least 30%, and that equity is the part your source-of-funds file has to explain. We cover the bank's side in our mortgage guide.

As a developer, we are a reporting entity under the same law, so we ask these questions too. Our company lawyer represents the company only. We recommend that every buyer hire an independent lawyer.

From the field: the father who was to receive the money

Attorney Ilan Leibovitch recalls a client's purchase abroad:

The due diligence came back clean: no attachments, no charges, no debts. The seller's lawyer and I agreed a final draft, and a third party was to sign on the seller's behalf. I asked for the power of attorney and received it at once. Everything looked fine, but something still bothered me.

An hour later I called the seller's lawyer again and asked where the money would be paid. Into the attorney-in-fact's account, he said. I asked for the money to go to the seller's own account, or for the power of attorney to state explicitly that the representative may receive it. The excuses began: the representative is the seller's father, the seller is studying abroad, it will take time. I offered a phone or video call in which the seller would confirm. He was never available.

I explained the situation and the risk to my client. That apartment was not bought.

The paper trail works in both directions. You should be able to show where your money comes from, and the deal should show exactly where it goes.

Frequently asked questions

Does a Romanian notary have to check where my money comes from?

Yes, when the risk calls for it. Notaries are reporting entities under Law 129/2019 when they handle the sale or purchase of real estate. They must identify you, understand the purpose of the transaction and check that it fits what they know about you, including the source of funds where relevant.

Which documents prove the source of funds in Romania?

The law does not list them. Usually whatever explains the money: payslips and bank statements for savings, a sale contract for a property you sold, an inheritance order, a loan agreement or a gift letter. Ask the bank and the notary for their list in writing.

Is my transfer reported to the authorities?

International transfers of €10,000 or more are reported routinely by the bank to ONPCSB, within 3 working days. This is an automatic report and not a sign of suspicion.

What happens if I cannot prove the source of funds?

Under Article 11(9) of Law 129/2019, a reporting entity that cannot complete its checks must not carry out the transaction. In practice, the signing may be postponed until the file is complete.

Can a relative pay part of the price for me?

It can be done, but it needs to be explained: a gift letter, the relative's bank statement and proof of the relationship. Payments from unknown or unassociated third parties are a risk factor under the law, so it is simpler if the money first reaches your own account, with the paperwork.

The bottom line

In Romania, the source-of-funds check is not a favour you ask of the bank. It is a legal duty of every professional in the deal.

The way to make it painless is to prepare the file before you choose the property: one page that maps the money, documents for each source, and one account in your name.

If you are planning a purchase in Romania, with us or anywhere else, book a 30-minute call with me. We will go through your sources of money and build the list of documents together.

Moti Azulay, Compass Group Romania

Sources: Law 129/2019 on preventing and combating money laundering, consolidated form (legislatie.just.ro), Art. 5, 7, 11, 17 and 21 · National Office for the Prevention and Control of Money Laundering (ONPCSB) · Israel Tax Authority, Form 106 (in Hebrew) · Hague Conference: Apostille Convention status table

This article is for general information only and is not legal, tax or financial advice. The rules are correct as of 17 October 2026. The documents each bank and notary require can differ; ask them in writing and consult an independent lawyer.

Now you know more.

✓ who checks your money in a Romanian deal✓ what Law 129/2019 requires✓ which documents explain each source of money✓ how to prepare the file from abroad
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This article is general information, not legal, tax or financial advice. Consult local professionals before any transaction.