AML/CFT, Anti-Bribery & Anti-Corruption

AML/CFT, Anti-Bribery, and Anti-Corruption Policy

Compliance Framework for Jewelry and Precious

Version 1.0 | Effective Date: June 02, 2026

Document Status: Internal policy model approved for management review and implementation. This document must be reviewed periodically and whenever there are changes in the legislation of the Republic of Moldova or in the company's activity.

1. Purpose and Scope

This document establishes the internal compliance policies of AMANET.MD regarding the prevention and combating of money laundering and terrorist financing (AML/CFT), as well as anti-bribery and anti-corruption.

The company enforces a zero-tolerance policy towards money laundering, terrorist financing, corruption, bribery, fraud, document forgery, smuggling, counterfeit goods, undeclared goods, tax evasion, and any transaction involving an unclear or illegal origin of assets.

These policies apply to all employees, management, contractors, intermediaries, business partners, and any other persons acting on behalf of the company.

2. Legal and Regulatory Framework

The company conducts its business in accordance with the applicable legislation of the Republic of Moldova and relevant international standards, including, where applicable:

Law No. 308/2017 on the prevention and combating of money laundering and terrorist financing, including all subsequent amendments and implementation acts.

Law No. 75/2020 on the procedure for establishing violations in the field of prevention of money laundering and terrorist financing and the application of sanctions.

Law No. 282/2004 on the regime of precious metals and precious stones, including rules on operations with precious metals and stones, state hallmarking supervision, authorization, record-keeping, storage, customs control, appraisal, and hallmarking.

Law No. 160/2011 on the regulatory framework for licensing entrepreneurial activity, as applicable to licensed/permissive activities with precious metals, precious stones, and pawnshop operations.

Criminal Code of the Republic of Moldova, including offenses related to corruption, bribery, fraud, money laundering, and other relevant crimes.

Integrity Law No. 82/2017, specifically the principle of zero tolerance for corruption in interactions with public entities and public officials.

Tax Code No. 1163/1997 and related obligations regarding taxation, VAT, invoicing, and reporting.

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 consumer information and adherence to consumer rights.

Law No. 133/2011 on personal data protection and, from its applicability date, Law No. 195/2024 on personal data protection, to the extent that the company processes customer, employee, vendor, or transaction data.

Labor Code, occupational health and safety laws, and other normative acts applicable to the company's activities in the Republic of Moldova.

Applicable international standards and best practices, including FATF Recommendations and relevant MONEYVAL/European principles, to the extent that they guide AML/CFT practice in the Republic of Moldova.

Law No. 114 of May 18, 2012 on payment services and electronic money.

3. Governance and Responsibilities

Management is responsible for establishing a compliance culture, approving policies, allocating resources, and ensuring the effective implementation of internal controls.

The Designated Compliance Officer coordinates AML/CFT controls, training, incident reporting, record archiving, and periodic policy reviews.

Administration and Department Heads must verify that daily activities comply with company policies, legal requirements, and internal procedures.

All Employees must immediately report suspicious transactions, suspicious behavior, unclear origin of assets, bribery attempts, forged documents, third-party pressure, or any violation of this policy.

4. AML/CFT Policy

AMANET.MD strictly complies with Law No. 308/2017 and Law No. 75/2020. The company will not knowingly initiate, support, facilitate, or conceal any transaction related to money laundering, terrorist 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 based on the nature of the customer, transaction, asset, payment method, and any unusual circumstances.

·  High-risk situations require additional verification, management review, and, where appropriate, refusal or reporting of the transaction.

·  No employee may split transactions, ignore red flags, or accept undocumented explanations to evade compliance controls.

4.2 Customer and Transaction Due Diligence

·  When required by law or internal thresholds, the company identifies and verifies customers, beneficial owners, representatives, and the purpose of the transaction.

·  The company maintains supporting documentation for relevant transactions, including invoices, receipts, identification data, contracts, payment confirmations, and asset details.

·  Cash transactions, unusually high-value transactions, repeated transactions, third-party transactions, and those inconsistent with the customer's known profile are subject to enhanced scrutiny.

4.3 Suspicious Activity

·  The company monitors for red flags such as refusal to provide identification, unclear source of funds, unusual urgency, contradictory explanations, or attempts to avoid official documentation.

·  If suspicious activity is identified, employees must, as appropriate, halt the transaction, inform the compliance officer, and retain all relevant documentation.

