AML/CFT, Anti-Bribery & Anti-Corruption

AML/CFT, Anti-Bribery & Anti-Corruption, and Responsible Supply Chain Policies

Jewellery and precious metals compliance framework

Version 1.0 | Effective date: 02 June 2026

Document status: approved internal policy template for management review and implementation. This document should be reviewed periodically and whenever Moldovan legislation or company operations change.

1. Purpose and Scope
This document sets out the internal compliance policies of AMANET.MD regarding anti-money laundering and counter-terrorist financing (AML/CFT), anti-bribery and anti-corruption, and responsible supply chain management for jewellery, precious metals, precious stones, and related activities.
The company applies a zero-tolerance approach to money laundering, terrorism financing, corruption, bribery, fraud, falsification of documents, smuggling, counterfeit goods, undeclared goods, tax evasion, and any transaction involving unclear or unlawful origin of goods or funds.
These policies apply to all employees, management, suppliers, contractors, intermediaries, commercial partners, and any other persons acting on behalf of the company.

2. Legal and Regulatory Framework
The company conducts its activity in accordance with applicable Moldovan legislation and relevant international standards, including, where applicable:
•    Law No. 308/2017 on Preventing and Combating Money Laundering and Terrorism Financing, including all subsequent amendments and implementing regulations.
•    Law No. 75/2020 on the procedure for establishing violations in the field of preventing money laundering and terrorism financing and imposing sanctions.
•    Law No. 282/2004 on the Regime of Precious Metals and Precious Stones, including rules on activity with precious metals and stones, state marking supervision, licensing, record-keeping, storage, customs control, testing and marking.
•    Law No. 160/2011 on the Regulation by Authorization of Entrepreneurial Activity, to the extent applicable to licensed/permissive activities involving precious metals, precious stones, and pawnshop operations.
•    Criminal Code of the Republic of Moldova, including corruption, bribery, fraud, money laundering and other relevant criminal offences.
•    Integrity Law No. 82/2017, in particular the principle of zero tolerance toward corruption in interactions with public entities and public agents.
•    Tax Code No. 1163/1997 and related fiscal, VAT, invoicing and reporting obligations.
•    Law No. 287/2017 on Accounting and Financial Reporting, including requirements for accurate accounting records, supporting documents, and financial reporting.
•    Law No. 105/2003 on Consumer Protection, including transparent information to consumers and respect for consumer rights.
•    Law No. 133/2011 on Personal Data Protection and, from its applicable date, Law No. 195/2024 on Personal Data Protection, insofar as the company processes customer, employee, supplier, or transaction personal data.
•    Customs, import/export, e-commerce, labour, health and safety, and other legislation applicable to the company’s activity in the Republic of Moldova.
•    Applicable international standards and good practices, including FATF Recommendations and relevant MONEYVAL/European compliance principles where they inform Moldovan AML/CFT practice.

3. Governance and Responsibilities
•    Management is responsible for establishing a compliance culture, approving policies, allocating resources, and ensuring that internal controls are implemented in practice.
•    The designated compliance responsible person coordinates AML/CFT controls, supplier due diligence, training, incident reporting, record archiving, and periodic policy review.
•    Shop managers and department heads must verify that daily operations follow company policies, legal requirements, and internal procedures.
•    All employees must immediately report suspicious transactions, suspicious behaviour, unclear origin of goods or funds, attempted bribery, falsified documents, pressure from third parties, or any breach of this policy.

