Decision on the Results of the Unannounced Inspection of Currency Exchange Units

REPUBLIC OF MOLDOVA NATIONAL FINANCIAL MARKET COMMISSION 1 DECISION 11 November 2025 No. 54/2 On the results of the unannounced inspection carried out within certain currency exchange units

1. In exercising the powers provided by the mandate for the protection of the rights of financial service consumers and in the context of emerging indicators of possible non-compliance in the activities of certain currency exchange units, the inspection team of the National Financial Market Commission (CNFMC) carried out an unannounced inspection (inspection), ordered by CNFMC Decision No. 45/1 dated 16.09.2025 on conducting the inspection within certain currency exchange units (Decision No. 45/1/2025), within 48 entities (participants), as follows:

1.1. 20 currency exchange offices: Branch No. 3 of C.S.V. “EURUS TRADE” S.R.L.; Currency exchange unit of C.S.V. “BENEFIT EXCHANGE” S.R.L.; Branch No. 6 of C.S.V. “VECTOR-AP” S.R.L.; Branch No. 5 of C.S.V. “ARMETIS-GRUP” S.R.L.; Branch No. 2 of C.S.V. “OANȚA-SCHIMB” S.R.L.; Branch No. 1 of C.S.V. “MACNOTIS” S.R.L.; Branch No. 2 of C.S.V. “DEGHEST” S.R.L.; Branch No. 3 of C.S.V. “MARAL SCHIMB” S.R.L.; Branch No. 3 of C.S.V. “SERGADR” S.R.L.; Sadoveanu Branch of C.S.V. “CITY EXCHANGE” S.R.L.; Branch No. 1 of C.S.V. “EXCLUSIV SCHIMB” S.R.L.; Branch No. 1 of C.S.V. “JOBENUL MAGIC” S.R.L.; Headquarters of C.S.V. “ORION SCHIMB” S.R.L.; Branch No. 17 of C.S.V. “BLAGO BLG” S.R.L.; Branch No. 1 of C.S.V. “GRAFITIS” S.R.L.; Branch No. 2 of C.S.V. “AVADA INVEST” S.R.L.; Branch No. 3 of C.S.V. “VESBAN” S.R.L.; Fălești Branch of C.S.V. “TRADE-NAȚIONAL” S.R.L.; Branch No. 2 of C.S.V. “EUDOLIR” S.R.L. and Headquarters of C.S.V. “TRIFAUX” S.R.L;

1.2. 27 currency exchange offices of licensed banks: Agency No. 37/01 “Tudor Vladimirescu” of “OTP Bank” S.A.; Agency No. 24/01 of Branch No. 24 “Bogdan Voievod” of “OTP Bank” S.A.; Hâncești Branch No. 17 of “OTP Bank” S.A.; Agency No. 7 of “Miron Costin” Branch of B.C. “MAIB” S.A.; Currency exchange unit of Hâncești Branch of B.C. “MAIB” S.A.; Agency No. 1 of Ungheni Branch of B.C. “MAIB” S.A.; Agency No. 5 of Branch No. 9 of B.C. “EXIMBANK” S.A.; Agency No. 11 of Branch No. 19 of B.C. “EXIMBANK” S.A.; Agency No. 7 of Branch No. 9 of B.C. “EXIMBANK” S.A.; Agency No. 5 of Branch No. 1 of B.C. “COMERȚBANK” S.A.; Agency No. 2 of Branch No. 1 of B.C. “COMERȚBANK” S.A.; Agency No. 1 of Branch No. 3 of B.C. “COMERȚBANK” S.A.; Agency No. 2 of Chișinău Branch No. 1 of B.C. “EuroCreditBank” S.A.; Agency No. 21 of Chișinău Branch No. 1 of B.C. “EuroCreditBank” S.A.; Agency No. 18 of Chișinău Branch No. 1 of B.C. “EuroCreditBank” S.A.; Agency No. 24 of Chișinău Branch No. 17 of B.C. “VICTORIABANK” S.A.; Agency No. 2 of Chișinău Branch No. 12 of B.C. “VICTORIABANK” S.A.; Agency No. 49 of Chișinău Branch No. 8 of B.C. “VICTORIABANK” S.A.; Agency No. 60 of “Testemițeanu” Branch of B.C. “Moldindconbank” S.A.; Agency No. 12 of Căușeni Branch of B.C. “Moldindconbank” S.A.; Agency No. 48 of Cimislia City Branch of B.C. “Moldindconbank” S.A.; Agency No. 1 of Branch No. 19 of B.C. “FinComBank” S.A.; Agency No. 1 of Branch No. 14 of B.C. “FinComBank” S.A.; Agency No. 2 of Branch No. 14 of B.C. “FinComBank” S.A.; Agency No. 9 of Bălți Branch of B.C. “ENERGBANK” S.A.; Agency No. 11 of Bălți Branch of B.C. “ENERGBANK” S.A. and Hâncești Branch of B.C. “ENERGBANK” S.A;

