Moldova cleans up its judicial system, while Bulgaria is still looking for those responsible for destroying it

Tsvetomir Todorov, Georgi Shumanov, Bulgarian Institute for Legislative Initiatives, October 9, 2025

Intro

While in Bulgaria real judicial reform seems harder to achieve than ever, and justice is increasingly becoming a caricature, mired in political and criminal dependencies, in neighboring Moldova, a country that until recently was synonymous with corruption, real change is taking place. Dozens of courts have been closed. Hundreds of magistrates have left the system or are about to do so. The incumbent prosecutor general has been arrested and investigated. The Superior Council of Magistrates has been depoliticized and even opened up to non-lawyers.

Context

The recent parliamentary elections in the Republic of Moldova have drawn international attention to Chisinau. The reason is not only the war in neighboring Ukraine, but also Moldova’s remarkable process of breaking away from its image as a post-Soviet country ruled by oligarchs and criminal clans linked to the status quo in Moscow. Moldova is moving toward integration into the European Union with an enthusiasm not seen in years. The stakes are high, and Moldova’s recent parliamentary elections had all the elements of a successful political thriller: the arrest and extradition of a prominent oligarch; the banning of the main pro-Russian parties from participating in the vote the day before the election; a disproportionate number of polling stations in various diasporas; serious interference from local and foreign services; an opposition that refused to recognize the results.

Moldova is successful for the moment. The pro-European movement won the parliamentary vote, proving that at least somewhere on the Old Continent the European idea is alive; that the EU can still fascinate, despite the economic, ideological, and institutional crises it is going through. The election results also showed something else: it is becoming increasingly difficult for the Russian Federation to effectively impose its control over foreign territories that it has long considered traditional spheres of influence without resorting to arms.

The change for Moldova began about five years ago and was based on the fulfillment of a promise regarding judicial reform and the fight against corruption. It is precisely for this reason that Moldovans elected Maia Sandu as president – a career politician, a Harvard University graduate, and someone with professional experience at the World Bank headquarters in Washington. At around the same time, a protest movement emerged in Bulgaria, raising similar slogans – zero tolerance for corruption, judicial reform, and a review of previous administrations. But that is where the parallels between the reform processes in Bulgaria and Moldova end. While in Bulgaria the spark of change seems to have been extinguished, drowned in a swamp of petty political disputes, insurmountable dependencies, and blatant political stupidity, in Moldova the reforms continue today. The start of Russia’s war against Ukraine has only deepened and accelerated them. Frightened by the danger of the war spreading to their homes, Moldovan citizens have four times in the last five years given their support in elections to pro-European forces, repeatedly reaffirming their course of leaving Russia’s sphere of influence.

Of course, neighboring Romania, the other country in the region with long-standing interests in Moldova, has played an enormous role in changing the course of Moldova’s foreign policy. In addition to its clear support for the new government in Chisinau, Romania has managed to put Moldova’s future on the agenda of the EU and the UK. Bulgaria has never managed to achieve anything similar with regard to the Western Balkans, particularly North Macedonia.

The results of Moldova’s judicial reform became evident in the September elections, when the country’s Supreme Court confirmed the exclusion of two pro-Russian parties from the elections immediately before the vote. Previously, the Central Court of Appeal had excluded a third party, led by former president Adrian Candu, from the electoral process, based on intelligence reports of “possible subversive activities” by individuals subject to international sanctions. In this context, it should be recalled that in 2019, the current president of the country, Maia Sandu, was not allowed to become prime minister precisely because of a court decision.

The captured state

To understand how fundamental and even incredible what is happening in Moldova is, we must take into account what the former Soviet republic was like until recently and how corrupt the Moldovan courts were. Decades after the collapse of the USSR, the Republic of Moldova was a symbol of a failed state in Europe. Moldovan society, divided on every possible level – ethnic, linguistic, geographical, political, geopolitical, and even religious – had become the ideal breeding ground for massive, all-encompassing, post-Soviet-style corruption. Organized crime and oligarchic interests were interconnected with power structures at all levels, effectively running the country. It is no coincidence that Moldova was the first European country cited by the World Bank as an example of state capture in its 2004 reports. By comparison, Bulgaria received this “title” only in 2014.

