POLITICALLY EXPOSED PERSONS AND THE STRUCTURAL LIMITS OF ROMANIA’S AML/CFT FRAMEWORK

Abstract

This paper examines key weaknesses in Romania’s anti-money laundering and counter-terrorist financing (AML/CFT) regulatory framework, with a particular focus on the detection and prosecution of money laundering involving politically exposed persons. The analysis begins with an original audit of the May 2025 list of important public functions maintained by Romania’s National Integrity Agency, which serves as the main reference tool for screening politically exposed persons. By cross-checking the list against the categories defined in the relevant legislation, the paper shows that this instrument is incomplete and therefore unreliable as a basis for effective compliance. The paper then identifies two additional structural vulnerabilities: the uneven supervisory coverage of obliged entities outside the banking sector and an enforcement system in which major cases frequently expire due to limitation periods or fail to be investigated at all. Taken together, these deficiencies suggest that Romania’s AML/CFT framework is not merely affected by isolated implementation gaps, but suffers from structural limitations that weaken its capacity to identify, investigate, and prosecute money laundering risks associated with politically exposed persons.