1.3. 1 currency exchange point of a hotel: “Radisson Blu Leogrand Hotel” of “LEOGRAND HOTEL” S.R.L.

It should also be noted that the inspection team found it impossible to conduct the inspection at Agency No. 11 of Branch No. 19 of B.C. “EXIMBANK” S.A., Agency No. 5 of Branch No. 9 of B.C. “EXIMBANK” S.A., Agency No. 7 of Branch No. 9 of B.C. “EXIMBANK” S.A., Agency No. 60 of “Testemițeanu” Branch of B.C. “Moldindconbank” S.A., Agency No. 24/01 of Branch No. 24 “Bogdan Voievod” of “OTP Bank” S.A. and the Currency exchange unit (B102024962) of C.S.V. “Benefit Exchange” S.R.L., because these participants no longer existed at the addresses indicated in the List of currency exchange units dated 01.09.2025.

2. The inspection aimed to verify the compliance of currency exchange units with the provisions of Article 13 of Law No. 105/2003 on consumer protection (Law No. 105/2003) regarding the information displayed on the advertising panel and/or on the screen of the currency exchange machine.

3. To carry out the field inspection, members of the inspection team traveled, during the period of 18 – 24 September 2025, to the headquarters of the participants and/or to the headquarters of their subdivisions in the cities of Fălești, Căușeni, Cimislia, as well as in the municipalities of Ungheni, Bălți, Hâncești and Chișinău.

4. In accordance with point 26 subpoint 1) and subpoint 4) of the Regulation on the administrative inspection procedure (CNFMC Decision No. 60/10/2023, hereinafter – Regulation No. 60/10/2023), on the day of the inspection, the participants were informed of Decision No. 45/1/2025 and were informed about their rights and obligations according to Regulation No. 60/10/2023.

5. During the field inspection, to attest the factual situation, the official camera of the CNFMC model NIKON D90 was used, as well as the internal provisions on establishing exchange rates applicable on the day of the inspection for cash exchange operations with individuals, presented by the participants at the request of the inspection team.

6. Consequently, it should be noted that the violations found were recorded in the Provisional Inspection Act dated 10.10.2025 on the results of the inspection carried out within certain currency exchange units regarding the verification of compliance with the provisions of Article 13 of Law No. 105/2003 on consumer protection, regarding the information displayed on the advertising panel and/or on the screen of the currency exchange machine (Provisional Inspection Act), which was sent to the participants via email on the same day. At the same time, the participants were granted a term, until 17.10.2025, to submit objections and comments on the Provisional Inspection Act.

7. In cases where entities subject to inspection had no violations found, they did not submit objections or comments. Regarding entities where violations were found, it should be noted that C.S.V. “TRADE-NATIONAL” S.R.L., Fălești Branch, did not formulate any objections or comments.

8. At the same time, objections and comments from participants regarding the findings exposed in the Provisional Inspection Act were received, as follows:

8.1. On 13.10.2025, C.S.V. “VESBAN” S.R.L., Branch No. 3, sent a reference to the email address schimb.valutar@cnpf.md with objections to the Provisional Inspection Act dated 10.10.2025, accompanied by confirming documents, including regarding the remediation of the detected discrepancy.

8.2. On 13.10.2025, C.S.V. “TRIFAUX” S.R.L., Headquarters, sent to the email address schimb.valutar@cnpf.md proof of remediation of the deficiency detected during the inspection, namely the photograph of the advertising panel and the Act of completion of works dated 29.09.2025.