Moldova proved that its reputation as the first captured state in Europe was no accident when, between 2010 and 2014, it became a launching pad for the largest money laundering scheme ever uncovered in history. Through the so-called “Russian Laundromat” scheme (also known as the “Russian Troika”), approximately €80 billion (the exact amount is impossible to estimate) entered the financial and economic circulation of the EU, the UK, and the US. This laundered Russian capital was then used to invest in real estate, luxury goods, and to buy political and media influence for the benefit of the Russian Federation and Russian citizens. The Russian money laundering operation in Moldova is simple and, at the same time, ingeniously effective. Russian companies enter into fictitious contracts with shell companies registered in offshore areas and then fail to fulfill their obligations. This causes their fictitious offshore partners to file claims for non-performance and damages. A key factor in the success of the fraud is the involvement of Moldovan courts, which, according to the terms of the contracts, are responsible for adjudicating the commercial disputes in question. As a result, dozens of corrupt Moldovan magistrates issue rulings requiring the “offending” Russian companies to pay billions of euros in penalties to their fictitious offshore counterparties. The money for the “penalties” related to unfulfilled contracts comes from Russia, passes through Moldovan banks, and then, at the request of offshore companies, is transferred to accounts opened at dozens of banks in the EU and the United Kingdom (which at that time was still part of the Union). After these transfers, the dirty money from Russia is legally injected into the Western economy (including Bulgaria, although the issue has never been the focus of our authorities), because the transactions are de jure the execution of a Moldovan court decision.

Moldova has seen a series of scandals related to massive strategic corruption. In 2014, over €1 billion was embezzled from three banks in the country. The scheme, behind which stand the names of two key local oligarchs, caused the state total damages equivalent to 12% of its gross domestic product for the same year. This case resembles the KTB bankruptcy in Bulgaria, not only because it occurred in the same year, but also because, as in Bulgaria, Moldovan law enforcement, control, and investigative authorities ignored the scheme, and the stolen capital was subsequently successfully reinvested in the political process. In Moldova, this turned one of those involved in the bank failures—the oligarch Vladimir Plahotniuc—into the country’s uncrowned king. Without ever having been prime minister or president, but only a member of parliament, Plahotniuc effectively controlled the country’s parliament, government, and judiciary for the next five years through a business empire in which his network of media outlets and loyal politicians and magistrates played a key role.

According to Gagauz journalist Mihail Sirkeli, a Bulgarian citizen, in an interview with the Ruse-based publication The Bridge of Friendship, between 2015 and 2019 Plahotniuc was effectively what Delyan Peevski is today for Bulgarian political and economic life. But that is where the similarities between Bulgaria and Moldova end, because in 2019 Plahotniuc, subject to sanctions from the US and the UK, was forced to leave Moldova as a result of the reforms that had begun. The oligarch was arrested in Greece in the summer of 2025 with six Romanian passports and, in September, on the eve of the presidential elections, was handed over to the Moldovan authorities, despite Moscow’s desire to extradite him to Russia.

More than any other small country in the region, Moldova is a hostage to its geography. Lacking access to the Black Sea, with a frozen conflict between the capital and the de facto separatist state of Transnistria, which is not recognized by anyone (except Moscow) and which also hosts a Russian army forgotten since the Cold War, Moldova seems destined to remain a gray area between the “Russian world” cherished by Moscow and Europe, and therefore a launching pad for Russian criminal activities and hybrid attacks in the region. It is no coincidence that a large proportion of luxury cars stolen in Bulgaria are taken, whole or in parts, to Transnistria, where they are recycled and prepared for the secondary market in the north and east of the Black Sea. Also significant for Moldova are the “investments” of Igor Ceaica, son of the former Prosecutor General of the Russian Federation, Yuri Ceaica (the latter known in Bulgaria from his official visit to Sofia in 2017, at the invitation of the then Chief Prosecutor, Sotir Tsatsarov), in “cryptocurrency mines” and “troll farms,” the latter actively flooding the public space with fake news throughout the region, including Bulgaria.

