The segregated-funds rule
Article 13 of Law 124/2015 — the law approving and amending GEO 77/2009 — requires Romanian gambling operators to segregate player funds from operational funds. The implementation rules under ONJN Order 226/2024:
- Player balances (deposits not yet wagered, plus winnings not yet withdrawn) must sit in a separate Romanian-bank account, distinct from the operator's working capital and operational funds.
- The segregated account must be held in a Romanian commercial bank — typically Libra Internet Bank for ONJN-licensed operators given banking constraints (see our non-resident banking guide).
- Reconciliation between recorded player liabilities and segregated bank balances must be performed daily and documented monthly. ONJN inspectors sample-audit this reconciliation in every routine inspection.
- Shortfalls — situations where segregated balances are less than recorded player liabilities — trigger immediate regulator notification and remediation. Material or repeated shortfalls trigger licence suspension under Article 27 of GEO 77/2009.
- Surplus management — funds in excess of player liabilities can be swept to operational accounts but only with documented procedures and regulator visibility.
The segregated-funds rule is the most consequential single compliance obligation for Romanian operators. Failures are detected quickly by inspectors and treated severely; remediation is operationally demanding.
The central self-exclusion register
Romania operates a centralised self-exclusion register managed by ONJN under Article 22 of GEO 77/2009 as amended. Mechanics:
- Voluntary entry — players can self-exclude themselves from all Romanian-licensed gambling for periods of 6 months, 1 year, 3 years, or indefinitely.
- Mandatory operator integration — every Class 1 operator must integrate with the central register and check the player's status before account opening, before significant deposits, and at regular intervals during active play.
- Court-ordered entries — courts can mandate self-exclusion in family-protection or debt-related proceedings.
- Affiliated-family exclusion — family members of problem gamblers can request exclusion of the affected person; ONJN reviews these requests.
- Removal procedure — once entered, exclusion cannot be reversed before the chosen period expires (with limited exceptions for hardship documented to ONJN).
The register is the single most important responsible-gambling tool in the Romanian regime. Operators serving self-excluded players — whether knowingly or through integration failures — face immediate fines, suspension, and potential individual liability for compliance officers. This is among the most frequent enforcement findings.
Deposit limits and reality checks
Under OUG 82/2023, Romanian operators must implement structured deposit-limit and session-management tools:
- Mandatory deposit-limit setting at account opening — every new player must set daily, weekly, and monthly deposit limits before first deposit. Default-zero or no-limit settings are not permitted.
- Cool-off period for limit increases — players raising their own deposit limits face a mandatory 24-hour cool-off period before the higher limit becomes effective. Decreases are immediate.
- Reality checks during play — operators must display session-time, session-spend, and net-position reminders at intervals (typically every 30 minutes of continuous play).
- Loss-limit prompts — when a player approaches significant losses (typically defined as 25%, 50%, 75% of their declared deposit limit within a 24-hour period), prompts encouraging review of play behaviour must trigger.
- Time-limit setting — players can voluntarily set daily, weekly, or monthly session-time caps; operators must enforce these.
The operational implementation requires integration into the gaming-platform UX rather than back-office controls alone. Sample audits in ONJN inspections include screen recordings of the player journey to verify that prompts and limits trigger as required.
AML and KYC under AMLD6 transposition
Romanian gambling operators are subject to the Romanian transposition of AMLD6 (Directive (EU) 2018/1673) under Law 129/2019 as amended. The framework:
- Customer due diligence (CDD) at account opening — identity verification using government-issued documents, address verification, sanctions screening, PEP (politically exposed persons) checks.
- Enhanced due diligence (EDD) for higher-risk customers — non-EU residents, players from FATF high-risk jurisdictions (see FATF list), PEPs, players triggering AML alerts.
- Transaction monitoring — automated and manual review of player transaction patterns. Specific threshold-based alerts (large single deposits, rapid deposit-withdraw cycles, deposit-without-play patterns).
- SAR filings (Suspicious Activity Reports) via SOIIA — Romania's centralised AML reporting system operated by ONPCSB. Reports must be filed within strict timelines (typically 3 working days of suspicion arising).
- Source-of-funds documentation for higher-value transactions — typically deposits above €2,000 cumulative within 30 days trigger SOF requests; thresholds vary by player risk profile.
- Record retention — all CDD records, transaction logs, and SAR-related documents retained minimum 5 years post-account-closure.
AML failures are the second most common reason for licence suspension after substance failures, and the most common reason for individual fines against compliance officers. Operators with mature MGA or UKGC AML programmes typically adapt them for Romania with moderate effort; operators new to regulated AML face material build-out work.
The compliance officer's daily duties
The Romanian compliance officer — registered with ONJN as the licensee's responsible person under ONJN Order 145/2018 — carries a defined daily and weekly workload:
- Daily review of AML alerts generated by transaction-monitoring systems; escalation to SAR drafting where warranted.
- Daily review of segregated-funds reconciliation outputs from finance team.
- Daily review of responsible-gambling intervention logs — self-exclusion enrolments, deposit-limit breaches, problem-gambler escalations.
- Weekly review of player complaints registered through the operator's complaint channel and through ONJN's public portal.
