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Used as a “money mule”? Frozen bank account & a suspicion of money-laundering — what Romanian law actually says and what you can do

The article explains how “easy money” schemes translate into money-laundering red flags for banks and prosecutors and why your account may suddenly be frozen. It details the difference between preventive AML holds and criminal seizure, how Romanian law defines money-laundering and which options you have to challenge measures, unblock funds and reduce criminal liability.

Short version (so you know where you stand):

  • In Romania, money laundering is a crime defined by Law no. 129/2019. It requires that the person knew the funds came from crime (direct or “accepting the risk”). Penalties are serious (typically prison from 3 to 10 years). (Portal Legislativ)
  • Banks and other “obliged entities” must send suspicious transaction reports (STRs) exclusively to the Financial Intelligence Unit (ONPCSB). They also have strict know-your-customer (KYC) duties under BNR Regulation no. 2/2019. Expect document requests about source of funds and source of wealth. (Sintact)
  • ONPCSB can order the suspension of a transaction for up to 48 hours; a prosecutor at the PICCJ may extend this by up to 72 hours. Longer-term blocking of an account usually comes from precautionary seizure in criminal proceedings, which you can contest. (Secretariat General al Guvernului)
  • If your account was blocked under AML/KYC (not a court/prosecutor seizure), you first answer the bank’s info requests; if disagreement persists, you can try CSALB (banking ADR) to resolve the dispute without going to court. (CSALB)
  • “Money mule” recruiting is real (often targeting students via “easy money” offers). If you suspect you were used, stop transfers, notify your bank, and consider a complaint. (Europol)

1) What “money laundering” means in Romania (and where “money mule” fits)

Romanian law criminalises the following, if you know the money comes from crime:
a) changing or transferring assets to conceal their illicit origin or to help the perpetrator;
b) concealing or disguising the nature, origin, location, disposition, movement, ownership or rights over assets;
c) acquiring, holding or using assets that you know come from crime.
Standard penalty: 3–10 years’ imprisonment; attempt is also punishable. (Various aggravating forms may apply.) (Portal Legislativ)

A “money mule” is typically someone who receives funds and passes them on (minus a commission) for others. Europol and EU banking bodies flag it as a key laundering method, often recruiting young people with “work from home / quick cash” ads. If you knowingly play such a role, it maps onto the behaviours in Law 129/2019 above. (Europol)

Important nuance: Public awareness campaigns sometimes say “being a mule is illegal even if you don’t know.” Under Romanian criminal law, the offense requires knowledge (“cunoscând”)—but prosecutors can infer that from red flags (unexplained third-party funds, cash-out/crypto hops, commissions for forwarding, etc.). Even if criminal liability doesn’t stick, banks can still terminate relationships for AML risk. (Portal Legislativ)

2) Why your bank may have frozen the account

There are three common legal bases, and it matters which applies:

A) ONPCSB administrative suspension (very short term)
When a bank files an STR, ONPCSB may order the suspension of the transaction for up to 48 hours. Before this expires, ONPCSB can ask the Prosecutor’s Office at the High Court (PICCJ) to extend that by up to 72 hours. After that, the suspension lapses unless prosecutors act (e.g., seize). (Secretariat General al Guvernului)

B) AML/KYC-based internal restrictions by the bank (risk control)
Under BNR Regulation no. 2/2019 and Law 129/2019, banks must apply risk-based KYC, ask for source-of-funds/wealth evidence, and may refuse or delay transactions that pose AML risk until due diligence is completed. Practically, this can feel like a “freeze,” though it’s a compliance hold rather than a judicial seizure. (Portal Legislativ)

C) Precautionary seizure in a criminal case (medium to long term)
The prosecutor or the court can seize assets/indisponibilize accounts as a precautionary measure in criminal proceedings. If that’s why your funds are blocked, you’ll usually see a reference to a prosecutor’s order or court order and a file number. This is contestable (see below). (O.N.P.C.S.B.)

Tip-off rules: AML law requires that reports are filed exclusively to the FIU; EU AML rules also prohibit “tipping-off” the customer about STRs. Don’t be surprised if the bank cannot tell you whether it filed an STR. (Sintact)

3) How to respond if you think you were used as a mule

Step 1 — Stop, document, notify.
Cease any transfers or withdrawals that could further the scheme. Write down exact who/what/when (messages, ads, phone numbers, wallet addresses, IBANs) and notify your bank that you suspect fraud/muling. Europol recommends notifying your payment provider and relevant authorities immediately. (Europol)

Step 2 — Cooperate with KYC/AML checks.
Be ready to provide source-of-funds documents (contracts, invoices, loan agreements, payslips, proof of sales) and explain the transaction logic. Under BNR Reg. 2/2019, banks must verify customers proportionally to risk; solid documentation often shortens holds. (Portal Legislativ)

Step 3 — If there’s a criminal seizure, use the proper remedy.
Where a prosecutor ordered seizure, file a contestație within 3 days of communication (or within 48 hours for court-ordered measures during trial), to the competent judge (judecătorul de drepturi și libertăți / instanța care judecă). The contestation is not suspensive, but it’s the formal way to test legality and proportionality. (Sintact)

Step 4 — If you disagree with a bank’s AML hold/closure (no seizure), try ADR.
If dialogue stalls, consumers can use CSALB (Centrul de Soluționare Alternativă a Litigiilor Bancare). It’s free for consumers, voluntary for banks, and designed to settle bank-client disputes quickly (conciliation or arbitration). (CSALB)

