Ilan Leibovitch & Co.Lawyer and real estate developer
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Proving the Source of Funds When Buying Property in Romania: What the Law Requires and How to Prepare a File

Who checks the source of money in a Romanian property deal under Law 129/2019, what is reported automatically, documents for each source, the file.

By Adv. Ilan LeibovitchUpdated: 5 min read
RegulationPl. I

In brief

In a real estate transaction in Romania, the bank, the notary, the lawyer and the developer or broker are “reporting entities” under Law 129/2019 on the prevention of money laundering. Each of them must identify you, understand the purpose of the transaction and, where the risk justifies it, check the source of funds. If the check has not been completed, the law directs that the transaction not be carried out, so an orderly document file is a practical condition for signing.

Key takeaways

  1. 1Under Article 5 of Law 129/2019, banks, notaries, lawyers, brokers and real estate developers are reporting entities.
  2. 2Cash transactions and international transfers of EUR 10,000 or more are reported to ONPCSB routinely, within 3 working days. This is not a sign of suspicion.
  3. 3Under Article 11(9), a reporting entity that has not completed the customer check will not carry out the transaction.
  4. 4The law does not set a list of documents; each source of money, such as salary, sale of an apartment, gift, inheritance or crypto, has its own customary documents.
  5. 5Pay from a single account in your name. Payment from an unrelated third party is a risk factor under the law.

Israeli buyers are sometimes surprised when a notary or a bank in Romania asks them to explain where the money comes from. This is not an expression of suspicion; it is a legal duty that applies to every professional in the transaction. The question is not whether you have the money, but whether you can show on paper how it reached you. Those who prepare the answer in advance avoid delays in signing.

Why are you asked where the money comes from?

The source is Law 129/2019, which is designed to prevent money laundering and terrorist financing. The law defines a range of professionals as “reporting entities” and requires them to know the customer and the transaction and, where necessary, also to establish where the money came from. It contains no closed list of documents, so each bank and each notarial office draws up its own list. The common denominator: a documented chain linking the source of the money to the account from which the payment is made.

Cash transactions and international transfers of EUR 10,000 or more are reported to ONPCSB routinely, within 3 working days. This is not a sign of suspicion.

Key takeaways

Who checks the money in the transaction, and under which article?

WhoWhy they checkArticle of Law 129/2019
The Romanian bank receiving or sending the moneyBanks are reporting entities5(1)(a)
The notary who signs the transactionA notary is a reporting entity when handling the purchase or sale of real property5(1)(f)
A lawyer accompanying the purchaseLawyers are included on the same terms as notaries5(1)(f)
The developer or the brokerBrokers and real estate developers are reporting entities5(1)(h)

The same question may therefore reach you from three different directions. Each of them is obliged to check separately. The reports go to Romania's financial intelligence unit, ONPCSB (Oficiul Național de Prevenire și Combatere a Spălării Banilor, the National Office for the Prevention and Combating of Money Laundering).

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What does the check include, and when is it stricter?

The basic check, known as “know your customer”, is defined in Article 11 of the law. In practice it includes five components:

ComponentWhat it means for you
Identification and verificationPresenting a reliable and independent identity document, before the transaction
Beneficial ownerWhen buying through a company, disclosing the real controlling owners
Purpose of the transactionAn explanation of the nature of the transaction and why it is being made
Consistency with the profileThe transaction must be consistent with what is known about you, sometimes including the source of funds
Anyone acting on your behalfAn attorney-in-fact also undergoes identification and verification

When the risk increases, Article 17 requires a more thorough check. Two situations are particularly relevant to real estate buyers. The first: an unusually large or complex transaction that does not match a normal pattern, in which case its context and purpose must be examined. The second: senior public figures, their relatives and close associates, in respect of whom both the source of the money and the source of wealth must be established, for at least one year after they have left office. Among the risk factors the law mentions is also a payment coming from a third party who is unknown or has no connection to the transaction.

When the check has not been completed

Under Article 11(9), a reporting entity that cannot complete the check will not carry out the transaction and, if there are grounds for suspicion, will report a suspicious transaction. In practice, one missing document can delay a signing.

Does a report on your transfer mean there is suspicion?

Not at all. Some reports are made by operation of law for every transaction that exceeds a certain threshold:

What is reportedThresholdArticle
Cash transactions, including linked transactionsEUR 10,000 or more, at the equivalent value in lei7(1)
Bank transfers to and from RomaniaEUR 10,000 or more7(3)
Deadline for reporting to ONPCSBUp to 3 working days from the transaction7(7)

Anyone financing a purchase from abroad will almost certainly exceed the transfer threshold, so a report will be made in any event and it says nothing about you. The reporting entity keeps the check materials for five years from the end of the relationship or the execution of the transaction (Article 21(2)).

