The National Bank’s new policy: from lenient oversight to sanction standards? - Commentary by InfoMarket
Over the past ten years, the National Bank of Moldova’s sanctions policy has gone through several phases: from targeted fines of tens and hundreds of thousands of lei in 2017–2020 to individual sanctions amounting to tens of millions of lei in 2022, and subsequently to a more systematic tightening of supervision in 2025–2026.
The first fine exceeding one million lei was charged in 2022: OTP Bank was fined 4.07 million lei, while five of the bank’s executives were fined a combined total of the same amount. The NBM set a new record in March 2026, imposing a fine of 7.7 million lei on FinComBank and an additional 1.8 million lei on two responsible individuals. The size of the sanctions exceeded previous maximums several times. Are we witnessing the National Bank’s transition to a sanctions-based regulatory model?
The sanctioning practice extends not only to the banking sector but also to other regulated markets—non-bank credit organizations (NBCOs), insurance companies, and fintech. Since 2024, the National Bank of Moldova (NBM) has fined six NBCOs a total of 6.29 million lei. The largest fines were imposed on Prima Finanțare—3.02 million lei (March 2026), Ecofinance Technologies—1.23 million lei (September 2025), and Mikro Kapital Company—1.56 million lei (December 2024).
So far, the sanctions have affected fairly large players in the sector, although there are even larger ones in the market. A total of 103 non-bank credit organizations operate in Moldova, yet only 22 companies have assets and a loan portfolio exceeding 100 million lei—these can likely be classified as medium-sized and large. Under current legislation, an NBCO can be fined up to 10% of its annual revenue. So, purely mathematically, the fines could be even higher.
Previously, sanctions against non-bank credit organizations and insurance companies (though certainly not those worth millions) were imposed by the National Financial Market Commission. However, as of July 1, 2023, oversight of the non-bank credit market and the insurance market was transferred to the NBM. And starting in 2024, the NBM began imposing monetary sanctions on the insurance market as well. To date, three insurance companies have been fined (there are nine in total on the market, not counting brokers), though the amounts of the sanctions have not yet exceeded 140 thousand lei.
The difference in approaches to various market segments has become a topic of discussions among financial sector participants. However, in response to a request from InfoMarket, the NBM stated that sanctions are determined not by the type of institution—banking or non-banking—but based on the nature and severity of the violations, their duration, impact on the market, potential benefits, and other criteria provided for by law. The regulator also emphasizes that it applies the “principle of proportionality and fairness” regardless of the category of financial institution and applies a unified legal framework in the area of preventing and combating money laundering and terrorist financing.
As InfoMarket has learned, inspections at a number of financial institutions are ongoing or in the planning stages, including major players. The market is awaiting further decisions from the regulator. Close attention will be paid to the consistency of sanctioning practices and the comparability of fine amounts for companies of different sizes. After all, if medium-sized companies with loan portfolios of 200–300 million lei were found to have violations that resulted in fines of 1.5–3 million lei, then the fines for those with loan portfolios ranging from 1 billion to 8 billion lei (there are five such companies) should be commensurate. Or should they not?..
One of the most notable cases in recent months has been the situation surrounding Paynet Services, which was fined twice over the course of several months. In October 2025, the company was fined 1.7 million lei. The decision was appealed to the Executive Committee of the NBM. And in February 2026 (four months later), the regulator imposed another fine on the company—1.52 million lei. The total amount of penalties reached 3.23 million lei, making this case one of the most discussed in the fintech sector.
The NBM rejects the characterization of such cases as “accumulation of fines,” emphasizing that each sanction is the result of a separate inspection procedure. According to the regulator, each inspection has its own subject of analysis, concerns specific categories of risks, clients, or transactions, and decisions are made based on an individual assessment, taking into account the organization’s level of cooperation and the corrective measures taken. “The application of multiple sanctions is not of an artificially cumulative nature, but reflects objective and separate conclusions in accordance with the legal framework and the principles of prudential supervision,” the NBM notes.
The fintech sector has been actively developing in Moldova in recent years, and the market features international brands alongside local players. Some market participants acknowledge that the tightening of sanctions oversight has become an additional factor in assessing future investment decisions and prospects for business expansion in the country. At the same time, industry representatives emphasize the need for greater predictability in regulatory practices and a clearer understanding of the criteria for applying sanctions.
It is worth recalling that since the banking system was established, market participants have had a more or less clear understanding of how the NBM treats commercial banks. The first Governor of the NBM, Leonid Talmaci, limited himself to warnings alone, and during his 18 years in office, he did not impose a single fine on commercial banks; after all, the regulator’s main task at the time was to allow Moldova’s banking system to take shape and strengthen itself, to grow before international investors began buying it up. After he stepped down, the imposition of penalties became a more common practice. And over the course of two decades, the banking system was, in essence, trained by a regulator that could impose sanctions at any moment. Starting in mid-2023, the other markets supervised by the NBM began to feel the impact as well. But while the excessive requirements for commercial banks are justified by the fact that banks operate with attracted deposits—the public’s money—and the NBM protects depositors’ interests, the case of non-bank credit organizations (NBCOs) and the fintech market is a slightly different story: they operate and take risks with their own money.