8.3. On 15.10.2025, C.S.V. “EURUS TRADE” S.R.L., Branch No. 3, sent to the email address schimb.valutar@cnpf.md proof of remediation of the deficiency detected during the inspection, namely the photograph of the advertising panel and the Act of completion of works dated 25.09.2025.

8.4. On 16.10.2025, C.S.V. “MACNOTIS” S.R.L., Branch No. 1, sent to the email address schimb.valutar@cnpf.md the photograph of the advertising panel as proof of remediation of the deficiency detected during the inspection.

8.5. On 17.10.2025, “OTP Bank” S.A. sent to the email address schimb.valutar@cnpf.md letter No. Cl17-2418.2025 dated 17.10.2025 regarding objections to the Provisional Inspection Act dated 10.10.2025, accompanied by proof of remediation of the detected discrepancy.

8.6. On 17.10.2025, B.C. “VICTORIABANK” S.A. sent to the email address office@cnpf.md letter (registered at CNFMC with No. 7574) regarding objections to the Provisional Inspection Act dated 10.10.2025, accompanied by proof of remediation of the detected discrepancy.

9. Thus, on the basis of point 65 of Regulation No. 60/10/2023, the inspection team prepared the Table of Divergences, finalizing on 24.10.2025 the Act on the results of the inspection carried out within certain currency exchange units regarding the verification of compliance with the provisions of Article 13 of Law No. 105/2003 on consumer protection, regarding the information displayed on the advertising panel and/or on the screen of the currency exchange machine, according to the annex to this Decision (Act on the results of the inspection). Similarly, on the basis of Article 94 of the Administrative Code and point 68 of Regulation No. 60/10/2023, to ensure the right to be heard before issuing an unfavorable decision, the CNFMC initiated the hearing procedure for 7 (seven) participants, regarding whom deviations from legal requirements were found.

Thus, on 24.10.2025, the Act on the results of the inspection, accompanied by the Table of Divergences and the invitation to be heard, was sent to the participants, as follows:

9.1. C.S.V. “EURUS TRADE” S.R.L., Branch No. 3, by CNFMC letter No. 04-5/4239 dated 24.10.2025, was informed about the right to be heard on 28.10.2025, at 09:00, regarding the facts and circumstances found during the inspection. Subsequently, during the hearing, the administrator of C.S.V. “EURUS TRADE” S.R.L. supported the allegations in the reference, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 28.10.2025.

9.2. C.S.V. “TRIFAUX” S.R.L., Headquarters, by CNFMC letter No. 04-5/4241 dated 24.10.2025, was informed about the right to be heard on 28.10.2025, at 10:00, regarding the facts and circumstances found during the inspection. Subsequently, during the hearing, the administrator of C.S.V. “TRIFAUX” S.R.L. supported the allegations in the reference, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 28.10.2025.

9.3. C.S.V. “MACNOTIS” S.R.L., Branch No. 1, by CNFMC letter No. 04-5/4242 dated 24.10.2025, was informed about the right to be heard on 30.10.2025, at 09:00, regarding the facts and circumstances found during the inspection. Subsequently, during the hearing, the administrator of C.S.V. “MACNOTIS” S.R.L. supported the allegations in the reference, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 30.10.2025.

9.4. B.C. “VICTORIABANK” S.A., by CNFMC letter No. 04-5/4238 dated 24.10.2025, was informed about the right to be heard on 30.10.2025, at 10:00, regarding the facts and circumstances found during the inspection. Subsequently, during the hearing, the representative of B.C. “VICTORIABANK” S.A. supported the allegations in the reference, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 30.10.2025.

9.5. C.S.V. “TRADE-NAȚIONAL” S.R.L., Fălești Branch, by CNFMC letter No. 04-5/4243 dated 24.10.2025, was informed about the right to be heard on 30.10.2025, at 11:00, regarding the facts and circumstances found during the inspection. Subsequently, during the hearing, the administrator of C.S.V. “TRADE-NAȚIONAL” S.R.L. confirmed the remediation of the violations found, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 30.10.2025.

9.6. “OTP Bank” S.A., by CNFMC letter No. 04-5/4237 dated 24.10.2025, was informed about the right to be heard on 31.10.2025, at 10:00, regarding the facts and circumstances found during the inspection. Subsequently, during the hearing, the representative of “OTP Bank” S.A. supported the allegations in the reference, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 30.10.2025.

