Moldova’s Central Bank: Who Will Control the Financial Regulator?

Anka Dragu, LP collage

Commentary by InfoMarket

In principle, this is correct. The central bank should be independent. In fact, it already is, in accordance with the law currently in force. And we shouldn’t confuse criticism with interference. Criticism of the NBM is not uncommon, and this is natural, since its decisions affect not only the institutions under its jurisdiction but also the country’s economic activity, including that of the state.

But there is another side to this story. The more independence a state institution gains, the more pressing another question becomes: Who oversees the institution itself?

Greater Powers Mean Greater Need for Oversight

This is especially true given that the National Bank has grown significantly over the past few years – not so much in size as in authority. As of July 1, 2023, it was granted oversight of insurance, non-bank credit institutions, and loan and savings associations. Add to this banks, payment systems, and payment organizations—and you end up with a fairly large portion of the financial market.

And the National Bank is actively engaged in regulating this market. As InfoMarket has previously reported, the NBM’s sanctions policy has become noticeably stricter in recent years. Whereas fines used to be measured in tens or hundreds of thousands of lei, the amounts now easily reach millions.

In March 2026, FinComBank was fined 7.7 million lei, with an additional 2.7 million lei in fines imposed on three responsible individuals. At the end of last year, Energbank was fined 3.1 million lei. Since 2024, six non-bank credit institutions have received fines totaling approximately 6.3 million lei. Among them: Prima Finantare was fined 3 million lei, Paynet Services received two fines totaling over 3.2 million lei over the course of several months. There is also information on the market about another large fine of 2 million lei imposed this summer, which the NBM has not yet reported.

The National Bank explains that it takes into account the severity of the violation, its duration, consequences, and other circumstances. Representatives of some regulated industries point to something else: the predictability of sanctions and the extent to which the regulator applies requirements uniformly to different market participants and justifies the amount of the fines imposed.

In fact, this is where InfoMarket’s previous commentary on the NBM’s new policy began. One caveat is in order here. The National Bank does not keep the fines for itself. The money goes to the state budget. In other words, the simplistic view that “the NBM fines businesses and lives off those fines” doesn’t hold up.

But the mechanism itself is interesting. The National Bank sets the requirements. It also checks to see how they are being met. It determines whether a violation has occurred. It also imposes the penalty. Initially, any challenge to this decision must be made within the NBM system. Only then can a case be taken to court.

Perhaps this is precisely why the bank liquidation system is currently being reformed. Under the current model, the NBM supervises a bank until its license is revoked, and then continues to play a key role during the liquidation process. The explanatory note to the new bill explicitly states that this structure creates a risk of conflicts of interest and litigation. They want to transfer some of these functions to the courts.

This makes sense. Even if the regulator is independent and professional, that does not mean it should simultaneously serve as the supervisor, prosecutor, judge, and participant in the subsequent proceedings.

Who Determines the National Bank’s Own Expenses?

Now let’s return to the National Bank itself. The NBM is often perceived as just another government agency. But financially, it is not a ministry at all. The National Bank does not receive annual funding for salaries from the state budget. It finances its operations from its own revenues—primarily from managing foreign exchange reserves and other central bank operations.

The amounts involved are substantial. In 2025, interest income on foreign exchange reserves totaled 3.1 billion lei. After accounting for all results, the NBM’s distributable profit reached 1.82 billion lei. The National Bank allocated half of this—910.4 million lei—to its capital and transferred another 910.4 million lei to the state budget, in accordance with the requirements of current legislation.

But this is not a typical commercial company. The NBM’s capital is owned by the state, and its foreign exchange reserves exist not because the National Bank came up with a successful business venture, but because it is the country’s central bank. Financial independence is necessary precisely so that the government cannot say tomorrow: “We’ll cut your budget if you don’t lower the interest rate.” It’s hard to argue with that, either.

The only question remaining is who determines how much the National Bank can spend on its own operations. In 2025, the NBM’s budget for administrative expenses was 657.3 million lei. In fact, less was spent—592.5 million lei. The approved budget allocated 406.1 million lei for personnel, with insurance and other mandatory expenses accounted for separately.

Salaries and the Price of Internal Independence

And this is where it gets really interesting. According to published declarations, approximately 7% of the National Bank’s employees (42 staff members) have salary income exceeding 1 million lei per year. And this is by no means limited to the governor (230,000 lei per month) and the deputy governors (170,000–220,000 lei per month). Even some department heads receive annual salaries in the millions. The lists have been published; we won’t repeat them here.

The NBM explains the high pay levels by the need to compete with the commercial financial sector and attract qualified specialists. This is probably true for some positions. The central bank needs specialists in reserves, banking risks, monetary policy, payment systems, and IT security. Talented people in these fields don’t come cheap on the market.

