In fact, the State Tax Service’s order, which came into force on 27 June, was the logical conclusion of previous actions taken by state authorities. It has nothing to do with the dispute between the owners.
The State Tax Service’s decision to freeze accounts is based directly on the Order of the Director of the SIB, published in the ‘MO’ on 19 June. According to this order, Topaz was included in the list of legal entities and individuals for whom there is evidence and documented information that they are under the control of a restricted entity – JSC United Engine Corporation (Russia).
This refers to international restrictive measures imposed by the UN Security Council, the EU and other international organisations. They are also imposed through unilateral decisions by the Republic of Moldova or other states in order to maintain international peace and security, prevent and combat terrorism, ensure respect for fundamental human rights and freedoms, develop and strengthen democracy and the rule of law, and for other purposes, in accordance with the objectives of the international community and international law. This is how the concept is defined in accordance with the Law ‘On the Application of International Restrictive Measures’.
Such restrictions were in place in Moldova before. However, the Order of the Director of the SIS dated 10 June 2025 supplemented the similar Order of the SIS No. 80 dated 16 December 2024, in the title of which, instead of one subject of restrictions – Ilan Shor – the definition of ‘subjects of restrictions’ appeared.
At the same time, the subject of the restrictions itself – JSC ‘ODK’, which officially owns 97.72% of the shares of JSC Topaz, was recognised as such by the Interdepartmental Supervisory Board (Decision No. 19 of 5 March 2025) — a collegial body headed by Prime Minister Dorin Recean.
The SIB then identifies lists of persons for whom there is evidence and documented information that they are under the control of the subject of restrictions.
All this became a chain of decisions that resulted in the GNS Order to block the accounts and assets of Topaz JSC. This means the mandatory application of the following measures:
– freezing of funds and economic resources belonging to, owned, possessed or controlled by Topaz JSC;
– prohibition on providing funds and economic resources to restricted entities, as well as on using funds and economic resources in their interests.
Many government agencies responsible for enforcing restrictive measures will be involved in implementing these measures.
In particular, all verification measures will be applied to prevent attempts to circumvent international restrictive measures.
The Real Estate Cadastre, the Public Services Agency, the Central Securities Depository, the National Financial Market Commission and other entities with the right to register/dispose of property and rights, including shares in the authorised capital of legal entities, will not register acts that may facilitate the transfer of assets to entities subject to restrictions.