9.7. C.S.V. “VESBAN” S.R.L., Branch No. 3, by CNFMC letter No. 04-5/4244 dated 24.10.2025, was informed about the right to be heard on 31.10.2025, at 11:00, regarding the facts and circumstances found during the inspection. Subsequently, during the hearing, the administrator of C.S.V. “VESBAN” S.R.L. supported the allegations in the reference, a fact recorded in the Hearing Record of the participant in the administrative procedure dated 31.10.2025.

10. Thus, as a result of the inspection, the following were found:

10.1. On 18.09.2025, the inspection team went to C.S.V. “TRIFAUX” S.R.L., Headquarters, located in Ungheni city, Mihai Eminescu str., No. 67. On the spot, the currency exchange office and the advertising panel associated with it were identified. As a result of examining the materials accumulated on site, related to the advertising panel, it was found that for the buying and selling rates of foreign currencies, the separation of decimal signs from the whole number was done by a point.

However, it was noted that for GBP (British pound) currency, the buying and selling rates were displayed without any separation between the whole number and decimal signs, in the format “2235” for buying and “2243” for selling.

At the same time, at the counter of the respective currency exchange office, in Directive No. 525 dated 18.09.2025 on establishing exchange rates for 18.09.2025, starting from 09:00 (Directive No. 525 dated 18.09.2025), for GBP currency, the buying rate was “22.35”, and the selling rate was “22.43”.

According to Article 1 of Law No. 105/2003, professional diligence represents “the level of specialized competence and consideration that the trader can reasonably exercise towards consumers, in accordance with correct commercial practice and/or with the general principle of good faith in the field of activity of the trader;”.

In the same sense, Article 10 para. (1) of the Civil Code provides that “(1) Natural and legal persons participating in civil legal relations must exercise their rights and fulfill their obligations in good faith, in accordance with the law, the contract, public order and good morals. Good faith is presumed until proven otherwise.”.

Also, according to point 8 of the Regulation on the activity of currency exchange units (Decision of the Executive Committee of the National Bank of Moldova No. 335/2016, hereinafter – Regulation No. 335/2016), “8. On the advertising panel, the separation of decimal signs from the whole number is done by a distinct space or by comma or point. […]”.

Therefore, C.S.V. “TRIFAUX” S.R.L., Headquarters, did not respect the obligation of professional diligence, as on its advertising panel, the exchange rate for GBP currency was displayed without separation by point, comma or distinct space.

The established fact – display without separation of decimal signs from the whole number for the GBP exchange rate on the advertising panel – is likely to create confusion and affect the economic behavior of the average consumer.

Thus, the average consumer, in a situation of making a transaction decision, in the absence of clear delimitation, may incorrectly understand that for GBP currency, the exchange rate would be 2235 MDL for 1 GBP for buying and 2243 GBP for 1 GBP for selling, but not 22.35 MDL, and respectively, 22.43 MDL for 1 GBP, as established by Directive No. 525 dated 18.09.2025.

This confusion is reinforced by the fact that for all other foreign currencies on the advertising panel, the exchange rates are displayed with separation by a point between the whole number and decimals, with the exception only of GBP currency. Such an inconsistency in display can be perceived by the average consumer as a common practice, creating an appearance of normality and thus inducing them to incorrectly assess the real value of the rate. Under these circumstances, there is a risk that they may make a transaction decision based on a misinterpretation, being determined by an ambiguous display mode.

Therefore, it is found that the cumulative conditions provided by Article 13 para. (2) lit. a) and lit. b) of Law No. 105/2003 are met, because C.S.V. “TRIFAUX” S.R.L., Headquarters, did not respect the obligation of professional diligence, through the improper presentation of information regarding the exchange rate, and the display mode was of a nature to mislead the average consumer and essentially influence their economic decision.

In accordance with Article 13 para. (5) and para. (8) of Law No. 105/2003, “(5) Misleading commercial practices can be misleading actions or misleading omissions. (8) A commercial practice is considered to be a misleading omission if, in the context of the factual situation and taking into account all characteristics and circumstances, as well as the limits of space and time imposed by the communication means used to transmit the information, this practice omits essential information necessary for the average consumer, taking into account the context, to make an informed transaction decision and, therefore, determines or is likely to determine the average consumer to make a transaction decision that they would not have made otherwise.”.

