Anti-money laundering policy
Non-Banking Financial Company (Organizația de Creditare Nebancară) Microinvest SRL operates in accordance with international standards and national regulations on the prevention and combating of money laundering and terrorist financing, including Law no. 308 of 22.12.2017, National Bank of Moldova Regulation no. 281 of 07.11.2024, and other relevant legal acts. The company’s policy in this area aims to protect itself from risks associated with illegal activities, maintain financial integrity, and ensure compliance with applicable requirements.
In establishing business relationships, the company applies a risk-based approach, whose main elements include the application of the “Know Your Customer” (KYC) principle through client and beneficial owner identification and verification procedures, determining the purpose of the business relationship, client acceptance and approval procedures based on the associated risk level, and implementation of due diligence measures proportional to the identified risks.
An essential aspect is the identification and management of risks associated with politically exposed persons (PEPs). OCN Microinvest SRL has mechanisms in place for identifying politically exposed persons and applies enhanced due diligence for clients holding prominent public functions, their family members, and persons known to be close associates, including additional analysis of the origin of assets and/or funds and senior-level approval prior to establishing a business relationship with such persons.
Ongoing monitoring of business relationships and transactions is a key component of the company’s internal program for preventing and combating money laundering and terrorist financing, enabling the detection and reporting of suspicious activities to the competent authorities. OCN Microinvest SRL does not establish business relationships with entities whose activities are included in the list of business types not financed by OCN Microinvest SRL, non-resident legal entities, legal entities registered in the administrative-territorial units on the left bank of the Dniester River, as well as individuals registered in those areas who do not hold an identity card/passport of a citizen of the Republic of Moldova; persons or companies listed on international sanctions lists or engaged in high-risk activities related to money laundering and terrorist financing.
The company ensures the retention of documents and information about clients for the entire duration of the business relationship, as well as for a period of 5 years after its termination or after the execution of an occasional transaction. It also complies with regulations on personal data protection and applies strict measures to prevent the misuse of customer-related information.
Microinvest has appointed individuals, including senior management representatives, responsible for ensuring compliance with the regulatory requirements on the prevention and combating of money laundering and terrorist financing, and for ensuring that internal policies and procedures align with these requirements.
Additionally, OCN Microinvest SRL has an ongoing internal training program for all employees involved in the prevention of money laundering and terrorist financing, ensuring they are prepared to identify and manage associated risks and understand and correctly apply procedures and legal obligations.
THIS DOCUMENT REPRESENTS A SUMMARY VERSION OF THE ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING POLICY OF OCN MICROINVEST S.R.L. AND SHOULD NOT BE CONSIDERED A SEPARATE INTERNAL REGULATORY ACT.