Reform

The first sign that real reform was beginning in Moldova was the arrest in the fall of 2021 of the then chief prosecutor, Alexandr Stoianoglo. A few days before his arrest, the parliament in Chișinău voted on amendments to the Law on the Prosecutor’s Office, according to which the chief prosecutor could be dismissed by a special commission that evaluated his performance if he received a negative evaluation of his work or was found guilty of a disciplinary violation. Stoianoglo was dismissed from office by President Maia Sandu, after which he was charged with five crimes. Although he was later acquitted, in 2023 he permanently ceased to be chief prosecutor, after which he entered politics and became Maia Sandu’s main opponent in the 2024 elections. Stoianoglo has been accused of having dubious ties to Russia because his party is financed by Israeli-born Moldovan oligarch Ilan Shor, one of two people guilty of embezzling €1 billion from Moldovan banks in 2014, who fled Moldovan justice to Moscow and obtained Russian citizenship.

The parallels with Bulgaria are again striking. In June 2023, a mechanism for investigating the chief prosecutor was adopted for the first time in the Bulgarian criminal procedure code. Complaints against the incumbent chief prosecutor Borislav Sarafov are multiplying (in the first six months of 2025 alone, there were 12 requests for investigation against him). In July 2023, Daniela Taleva, a judge at the Sofia Court, was selected by lottery to be an ad hoc prosecutor. In practice, however, she did not take up her post until six months later, after the Supreme Judicial Council created “internal and organizational” obstacles. Two years later, and after a series of doubts about Taleva’s dependencies, it appears that this mechanism in Bulgaria has been turned into another farce and parody of reform.

Judicial reform in Moldova would have been unthinkable without the country’s integration into the EU. On March 3, 2022, just one week after Russia’s invasion of Ukraine, Chisinau officially submitted its application for EU membership. On June 22, 2022, the country was granted candidate status, and on December 14, 2023, the European Council decided to open accession negotiations, something that seemed unimaginable just a few years earlier. As part of the process of harmonizing its legislation with EU law, Moldova is adopting key rules to strengthen the rule of law and the independence of the judiciary. In April 2022, constitutional amendments came into force that exclude political factors influencing the selection of members of the Superior Council of Magistracy of the Republic of Moldova (the equivalent of the Supreme Judicial Council in Bulgaria). The new rules exclude ex officio members such as the Minister of Justice, the Prosecutor General, and the President of the Supreme Court from the Council, stipulating that the Council will consist of 12 members. Six of these are professional members, i.e., judges elected by the General Assembly of Judges of the country. The other six do not have to be judges, do not have to be part of the executive, judicial or legislative branches, and do not have to have any political affiliation, with at least four of them having experience in the field of law. The members of the non-professional quota of the Council are elected by Parliament with a qualified majority of 3/5 of the total number of deputies.

In the same year, Law No. 26/2022 was adopted on certain measures relating to the selection of candidates for membership of the autonomous bodies of judges and prosecutors. This introduces the so-called prior verification or, more descriptively, a process of preliminary verification, prior to appointment, of the financial and ethical integrity of all candidates for the Superior Council of Magistracy (CSM) and the Superior Council of Prosecutors (CSP). This includes their lifestyle and expenses (as well as those of their relatives) over the past 15 years. The aim is to identify conflicts of interest, illegal enrichment, or links to corruption before a person is considered a potential candidate for such a high office. The integrity assessment is carried out by a special external commission composed of national and international members. Many of the candidates for the two councils of the Moldovan judiciary fail this assessment because of issues related to their property, discrepancies between their income and lifestyle, or simply because they did not submit their declarations on time. The Constitutional Court examined complaints against the law but confirmed its constitutionality.

The success of this preliminary assessment of integrity and professional qualities sparked a heated debate on extending it to all sitting magistrates, similar to the Albanian model. In this context, two laws were adopted – No. 65/2023 and No. 252/2023 – which initiated the effective verification of sitting magistrates. On this basis, a special verification commission was set up to carry out a single external assessment of the professional qualities, ethical and financial integrity of certain categories of judges and prosecutors who hold or have held key leadership positions. The law provides for real consequences: magistrates who fail the verification may be dismissed from office and prohibited from holding public office for a period of 5 to 7 years.