In this case, C.S.V. “TRIFAUX” S.R.L., Headquarters, failed to separate the whole number from the decimal signs on the advertising panel associated with the exchange rate for GBP currency, a fact that constitutes a lack of essential information for the consumer. The absence of such a delimitation, which contradicts legal regulations and the display practice used for other foreign currencies, places the consumer in a situation of uncertainty and interpretability regarding the real value of the applied rate.

Under these conditions, the average consumer is exposed to the risk of making an incorrect transaction decision, based on a false perception of the rate, a perception created exclusively by the display mode practiced by the currency exchange office.

Therefore, the established actions are qualified as a misleading commercial practice, of the type misleading omission, likely to mislead the average consumer and essentially distort their economic behavior.

10.2. On 18.09.2025, the inspection team went to C.S.V. “TRADE-NAȚIONAL” S.R.L., Fălești Branch, located in Fălești city, Pieței str., No. 2/a. On the spot, the currency exchange office and 3 (three) advertising panels associated with it were identified: 2 panels located outside (on the street) and 1 (one) panel at the counter. As a result of examining the materials accumulated on site, the following were found:

10.2.1. Regarding the advertising panel located on the street (blue color), the exchange rate for BGN (Bulgarian lev) currency was displayed with “8.04” for buying and “11.4” for selling.

However, it was noted that at the counter of the respective currency exchange office, in the Directive on currency rates dated 18.09.2025 (Directive dated 18.09.2025), for BGN currency, the buying rate was “8.04”, and the selling rate was “11.45”.

According to Article 1 of Law No. 105/2003, professional diligence represents “the level of specialized competence and consideration that the trader can reasonably exercise towards consumers, in accordance with correct commercial practice and/or with the general principle of good faith in the field of activity of the trader;”.

In the same sense, Article 10 para. (1) of the Civil Code provides that “(1) Natural and legal persons participating in civil legal relations must exercise their rights and fulfill their obligations in good faith, in accordance with the law, the contract, public order and good morals. Good faith is presumed until proven otherwise.”.

Also, according to point 8 of Regulation No. 335/2016, “8.[…] The number of decimal signs associated with the buying rates of foreign currencies must be equal to the number of decimal signs associated with the selling rates of the respective foreign currencies. […]”.

Therefore, C.S.V. “TRADE-NAȚIONAL” S.R.L. did not respect the obligation of professional diligence, as the selling rate for BGN currency was displayed with a single decimal sign (“11.4”), while the buying rate for the same currency was displayed with two decimal signs (“8.04”).

The established fact – display of the BGN exchange rate with an unequal number of decimal signs for the buying and selling rates – is likely to create confusion and affect the economic behavior of the average consumer.

Thus, the average consumer, in a situation of making a transaction decision, may incorrectly interpret that the selling rate for 1 BGN is 11.40 MDL, but not 11.45 MDL, according to the official rate established in the Directive dated 18.09.2025.

Consequently, they might incorrectly consider that the transaction of buying BGN is more advantageous than it actually is. This discrepancy between the information displayed on the panel and the real applicable rate has the capacity to influence the consumer's economic decision, determining them to opt for carrying out the exchange operation at the respective currency exchange office, based on a false perception of the rate.

Therefore, it is found that the cumulative conditions provided by Article 13 para. (2) lit. a) and lit. b) of Law No. 105/2003 are met, because C.S.V. “TRADE-NAȚIONAL” S.R.L., Fălești Branch, did not respect the obligation of professional diligence, by displaying incorrect information regarding the exchange rate, which was of a nature to mislead the average consumer and essentially influence their economic decision.

In accordance with Article 13 para. (5) and para. (8) of Law No. 105/2003, “(5) Misleading commercial practices can be misleading actions or misleading omissions. (8) A commercial practice is considered to be a misleading omission if, in the context of the factual situation and taking into account all characteristics and circumstances, as well as the limits of space and time imposed by the communication means used to transmit the information, this practice omits essential information necessary for the average consumer, taking into account the context, to make an informed transaction decision and, therefore, determines or is likely to determine the average consumer to make a transaction decision that they would not have made otherwise.”.

In this case, C.S.V. “TRADE-NAȚIONAL” S.R.L. failed to respect the legal requirement regarding the indication of an equal number of decimal signs for BGN currency, in relation to the buying rate...