Fintech and NBCOs market participants who agreed to comment on the situation to the InfoMarket agency claim that a significant portion of the sanctions is linked to differences or even ambiguities in the interpretation of procedural requirements. According to them, in a number of cases, the identified violations, in their assessment, did not result in harm to clients, counterparties, or the state, yet served as grounds for substantial fines. In this situation, market participants point to a lack of clarity regarding the objectives of certain supervisory decisions—a fine for the sake of a fine? At the same time, market representatives point to a lack of direct and constructive dialogue with the regulator, as well as the need for clearer explanations of supervisory practices.
The NBM rejects the view that sanctions are an end in themselves and emphasizes that the measures are aimed at ensuring financial market stability, protecting consumers, and reducing systemic risks. The NBM notes that fines are imposed in cases of serious or repeated violations, whereas a warning may be issued if the violation is deemed minor after analyzing all circumstances. Furthermore, the amounts collected are transferred in full to the state budget, and the regulator itself does not derive any direct financial benefit from the application of sanctions.
Some companies have attempted to challenge the disputed decisions. For example, Mikro Kapital Company, having received a fine in 2024, challenged the NBM’s decision in court. However, nine months after the sanctions were imposed, the company withdrew its appeal from the Court of Appeals. The company declined to comment on this decision to us.
Others sought to resolve the disputed issues without going to court—through the NBM’s Executive Committee—while simultaneously attempting to convey to the NBM’s leadership their position regarding the potential impact of the sanctions on the market, investment activity, and business conditions. Since 2024, one insurance company and two insurance brokers have filed complaints with the NBM Executive Committee regarding decisions made by the regulator’s staff. All appeals were rejected.
The NBM explains that the rejection of the appeals confirms the legality and validity of the NBM’s initial decisions. “These decisions are already the result of a comprehensive analysis, supported by evidence and exhaustive legal justifications. In practice, appeals are rejected when market participants do not provide new evidence or violations of the law, but merely repeat arguments that have already been analyzed,” the NBM emphasized.
Market participants also claim that the NBM does not fully understand how the fintech sector actually works and is simply following instructions. They tend to believe that the regulator’s Executive Committee includes newly appointed members who may not have fully grasped all the nuances, or who have placed complete trust in the decisions made by the supervisory department. In an attempt to explain the specifics of the fintech sector’s operations, some of the fined companies tried to take a conciliatory approach—not filing a lawsuit immediately, but bringing the situation to the attention of the NBM Executive Committee and explaining the causes and consequences—how the sanctions could impact the market, investments, and the country’s reputation.
However, none of them managed to convey their position to the NBM leadership in person: requests for a hearing from the companies we were able to speak with were rejected. Moreover, companies generally view the likelihood of a review of these decisions at the internal level with skepticism.
In such cases, it makes sense to raise the issue of independent arbitration, which could verify the competence of the regulator’s inspectors and truly hear the position of the company subject to inspection—before legal proceedings. Otherwise, any complaints directed at the NBM Executive Board will always be rejected; after all, this is a matter of the regulator’s reputation and that of the specialists working there.
Independent arbitration is a modern practice resorted to by large companies, particularly those with foreign investment, that disagree with the decisions of tax or customs authorities. After all, litigation is a lengthy and complex process that consumes significant time and resources that could be directed toward development. Moreover, it entails investment risks for the entire country.
Ultimately, the lack of constructive dialogue and sweeping punitive measures are a red flag for potential foreign and local investors, signaling the risks of uncertainty and abuse of sanctions in the country and in specific markets. In the absence of dialogue, tensions between the regulator and the market may also escalate.
Going back to the beginning. As reported to InfoMarket, FinComBank and the fined responsible parties have initiated legal proceedings to challenge the regulator’s decisions. These proceedings may attract additional attention from market participants, given the scale of the sanctions imposed and the bank’s significance to the national financial sector. As a reminder, Fincombank remains the only bank in Moldova owned by Moldovan shareholders, with no well-known international financial institutions or major foreign banks and funds among them.
The banking market, the non-bank lending sector, fintech companies, the insurance market…—almost all of their participants are convinced that the tightening of supervision, including through sanctions, has only just begun. At the same time, many believe that this wave will not affect certain economic agents toward whom the regulator has a “special attitude,” no matter how much it denies it. Market participants have been saying this for many years, observing instances where inspections result in fines of millions for some, while for others they result in nothing more than warnings.
In this storm, either someone will drown, or the market will “vote with its feet.” //28.05.2026 — InfoMarket.
P.S.: The National Bank's new sanction was published this week. By a decision adopted on April 23, 2026, the regulator imposed the sanction on Moldindconbank. Five members of the Board of this financial institution and two members of the Executive Committee received a written warning from the NBM regarding a number of shortcomings in the bank’s management system. At the same time, the NBM notes that the bank is operating as usual, providing its full range of services. The regulator also reported that one of the members of Moldindconbank’s Executive Committee appealed the decision to the Executive Committee of the NBM with the aim of partially revoking the penalty imposed.
