National Bank of Moldova publishes draft amendments to fit and proper requirements for bank management bodies and key function holders

The National Bank of Moldova has published a draft decision to amend its regulation on suitability requirements for members of banks’ management bodies, financial holding and mixed holding companies, managers of foreign bank branches, key function holders and bank liquidators. The draft would tighten and operationalise the “fit and proper” framework by expanding when suitability must be assessed or reassessed and by adding more granular criteria and supporting documentation requirements. Key changes include introducing definitions for “adequacy” and “chief financial officer”, requiring additional National Bank of Moldova approval where an already approved person is later assigned a new responsibility area that could expose the bank or branch to significant risks, and strengthening banks’ obligations to ensure ongoing compliance with suitability criteria. The draft broadens reassessment triggers, including significant changes to a bank’s business model, risk appetite, risk management strategy or group structure, and situations suggesting heightened money laundering or terrorist financing risk. It also adds further detail to reputation, honesty and integrity assessments, links suitability expectations to the bank governance framework under Regulation No. 322/2018, introduces annexes covering independent thinking and sufficient time commitment, and adds a template to evidence compliance with the requirement that at least one-third of bank council members be independent. The draft decision would enter into force one month after publication in the Official Monitor of the Republic of Moldova.