The commission consists of six members appointed by Parliament with a 3/5 majority. Three of them must be citizens of the Republic of Moldova, nominated by parliamentary parties (with guaranteed representation of the ruling and opposition parties), and three must be international experts. The members were appointed on June 15, 2023, and have an independent secretariat that provides organizational and technical support for their activities. The commission’s powers include collecting and verifying information from all admissible sources, accessing state information systems, requesting data from public and private institutions, including banks, hearing persons under investigation and witnesses, and preparing and approving reports on the results of investigations. Subsequently, the process of verifying magistrates is carried out in parallel by two structures: a commission for judges and one for prosecutors, which take over the work of the initial joint commission.

Of course, the process of evaluating magistrates faces serious resistance within the system. A telling example from practice is the case of prosecutor Vladimir Adam, a former member of the Anti-Corruption Prosecutor’s Office. In November 2024, the Verification Commission decided that he did not meet the ethical and financial integrity criteria set out in Law No. 65/2023. The decision was confirmed by the Superior Council of Magistrates in December 2024 and by the Supreme Court of Justice in May 2025. Consequently, on June 5, 2025, the Superior Council of Prosecutors notified the General Prosecutor’s Office to initiate the procedure for his dismissal. The case clearly shows that vetting is not a formalistic procedure, but an instrument with real legal consequences – from the verification of ethical integrity and assets to definitive dismissal from the system.

Moldova is still far from the comprehensive integrity checks carried out in Albania. However, more than 140 magistrates have already left the system due to issues related to their integrity or professionalism. Albania’s experience shows that a temporary staff crisis is inevitable after such a purge of the system. Nevertheless, Albania’s experience is considered a success, so Moldova will likely continue along this path.

In addition to efforts to purge the system of personnel, Moldova is also undertaking other important structural changes. It is reorganizing the Supreme Court, transforming it into a purely cassation court. This is expected to reduce the workload, which is why the number of supreme judges has been reduced from 33 to 20. Interestingly, 11 of the Supreme Court judges should be career magistrates, while the rest should be representatives of other legal professions—lawyers, prosecutors, university lecturers.

Moldova is also a positive example of successful reorganization of its judicial map, something that in Bulgaria continues to be an unattainable dream and a real taboo, despite the multi-million euro project implemented by the Supreme Judicial Council a few years ago. Unlike Bulgaria, between 2016 and 2024 Moldova has reorganized its judicial map twice to respond to the country’s current demographic developments, to efficiently concentrate resources in the system, and, above all, to avoid courts with two or three judges, which prevent the possibility of random case allocation. In 2017, the number of first instance courts was reduced from 44 to 15, and in 2023 there will be 14. The number of appeal courts was reduced from 5 in 2016 to 4, and in 2024 it will be reduced to 3.

The combination of institutional and structural reforms and external vetting of magistrates is considered a key element in restoring public confidence and bringing the country closer to European standards. As a result, the European Commission has already pointed out that Moldova has a stable institutional framework and “reasonably stable” macroeconomic policies, with progress in the financial sector and the business environment, although key economic reforms remain to be implemented. Consequently, on June 23, 2022, the Council granted candidate country status, and on December 14, 2023, it approved the opening of negotiations.

The integration process is not taking place in a vacuum. The war in Ukraine, dependence on Russian energy, and the Transnistria territory, controlled by pro-Russian forces, pose serious challenges. Russia is using hybrid attacks, propaganda, and economic leverage to destabilize the country. Nevertheless, in a referendum held in October 2024, Moldovans supported the inclusion of EU accession in the constitution, although the results were contested due to a large-scale Russian disinformation campaign.

The EU is responding with active support. In March 2025, the European Parliament approved the Reform and Growth Facility for Moldova, worth €1.9 billion – the largest aid package for this country to date. The funds are intended to accelerate socio-economic reforms, reduce energy dependence, and strengthen resilience to external threats. An additional €250 million is specifically allocated to energy independence.

Moldova proves that when there is sincere political will, change is possible. Bulgaria, despite having been part of the EU for almost two decades, continues to suffer from the highest levels of corruption and dependence in the EU. It remains to be seen where the two countries will end up in the future and whether we will manage to close the gap.

The subtitle is chosen by The Bridge of Friendship.

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