·  The company cooperates with competent authorities in accordance with the law and does not disclose restricted information when tipping-off prohibitions apply.

4.4 Recordkeeping and Archiving

·  All AML/CFT records are securely archived and kept easily retrievable for the period mandated by law.

·  Archived records include customer and transaction files, payment records, internal approvals, notes on suspicious activities, training evidence, and compliance audit logs.

·  Records must be accurate, complete, dated, and protected against unauthorized modification or deletion.

5. Anti-Bribery and Anti-Corruption Policy

The company enforces a strict zero-tolerance policy towards bribery and corruption. No director, employee, agent, or partner may offer, promise, give, request, accept, or authorize a bribe, kickback, facilitation payment, hidden commission, improper advantage, or benefit intended to influence a decision or secure an unfair business advantage.

5.1 Prohibited Conduct

·  Bribes, kickbacks, secret commissions, facilitation payments, or unofficial payments to public officials or private individuals.

·  Gifts, hospitality, discounts, sponsorships, donations, or personal favors intended to influence a business or regulatory decision.

·  Pressuring employees to ignore legal requirements, tax obligations, or internal controls.

5.2 Gifts and Hospitality

·  Gifts and hospitality must be modest, legal, transparent, properly recorded, and never used to influence decisions.

·  Cash gifts or cash equivalents are strictly prohibited.

·  Any gift or hospitality involving a public official, inspector, regulator, customs official, law enforcement officer, or state employee requires prior management approval.

5.3 Conflicts of Interest

·  Employees and managers must declare personal, family, financial, or business interests that could influence hiring decisions or client treatment.

·  Decisions must be based on objective commercial criteria, documented evidence, and the best interests of the company.

5.4 Reporting and Protection

·  Employees must immediately report to management or the compliance officer any bribe requests, improper payment attempts, threats, pressure, or unethical conduct.

·  The company prohibits any retaliation against an individual who reports a concern in good faith.

6. Accounting, Tax, and Documentary Controls

All transactions must be accurately recorded and supported by appropriate documentation.

Receipts, tax invoices, contracts, payment confirmations, accounting records, and financial reports must reflect the true commercial substance of the transactions.

The company prohibits hidden payments, false entries, and off-the-books accounting alterations.

Accounting and tax records must be retained in accordance with legal requirements and internal archiving rules.

7. Consumer Protection and Collateral Integrity

The company provides customers (pledgors) with clear, accurate, and transparent information regarding the terms of collateral-backed loans, including valuation methods for precious metals, fineness (purity), fees, interest rates, repayment schedules, and the consequences of unredeemed items, in accordance with legal requirements.

The company does not mislead customers regarding the appraised value of pledged property, valuation criteria, weight, precious metal purity, or contractual loan terms.

Customer complaints and disputes regarding collateral valuation or lending services are handled professionally, fully documented, and thoroughly analyzed to improve service quality and maintain customer transparency.

8. Personal Data and Confidentiality

The company processes personal data only for legitimate, lawful, and necessary business purposes, including customer identification when required, AML/CFT checks, accounting, taxation, employment relationships, and legal compliance.

Personal data and confidential documents are safeguarded against unauthorized access, disclosure, alteration, loss, or destruction.

Employees may access customer, employee, or transaction data only to the extent required to fulfill their job duties.

9. Training and Awareness

Employees receive practical instructions on AML/CFT red flags, anti-corruption rules, transaction recordkeeping, consumer transparency, and internal reporting.

Training sessions and policy acknowledgment confirmations are documented and archived.

New employees must complete compliance training prior to handling high-value transactions or customer documentation.

10. Monitoring, Internal Control, and Breach Management

The company monitors policy compliance through management checks, document reviews, inventory audits, accounting reconciliations, and red flag investigations.

Any violation may result in corrective actions, disciplinary sanctions, termination of employment/contracts, transaction refusal, notification of competent authorities, and other statutory remedies.

This policy is reviewed at least annually and whenever significant changes occur in legislation, business operations, risk exposure, or regulatory guidance.

11. Practical risk indicators

The customer refuses to provide information regarding their identity, source of funds, or source of assets.

The customer requests transaction splitting, payment processing via unexplained third parties, or evasion of official documentation.

A public official or inspector requests an unofficial payment, gift, discount, favor, or other improper benefit.

An employee or partner requests to bypass procedures, skip record archiving, or resolve an issue "informally."