Which documents explain each source of money?

This is not a statutory list but a compilation of what is usually accepted. Each entity decides for itself, so it is worth obtaining a written list from it at an early stage.

Source of the moneyWhat usually explains it
Salary and savingsPayslips or Form 106, and bank statements showing how the savings accumulated
Sale of an apartmentThe sale contract, and a bank statement showing that the proceeds entered your account
Gift from familyA signed gift letter, a bank statement of the donor showing the transfer, and a document proving the relationship
InheritanceA succession order or probate order with an apostille and certified translation, and a bank statement showing receipt of the money
Loan or mortgage on an apartment you ownThe loan agreement and the lender's confirmation that it was advanced
Business income or dividendFinancial statements, a distribution resolution and an accountant's confirmation
Withdrawal from a pension fund, provident fund or study fundThe fund's confirmation of the withdrawal
CryptoExchange reports on purchase, sale and conversion, and the transfer from the exchange to the bank account
  • Explain movements, not just balances. The most frequently repeated question concerns a large deposit with no explanation, so every significant deposit needs a document explaining it.
  • Translate as required. Confirm in advance which documents need translation into Romanian and which need an apostille, and do not translate beyond that.
  • Crypto requires full documentation. Banks are less familiar with crypto exchange reports than with payslips, so prepare the entire chain and confirm in advance that the receiving bank is prepared to accept such funds.

How do you build the file from Israel?

  1. Mapping: a single page describing the amounts, the sources, the accounts through which the money passed and the dates.
  2. One account: the payment is made from an account registered in the name of the person who appears as buyer in the contract. A transfer from the account of a relative or a company raises an additional question.
  3. Written lists: from the bank receiving the money, from the notary and, with financing, also from the lending bank.
  4. Collection and translation: ordering the documents, the apostilles and the certified translations. This stage usually takes the longest, so start it early.
  5. Transfer evidence: keeping a SWIFT confirmation (MT103) for each payment, as evidence that the money left your account.
  6. A lawyer acting for you: reviewing the file before submission. The notary is not a party, and the developer's lawyer works for the developer.

If part of the price is financed, the bank will also check income. According to common practice among Romanian banks, financing can reach up to 70% of the price, so the equity, at least 30%, is the part the source of funds file needs to explain.

And what about the opposite direction: where does the money go?

The paper trail works in both directions. Just as you show where the money comes from, the transaction must show exactly where it goes. If you are asked to transfer the proceeds to the account of the seller's attorney-in-fact and not to the seller's own account, demand that the power of attorney expressly permit the receipt of funds, or direct confirmation from the seller. A refusal or evasion is a sign to stop and check.

What should be done before signing?

Prepare the file before choosing a property: a page mapping the money, documents for each source, and one account in your name. When we accompany a buyer, we build the list of documents with the buyer against the written requirements of the bank and the notary, and also check the beneficiary account details on the seller's side. The checks under Romanian law are carried out by the notary, the bank and a lawyer licensed to practise in Romania.

General information only

The content of this article is general information only and does not constitute legal or financial advice. The rules are correct as of October 2026, and the documents each bank and notary require may differ. Before a transaction, ask for a written list and consult an independent lawyer.

Frequently asked questions

Is the notary in Romania required to check where my money comes from?

Yes, where the risk justifies it. Under Law 129/2019 a notary is a reporting entity when handling the purchase or sale of real property, and must identify you, understand the purpose of the transaction and check that it is consistent with what is known about you, including the source of funds where relevant.

Is my transfer to Romania reported to the authorities?

International transfers of EUR 10,000 or more are routinely reported 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 has not completed the check will not carry out the transaction. In practice, the signing may be postponed until the file is complete.

Can a family member pay part of the price?

Yes, but it must be explained: a gift letter, the donor's bank statement and proof of the relationship. Payment from an unrelated third party is a risk factor under the law, so it is simpler for the money to pass first to your account, with the documents.

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Sources

  1. Law 129/2019 on the prevention of money laundering - Romanian legislation portal
  2. ONPCSB - Romanian National Office for the Prevention and Combating of Money Laundering
  3. Israel Tax Authority - Form 106
  4. HCCH - Status table of the Apostille Convention

The information in this guide is general in nature and does not constitute legal or tax advice on any specific transaction. Every transaction is assessed on its own facts.

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