4) Red flags prosecutors (and banks) look at in mule scenarios

  • Easy money for “receiving and forwarding” funds, often via social media or messaging apps. (Europol)
  • Third-party money with no contractual relationship (you don’t know the sender/buyer). (Europol)
  • Requests to withdraw cash, buy crypto/e-vouchers, or forward funds abroad fast. (Europol)
  • Narrative that discourages questions: “It’s a company policy”, “we’re blocked in X country”, “just help as an intermediary.” (Europol)

Why they matter legally: Even if you claim you didn’t know, these are the kinds of indicators from which knowledge or at least accepting the obvious risk can be inferred. Romanian law’s wording—“cunoscând că bunurile provin din săvârșirea de infracțiuni”—puts the evidentiary spotlight on these circumstances. (Portal Legislativ)

5) Documentation that actually helps

  • Chronology of messages and transfers (screenshots + CSV/extracts).
  • Contracts/invoices explaining the lawful origin of each inflow.
  • Proof of product/service (delivery, acceptance, identity of counterparties).
  • Bank transfer memos (avoid vague notes like “loan” when there is none).
  • Source-of-wealth basics: where your money generally comes from (job, business, sale), supported by payslips, tax returns, sales contracts.

This aligns with banks’ risk-based KYC duties under BNR Reg. 2/2019 and the “obligations to report” framework in Law 129/2019. (Portal Legislativ)

6) Contesting a criminal seizure: what to argue

When you file a contestație (art. 250/250¹ CPP), typical lines of argument are:

  • Lack of reasonable suspicion that the funds are linked to crime;
  • Proportionality (blocking the entire balance vs. only the suspicious tranche);
  • Necessity (less intrusive measures could suffice);
  • Traceability (legitimate source shown via documents; bank statements match).

Deadlines are short: 3 days from communication (prosecutor-ordered) or 48 hours (court-ordered during trial). Rulings are generally prompt and not suspensive. (Sintact)

7) If the bank relationship is terminated

Banks may decide to exit a client relationship for AML risk even without a criminal charge. While AML laws require confidentiality around STRs (and EU law bans “tipping-off”), you can:

  1. Ask for the bank’s position (it may be limited);
  2. Submit a formal complaint and, if needed, apply to CSALB;
  3. Where a legal right is at stake (wages/pensions), negotiate a controlled access mechanism (e.g., allowing incoming payments and specific outward transfers). (EUR-Lex)

8) Practical playbook (do this, in order)

  1. Freeze your own activity: stop forwarding money; block the recruiters; keep all evidence. Europol advises immediate notice to your bank/payment provider. (Europol)
  2. Call the bank’s AML/KYC desk: ask precisely what documents they need (SOF/SOW, invoices, contracts) and send them fast. This is often the shortest path to unblocking. (Portal Legislativ)
  3. Check which “freeze” you have: FIU suspension (short, administrative), AML hold (compliance), or criminal seizure. The last one will cite a file/order—then file contestație in time. (Secretariat General al Guvernului)
  4. Consider a criminal complaint if you were duped (fraud, cybercrime). The more proactive and transparent you are, the better your position when “knowledge” is assessed. (Europol)
  5. If the bank won’t budge and there’s no seizure, file at CSALB (free for consumers) for fast ADR with the bank. (CSALB)

9) FAQs we hear from clients

Q1: Can the bank keep my money forever without a court order?
No. An FIU suspension lasts at most 48h + a possible 72h extension by the prosecutor. Longer indivisibilities usually come from criminal seizure, which is contestable. AML/KYC “holds” shouldn’t be indefinite; if they persist with no legal basis, use the complaint route and CSALB. (Secretariat General al Guvernului)

Q2: If I truly didn’t know, am I safe?
Criminally, knowledge is required; but prosecutors can infer it from facts. Even absent charges, the banking relationship may be ended for risk reasons under BNR’s risk-based rules. (Portal Legislativ)

Q3: Why won’t the bank tell me if it filed a report?
EU AML rules restrict tipping-off; Romanian law channels reports exclusively to the FIU. Staff who disclose could violate AML law. (EUR-Lex)

Q4: Who can help me settle a dispute with the bank?
For consumers: CSALB (Alternative Dispute Resolution centre for banking) — conciliations/arbitrations, free for you. (CSALB)

10) Why students and gig-workers get targeted — and how to protect yourself

Campaigns across Europe show criminals systematically recruit people aged 16–24 through fake jobs and “easy cash” schemes. If you see offers to “use your account for a commission”, assume it’s laundering. If it sounds too good to be true, it is. Report and walk away. (Europol)

11) What we do for clients in these cases

  • Rapid triage of the freeze type (FIU suspension vs. AML hold vs. criminal seizure).
  • Document pack for KYC: SOF/SOW assembly, narrative alignment with statements.
  • Contestations (art. 250/250¹ CPP) against seizures; proportionality/traceability arguments.
  • Dialogue/ADR with the bank (CSALB where suitable). (Sintact)

12) Sources you can check yourself (key legal hooks)

  • Money laundering offense (Art. 49) — Law no. 129/2019. (Portal Legislativ)
  • STRs & cash-transaction reporting; FIU suspension 48h; reporting exclusively to FIU — Law no. 129/2019 (esp. Arts. 6–9). (Sintact)
  • 72-hour extension by prosecutor — Law 129/2019 (practice summaries / consolidated texts). (Integritate)
  • KYC duties for banks — BNR Regulation no. 2/2019. (Portal Legislativ)
  • Contesting precautionary seizures — CPP Arts. 250 / 250¹. (Sintact)
  • ADR with banks (CSALB) — official site & FAQs. (CSALB)
  • Money mule awareness & what to do — Europol guide. (Europol)

Original Romanian version of this topic on our site: Folosit ca „cărauş de bani”: cont blocat & suspiciune de spălare a banilor . (Sintact)

If you want, I can package this as a clean Word file with footnoted references, ready for publishing on the English blog.