4. AML/CFT Policy
AMANET.MD strictly respects Law No. 308/2017 and Law No. 75/2020. The company will not knowingly enter into, assist, facilitate, or conceal any transaction connected with money laundering, terrorism financing, proliferation financing, fraud, tax evasion, corruption, illegal trafficking, smuggling, or unclear ownership of assets.
4.1 Risk-Based Approach
•    The company evaluates AML/CFT risk according to the nature of the customer, transaction, product, payment method, supplier, geography, and any unusual circumstances.
•    Higher risk situations require enhanced checks, management review, and, where required, refusal or reporting of the transaction.
•    No employee may split transactions, ignore warning signs, or accept undocumented explanations in order to avoid compliance checks.
4.2 Customer and Transaction Controls
•    Where required by law or internal thresholds, the company identifies and verifies customers, beneficial owners, representatives, and transaction purpose.
•    The company records supporting documents for relevant transactions, including invoices, receipts, identification details, contracts, payment confirmations, and product information.
•    Cash transactions, unusually high-value transactions, repeated transactions, transactions with third parties, and transactions inconsistent with the known customer profile are reviewed carefully.
4.3 Suspicious Activity
•    The company monitors red flags such as reluctance to provide identification, unclear source of funds, requests to alter invoices, use of intermediaries without economic reason, unusual urgency, inconsistent explanations, or attempts to avoid official documentation.
•    If suspicious activity is identified, employees must stop the transaction where appropriate, notify the compliance responsible person, and preserve all relevant documents.
•    The company cooperates with competent authorities in accordance with applicable law and does not disclose restricted information where tipping-off rules apply.
4.4 Record Keeping and Archiving
•    All AML/CFT records are archived securely and in a retrievable manner for the legally required retention period.
•    Archived records include customer/transaction files, invoices, payment records, internal approvals, supplier documentation, suspicious activity notes, training evidence, and compliance review logs.
•    Records must be accurate, complete, dated, and protected from unauthorized alteration or deletion.

5. Anti-Bribery and Anti-Corruption Policy
The company has a strict zero-tolerance policy toward bribery and corruption. No director, employee, supplier, agent, or partner may offer, promise, give, request, accept, or authorize any bribe, kickback, facilitation payment, hidden commission, improper advantage, or benefit intended to influence a decision or obtain an unfair business advantage.
5.1 Prohibited Conduct
•    Bribes, kickbacks, secret commissions, facilitation payments, or unofficial payments to public officials or private persons.
•    Gifts, hospitality, discounts, sponsorships, donations, or personal favours intended to influence a business or regulatory decision.
•    False invoices, inflated prices, undocumented commissions, sham consulting agreements, or payments to unknown third parties.
•    Pressure on employees to ignore legal requirements, customs rules, hallmarking requirements, fiscal obligations, or internal controls.
5.2 Gifts and Hospitality
•    Gifts and hospitality must be modest, lawful, transparent, properly recorded, and never used to influence a decision.
•    Cash or cash-equivalent gifts are prohibited.
•    Any gift or hospitality involving a public official, inspector, regulator, customs officer, law enforcement representative, or state employee requires prior management approval.
5.3 Conflicts of Interest
•    Employees and managers must disclose personal, family, financial, or business interests that could influence purchasing, supplier selection, pricing, employment decisions, or customer treatment.
•    Decisions must be based on objective commercial criteria, documented evidence, and company interests.
5.4 Reporting and Protection
•    Employees must report bribery requests, attempted improper payments, threats, pressure, or unethical conduct immediately to management or the compliance responsible person.
•    The company prohibits retaliation against any person who reports a concern in good faith.

6. Responsible Supply Chain Policy
AMANET.MD maintains a clear, transparent, documented, verified, and archived supply chain. The company purchases, imports, stores, displays, sells, repairs, or otherwise handles jewellery and precious items only where the lawful origin, commercial path, and supporting documents can be reasonably verified.
6.1 Supplier Due Diligence
•    Before cooperation, suppliers are checked for legal identity, registration details, contact information, licences/authorizations where relevant, reputation, product documentation, and ability to provide complete invoices and certificates.
•    The company avoids suppliers that cannot demonstrate lawful origin of goods, refuse documentation, request non-transparent payments, or present high AML/CFT or corruption risk.
•    Supplier files are kept updated and archived.
6.2 Product Documentation and Traceability
•    For each relevant product or batch, the company keeps available documents such as supplier invoices, contracts, delivery notes, assay/hallmarking documents, certificates, import/customs documents, payment confirmations, and internal inventory records.
•    Products made of precious metals or precious stones are handled in accordance with applicable testing, marking, registration, storage, and record-keeping requirements.
•    Any product with unclear origin, unclear markings, inconsistent documents, or suspected counterfeit/fraudulent characteristics is held for review and is not sold until verified.
6.3 Prohibited Sources
•    The company does not knowingly source goods connected with crime, corruption, sanctions, money laundering, terrorism financing, conflict financing, smuggling, theft, counterfeit goods, forced labour, child labour, or human rights abuses.
•    The company rejects products when documentation is missing, inconsistent, falsified, or impossible to verify.
6.4 Archiving and Verification
•    All supply chain documents are archived in physical and/or electronic format and can be retrieved for internal review, audit, accounting, tax, regulatory, or law-enforcement purposes.
•    The company periodically reviews supplier documentation, inventory records, product markings, and transaction files to ensure consistency and transparency.

