First major change to the global banking structure in over 40 years and what it means for Romanian banks
— by Cătălin Săpașu, Senior associate, ONV LAW —
1. What is SWIFT and why its strategic move to blockchain matters
The Society for Worldwide Interbank Financial Telecommunication (SWIFT) constitutes a critical component of the global financial infrastructure, utilized by more than 11,000 banking and financial institutions worldwide. Although SWIFT does not itself execute the transfer of funds, it facilitates the secure transmission of messages and instructions through which banks authorize debit and credit operations.
In practice, whenever a Romanian entity engages in cross-border financial transactions, whether by remitting payments to foreign counterparties or by receiving inbound investment, it is highly probable that such operations are facilitated through the SWIFT network. In late 2025, SWIFT announced its intention to integrate blockchain technology into its global infrastructure, thereby transitioning from a traditional financial messaging system to a shared digital ledger designed to record and validate financial transactions in real time.
This change is more than a mere technological update, it represents the first significant structural transformation of the global banking infrastructure in over four decades. Transactions that were historically reconciled and settled through multiple intermediaries may, in the near future, be executed in real time on a secure, transparent, and programmable platform. For financial institutions worldwide, including those operating within Romania, this evolution is expected to materially impact the operational, legal, and compliance frameworks governing cross-border payment activities.
2. Regulatory and compliance challenges for banks
A. Compliance will become more complex
While blockchain-based settlement mechanisms offer enhanced transparency, they also fundamentally alter the manner in which information is shared and the allocation of responsibility among participants.
Within a distributed ledger environment, multiple institutions may validate or store components of the same transaction. Consequently, Romanian banks will be required to re-evaluate their anti-money laundering (AML), know-your-customer (KYC), and regulatory reporting procedures to ensure continued compliance, even when transactional data is distributed across multiple international participants. National authorities, including the National Bank of Romania (BNR), are expected to demand clear and robust frameworks delineating reporting obligations, client data handling protocols, and the precise point at which a payment attains finality.
B. Redefining legal concepts
Today, a transaction attains “finality” when such status is conferred by applicable law and the regulations of the central bank.
Within a blockchain environment, however, the transfer of value occurs in real time, yet it remains uncertain whether that moment constitutes legal final settlement under Romanian or European Union law.
Consequently, financial institutions will need to revise their contractual frameworks, treasury operations, and accounting policies to establish with precision the point at which ownership is deemed to have transferred. Such clarity will be essential to mitigate the risk of disputes arising from operational errors or insolvency events.
C. Governance and data protection challenges
Participation in a global blockchain infrastructure will require Romanian banks to strengthen their governance, cybersecurity, and data protection frameworks. Although blockchain technology ensures traceability, it may present conflicts with privacy regulations such as the GDPR, given the inherent immutability of information recorded on a shared ledger. Accordingly, banks must implement systems that safeguard sensitive client data while simultaneously preserving the transparency required for regulatory compliance.
3. Romania’s banking sector: opportunities and challenges
Romanian banks have achieved notable progress in digitalization, with initiatives such as ReGIS and RoPay demonstrating their capacity to modernize payment systems. Nevertheless, in comparison with larger EU markets, local institutions remain cautious and legally conservative.
The integration of Romanian banks into a global blockchain infrastructure will necessitate the development of new operational and technological frameworks, as well as clear legal guidance and enhanced regulatory coordination. Without proactive preparation, Romanian financial institutions risk being left behind in both compliance adaptation and competitive positioning.
The benefits are considerable, including accelerated settlement processes, reduced liquidity costs, and enhanced global interoperability. However, in the absence of legal certainty, these advantages could be undermined by regulatory non-compliance or operational risks.
4. Key focus areas for bank management
Strategic awareness: recognize SWIFT’s blockchain transition as a long-term structural transformation rather than a mere technical project. The change will have implications across all bank functions, including compliance, treasury, IT, and legal operations.
Regulatory engagement: initiate early and proactive dialogue with the National Bank of Romania to clarify expectations regarding settlement finality, AML, and reporting obligations. Such engagement will help mitigate supervisory and regulatory risk.
Legal and compliance gap analysis: review current contracts, AML/KYC policies, and data governance procedures to determine to identify necessary adjustments for blockchain implementation.
Participation in early-stage pilot programs: evaluate the possibility of early involvement in pilot programs or test networks to acquire both technical and legal experience, and to assess operational impacts before full-scale adoption.
Governance and risk management: revise vendor management, cybersecurity protocols, and operational resilience frameworks to accommodate the specific requirements of distributed ledger environments, to risk management, and maintain regulatory compliance.
5. Considerations for Romanian Banks
SWIFT’s transition to blockchain introduces a new set of legal and operational considerations for financial institutions. Romanian banks should evaluate the alignment of their compliance, governance, and contractual frameworks with this evolving infrastructure.
Early assessment and alignment can help institutions manage regulatory obligations, reduce operational risks, and ensure continuity in cross-border payment processes. Delayed action may result in increased compliance exposure, higher integration costs, and operational uncertainty.
As the financial sector adopts increasingly digital infrastructures, targeted legal guidance will be essential to support compliant and efficient adoption of blockchain based solutions.