But this raises a simple question: where does the need to compete for unique specialists end, and where does a simply very well-paid administrative system begin? For example, is the salary of an advisor or the head of the NBM president’s office also a matter of competing with the international banking market?

And who determines this? Largely, the NBM’s own Supervisory Board. By approving the expenditure side of the budget—which includes salaries in the millions for the institution’s employees—it thereby reduces the NBM’s net profit, while simultaneously reducing budget revenues, since half of the profit is required by law to go to the budget.

Who Oversees the Oversight Body?

The Council approves the National Bank’s operating budget and investments, oversees the internal governance system, and participates in determining the payroll fund and executive compensation. It consists of seven members. Four of them are not currently NBM employees—they are external members of the Board. And they, too, receive quite substantial compensation.

Natalia Gavrilita, a former prime minister and finance minister, became a member of the Supervisory Board in the summer of 2023. In 2024, her income from the NBM amounted to about 1.22 million lei—approximately 100,000 lei per month. Another external member of the Council, Vitalie Lemne, received roughly the same amount. In other words, external oversight of the National Bank is a well-paid job.

If an external member of the Board is paid more than one million lei per year, and there were 14 Board meetings in 2025, it would be helpful to understand not only the number of meetings they attended but also the specific results of their work. For example, how do they monitor the NBM’s expenditures, especially in light of recent events?

The very composition of the National Bank’s Supervisory Board raises questions for many, and these have been voiced. The Board is gradually filling up with quite a few names familiar from the government. Natalia Gavrilita joined the Board a few months after stepping down as prime minister. In July 2025, Parliament appointed Dumitru Alaiba, the former Deputy Prime Minister and Minister of Economic Development and Digitalization, as a member of the Council.

Formally speaking, neither has much professional experience in these areas. Gavrilița served as Minister of Finance and worked in international financial institutions. Alaibais an economist who headed the parliamentary committee on the economy, budget, and finance and subsequently led the government’s economic bloc.

Still, this is an interesting precedent. A person leaves one of the highest government posts, and a few months later receives a seven-year term at an independent state institution with a salary in the millions.

When Regulators Go to Court Against Their Boss

There is another curious episode in this story. In 2026, two external members of the NBM Supervisory Board – Ion Lapteacru and Vitalie Lemne – sued the National Bank and Governor Anca Dragu for her unilateral decision that all Council meetings must be held exclusively with members physically present. They believe this decision should have been made collectively. On the other hand, if the issue of in-person attendance arises, does that mean online attendance was also practiced? You have to admit that for over 100,000 lei a month (according to the published declarations of some Council members), it would have been possible to show up at the National Bank once or twice a month.

A precedent has been set: National Bank auditors are suing the head of the National Bank, who simultaneously chairs the Council where they are supposed to exercise this oversight. The structure of the NBM’s governance is becoming increasingly complex, and it is growing ever more difficult for outsiders to understand who oversees whom.

How the NBM Is Governed Today

And here’s the most interesting part! Compare for yourself the nominal compositions of the National Bank’s governing bodies.

The NBM Executive Committee – 5 members:

– Anca Dragu – NBM President, Chair of the Executive Committee;
– Petru Rotaru – First Deputy Governor, Vice Chair of the Executive Committee;
– Tatiana Ivanicichina – Vice President;
– Constantin Șchendra – Vice President;
– Mihnea Constantinescu – Vice President.

The NBM Supervisory Board consists of 7 members:

– Anca Dragu – Chair;
– Petru Rotaru – Vice Chair;
– Tatiana Ivanicichina;
– Natalia Gavrilița;
– Vitalie Lemne;
– Ion Lapteacru;
– Dumitru Alaiba.

Of these, the first three are employees; the remaining four are not employees of the NBM.

The NBM Audit Committee consists of three members:

– Vitalie Lemne – Chair;
– Natalia Gavrilita – member;
– Ion Laptiacru – member.

These seven individuals currently comprise the entire top-level management and oversight structure of the National Bank. Moreover, three of the four external members of the Supervisory Board also serve on the Audit Committee, which oversees the NBM’s internal audit and monitors the activities of the external auditor. Four of the seven members of the Council (at least formally) are independent.

There is a proposal to replace the external members with NBM staff

But that’s not all. There is a proposal to change this structure. A bill has been introduced in Parliament proposing to replace the four external members of the Supervisory Board with employees of the National Bank itself. It is argued that this would eliminate the need to pay monthly compensation to the external members. The author of the initiative explains this by stating that they could use their position as a tool to influence the National Bank. (“could be used as a tool to influence the institution”).