- Monthly compliance dashboard to the operator's board summarising AML, RG, segregated-funds, and inspection-readiness status.
- Quarterly training for customer-facing staff on AML, RG, fraud prevention, and recent regulatory developments.
- Annual programme review updating policies and procedures against regulatory changes.
- Inspection coordination — primary point of contact for ONJN inspectors during scheduled and unannounced visits.
The role requires 40+ hours per week of attention for a typical mid-sized Class 1 operator. Operators that under-resource the compliance function (using junior staff or shared-services arrangements) routinely face inspection findings within the first 12 months.
The penalty regime
Romanian gambling non-compliance penalties under Article 28 of GEO 77/2009 and OUG 82/2023:
- Fines — ranging from RON 5,000 for minor administrative breaches to RON 1,000,000 (~€200,000) for serious AML or substance failures. Repeat offenders face escalated fines.
- Licence suspension — typically 30–180 days for material breaches, with operations halted during the period and the operator unable to accept new players or deposits.
- Licence revocation — for serious, persistent, or fraudulent breaches. Revocation is the regulator's most severe sanction and is followed by a multi-year period during which the operator's shareholders and directors face fit-and-proper concerns for any future licence application.
- Individual fines — against compliance officers, directors, or shareholders for personal compliance failures. Capped at RON 100,000 per individual per finding.
- Criminal referral — for fraud, money laundering, or unlicensed gambling. Romanian criminal-law gambling offences carry imprisonment of 6 months to 7 years.
- Reputational consequence — sanctions are published in the ONJN licensees register and carry material commercial implications for B2B relationships and banking access.
The Romanian penalty regime is materially stricter than offshore alternatives and broadly comparable to Malta and UK in rigour. Operators planning Romanian operations should budget for compliance investment proportionate to the regulatory risk rather than treating it as a cost to minimise.
Frequently asked questions
Where do segregated funds need to sit?
In a Romanian commercial bank account, distinct from the operator's working capital. Most ONJN licensees use Libra Internet Bank given the broader banking constraints on gambling operators. The account must be in the licensee's name (not in a trust or escrow arrangement), with funds available for player withdrawal at any time. Reconciliation between recorded player liabilities and the segregated balance is performed daily.
How does the central self-exclusion register work?
ONJN operates a centralised database that operators query in real time. Every player account-opening, every significant deposit, and (at configured intervals) every active session triggers a register check. Self-excluded players are blocked from opening accounts or transacting. Operators that fail to integrate or that serve self-excluded players face immediate fines and potential suspension. The integration is technical, not procedural — there is no manual workaround.
Are reality checks mandatory or just recommended?
Mandatory under OUG 82/2023 as amended. Session-time, session-spend, and net-position reminders must trigger at defined intervals (typically every 30 minutes of continuous play). Loss-limit prompts trigger at 25%/50%/75% of declared deposit limits. The specific implementation can vary by operator UX, but the triggering events and core message content are prescribed. Inspectors sample-audit screen recordings of the player journey.
What is the AML threshold for SAR filing?
There is no fixed monetary threshold — SAR filing is triggered by suspicion rather than amount. In practice, automated transaction-monitoring systems generate alerts based on patterns (rapid deposit-withdraw, large unusual transactions, deposit without play, sudden behaviour changes) and the compliance officer reviews each alert for SAR-worthiness. Suspicion-of-suspicion is itself reportable; the threshold is set deliberately low under the AMLD6 transposition. SARs must be filed within 3 working days of suspicion arising.
Who can be the compliance officer?
A Romanian-resident individual with documented gambling-compliance experience (typically 3+ years in AML, RG, or regulatory affairs at a gambling operator or specialist firm). The officer must not hold a board seat or executive operational role at the same operator (the functional-independence requirement) and must have a direct reporting line to the board bypassing operational management. Non-Romanian-resident compliance officers are not accepted. Shared compliance officers across separately-licensed entities are not permitted.
What happens if I fail an inspection?
Inspectors document findings in a written report. Findings are categorised by severity. Administrative findings typically trigger remediation requirements with 30–90 day deadlines and follow-up inspection. Material findings trigger fines and may trigger short-term suspension. Serious findings — particularly substance, AML, or segregated-funds failures — can trigger immediate suspension and licence-review proceedings. The operator has rights of appeal but operations remain halted during appeal in suspension cases.
Talk to us
Romanian gambling compliance is operationally heavy — segregated funds, real-time self-exclusion integration, structured RG controls, AMLD6-aligned AML, daily compliance-officer workload. Bespoke engagements include compliance-programme design, policy authoring, compliance-officer recruitment support, and inspection-readiness preparation for the first 12 months. Book a discovery call.
Related guides
- iGaming licensing under ONJN: the complete 2026 guide — the pillar overview
- ONJN Class 1 (B2C) authorisation in detail — where compliance fits in the application
- Substance and inspection regime for ONJN licensees — what inspectors check across the compliance dimensions
- Romania's iGaming tax stack: the 27% revenue tax — tax compliance as part of the operational picture
- Game certification: RNG testing and accredited labs — technical compliance dimension