7. Accounting, Tax and Documentation Controls
•    All transactions must be recorded accurately and supported by appropriate documents.
•    Invoices, receipts, tax invoices, contracts, delivery notes, payment confirmations, inventory records, accounting entries, and financial reports must reflect the real commercial substance of transactions.
•    The company prohibits off-book sales, hidden payments, false descriptions, under-invoicing, over-invoicing, undocumented discounts, and alteration of accounting records.
•    Accounting and tax documents are retained according to legal requirements and internal archiving rules.

8. Consumer Protection and Product Integrity
•    The company provides consumers with clear and truthful information about jewellery products, including the type of metal, fineness, stones, price, warranty or return conditions where applicable, and other legally required product characteristics.
•    The company does not mislead consumers regarding origin, material, quality, price, discount, brand, stone type, or product characteristics.
•    Complaints are handled professionally, documented, and reviewed to improve controls and customer trust.

9. Personal Data and Confidentiality
•    The company processes personal data only for lawful, legitimate, and necessary business purposes, including sales, customer identification where required, AML/CFT checks, accounting, tax, employment, supplier management, and legal compliance.
•    Personal data and confidential documents are protected against unauthorized access, disclosure, alteration, loss, or destruction.
•    Employees may access customer, supplier, employee, or transaction information only where required for their role.

10. Training and Awareness
•    Employees receive practical instructions on AML/CFT red flags, anti-bribery rules, supplier documentation, transaction records, consumer transparency, and internal reporting.
•    Training and policy acknowledgements are documented and archived.
•    New employees must receive compliance orientation before handling high-value transactions or supplier/customer documentation.

11. Monitoring, Internal Review and Breach Management
•    The company monitors compliance with this policy through management checks, document reviews, inventory checks, supplier file reviews, accounting reconciliation, and investigation of red flags.
•    Any breach may result in corrective action, disciplinary measures, termination of cooperation, refusal of transaction, notification to competent authorities, and other steps required by law.
•    This policy is reviewed at least annually and whenever legislation, business operations, suppliers, risks, or regulatory guidance materially change.

12. Practical Red Flags
•    Customer or supplier refuses to provide identity, registration, licence, ownership, source-of-funds, or source-of-goods information.
•    Customer asks to split payments or invoices, use third-party payments without explanation, or avoid official documents.
•    Supplier offers jewellery or precious items at unusually low prices with weak documentation.
•    Documents contain inconsistent names, quantities, weights, values, markings, dates, or payment details.
•    Goods appear altered, counterfeit, improperly marked, or inconsistent with certificates or invoices.
•    A public official or inspector asks for an unofficial payment, gift, discount, favour, or benefit.
•    Employee or partner asks to bypass procedures, not archive documents, or “solve” an issue informally.

13. Legal Reference Notes
1. Law No. 308/2017 establishes measures for the prevention and combating of money laundering and terrorism financing and applies to designated non-financial businesses and professions as part of the protected financial and non-financial system.
2. Law No. 282/2004 regulates activities with precious metals and precious stones, including sale, purchase, manufacture, repair, storage, testing, marking, state supervision, customs control, special record-keeping, and licensing/permissive requirements.
3. Law No. 75/2020 regulates the procedure for establishing AML/CFT violations and imposing sanctions in the Republic of Moldova.
4. Integrity Law No. 82/2017 promotes a zero-tolerance climate toward corruption in public entities and interactions involving public agents and the private sector.
5. Law No. 287/2017 regulates accounting and financial reporting obligations in Moldova; the Tax Code No. 1163/1997 governs tax compliance; Law No. 105/2003 regulates consumer protection; Law No. 133/2011 currently regulates personal data protection, with Law No. 195/2024 expected to become applicable from August 2026.