This is a dubious claim, to say the least. If the main problem is the high cost of compensating the four external members of the Supervisory Board, then the amount of their compensation can be discussed. If the external members are not performing adequately, more detailed reporting on their activities can be required. If the right people haven’t been selected, the appointment procedure can be changed. Furthermore, as soon as an independent external member of the Council is elected and appointed, they become a public official and act in the interests of their office. Of course, they must oversee the National Bank’s work—that’s the whole point!

And what kind of savings can we really be talking about if 42 millionaires at the NBM receive salaries higher than those of the members of the Supervisory Board?! Or perhaps the issue is that two Council members have filed a lawsuit against the NBM and Anca Dragu? In reality, the situation is much worse.

If the four external members of the Council are replaced by National Bank employees, there will be no independent oversight. As a member of the Board, a National Bank employee has a full vote alongside the chair—the NBM president—during Board meetings, but at all other times, he or she is the president’s subordinate. So, will the National Bank end up overseeing itself even more effectively? Remember where that led?

Why were external members introduced after the banking crisis?

External members were introduced to the National Bank’s Supervisory Board after the banking crisis, following the theft of a billion. On March 24, 2015, following an investigation into the situation at Banca de Economii, Banca Socială, and Unibank, Parliament instructed the government, in conjunction with the NBM, to draft legislative amendments to strengthen the NBM’s accountability “by establishing a Supervisory Board.” The Supervisory Board consists of seven people: the governor, the first deputy governor, one deputy governor, and “four members who are not employees of the National Bank.” The relevant law took effect in August 2015, but external members of the council did not join until July 2016.

Now, under some dubious pretext, there is a proposal to remove the external, independent members of the Council. It’s not hard to guess why.

And here we return once again to the issue of independence. The National Bank must be independent of the government. There is no doubt about that. But an employee’s salary of 1–2 million lei per year is not monetary policy. An expenditure budget of nearly 600 million lei is not monetary policy either. The compensation for members of the Supervisory Board is not the exchange rate. And a fine of several million lei imposed on a private company is not the base rate either.

All of this can certainly be discussed by the public, parliament, the business community, and journalists without any attempt to “put pressure on the independent National Bank.” But first and foremost, oversight of the NBM’s activities should be carried out by the Supervisory Board; its members’ authority is more than sufficient to prevent the current mess. And independent members must be included on the Board as a matter of course.

It would be all the more strange for the National Bank to demand absolute transparency, detailed explanations of operations, and compliance with every procedure from commercial banks, insurers, NGOs, and payment companies to provide absolute transparency, detailed explanations of their operations, and compliance with every procedure, while regarding such demands as interference with its own independence when applied to itself.

The National Bank has become much stronger in recent years. It has taken on supervision of more markets. It has begun to impose more severe sanctions. Now it wants even more robust legal protection.

But then, along with independence, oversight must also develop. Otherwise, sooner or later we will end up in a rather strange situation: The National Bank itself determines a significant portion of its own expenditures, oversees the financial market, fines its participants, and the National Bank itself will be “overseeing” by people from within the National Bank. The National Bank must be independent, but the proposed absolute independence will lack adequate oversight.

What International Practice Recommends

International practice and the recommendations of leading financial institutions, such as the International Monetary Fund and the World Bank, are based on the principle that central bank independence must be accompanied by an effective system of accountability, a separation of functions, and mechanisms for independent oversight. One common model is the separation of executive management and oversight.

The IMF views a majority of non-executive (external) members on central bank supervisory boards as a key element of such a system. According to the Fund, most central banks with separate oversight bodies have a majority of non-executive members; the IMF explicitly notes that such members play a critical role in establishing a system of checks and balances and ensuring oversight of executive management.

The current model of external oversight of the NBM did not arise by chance. As early as the IMF’s 2010 assessment, the need for independent oversight of the central bank was highlighted, and the IMF recommended amending the law on the NBM to that end. By 2015, the law had been amended to reflect these recommendations: it established a Supervisory Board and an independent Audit Committee, which at that time had yet to be formed in practice. And in 2016, the actual establishment of these bodies became one of the preconditions for a new IMF program.

Moldova’s previous program with the Fund had concluded. In May 2026, the authorities and IMF experts agreed on a new 36-month program at the expert level; however, the agreement still needs to be approved by the IMF Executive Board.

Independence Without Accountability

As a result, the external framework for oversight of one of the country’s strongest economic institutions is gradually narrowing at the very moment when the NBM’s own powers are expanding. The central bank’s independence from political interference is essential. But when a financially autonomous regulator with broad powers begins to exercise significant self-regulation, the issue is no longer merely one of independence. The very balance between authority and accountability is shifting: the less external oversight there is, the more the system must trust that the institution being regulated is capable of effectively regulating itself.

But if an independent National Bank begins to exercise significant self-regulation, this is no longer just a matter of independence. It represents a shift in the very balance of power and accountability within the state and the creation of a powerful and financially secure “state within a state.”