Compliance Control

OJSC MBANK (hereinafter referred to as the “Bank”) adheres to high standards of corporate governance, transparency, and business ethics.

The Bank recognizes its responsibility to its customers, partners, and the state. Therefore, compliance with legal requirements, ensuring transparency of operations, and combating money laundering, terrorist financing, and the financing of proliferation of weapons of mass destruction are among our absolute priorities.

Identification, assessment, and management of compliance risks.

Compliance with legislation and internal regulatory documents.

Preventing the Bank from becoming involved in illegal activities.

Protecting the interests of the Bank, its customers, and partners.

• The legislation of the Kyrgyz Republic;

• Regulatory legal acts of the National Bank of the Kyrgyz Republic (NBKR);

• Requirements of the State Financial Intelligence Service (SFIS);

• International standards and recommendations of the Financial Action Task Force (FATF).

The Bank implements internal controls for AML/CFT/CPF purposes in accordance with the Law of the Kyrgyz Republic “On Combating the Financing of Criminal Activities and Legalization (Laundering) of Criminal Proceeds.”

The Bank applies a risk-based approach that involves identifying, assessing, and managing relevant risks, as well as detecting and preventing suspicious transactions.

At the same time, the Bank strives to ensure proper compliance with legal requirements while maintaining a balance between effective internal controls and convenient services for law-abiding customers.

The Bank places particular emphasis on customer identification and Customer Due Diligence (CDD) procedures under the Know Your Customer (KYC) principle.

These procedures are aimed at verifying the identities of customers and their beneficial owners, understanding the purpose and nature of business relationships, and assessing the risks associated with providing banking services.

The Bank ensures that customer information is kept up to date and monitors transactions to detect suspicious activity and prevent the misuse of its services for illegal purposes.

In the context of an increasingly globalized financial market, OJSC MBANK places particular emphasis on compliance with national and international sanctions requirements and restrictions.

The Bank screens customers, counterparties, and transactions for compliance with sanctions regimes imposed by the United Nations Security Council, the United States (OFAC), the European Union, the United Kingdom, and other jurisdictions whose requirements are taken into account in the Bank's operations and international business relationships.

These measures are aimed at preventing violations of sanctions restrictions, identifying potential sanctions evasion, and minimizing legal, regulatory, and reputational risks.

When processing cross-border transfers, the Bank has the right to request additional documents and information from customers to verify the economic substance and purpose of a transaction, its legality, and compliance with applicable sanctions requirements, as well as to identify potential signs of sanctions evasion.

Depending on the Nature of the Transaction, the Bank May Request:

• Foreign trade contracts and supplementary agreements;

• Invoices, payment requests, and specifications;

• Customs declarations and transport documents;

• Documents confirming the origin of goods, their intended use, and the ultimate recipient;

• Information about the parties to the transaction, their beneficial owners, and other participants;

• Licenses, permits, and other documents required to confirm the permissibility of the transaction;

• Other documents and information related to the transaction and necessary for conducting the review.

Based on the results of the review, the Bank has the right to take measures provided for by the legislation of the Kyrgyz Republic and the Bank's internal documents, including refusing to process a transaction and/or terminating business relationships with a customer where appropriate grounds exist.

The Bank adheres to a zero-tolerance policy toward all forms of corruption and bribery.

The Bank implements measures to prevent, identify, and resolve conflicts of interest among employees and management, aimed at ensuring fair and impartial customer service.

If you become aware of potential cases of corruption, fraud, unethical behavior by Bank employees, or other violations of the legislation of the Kyrgyz Republic, you may report them to the Bank's Compliance Control Department.

The Bank ensures the confidentiality of received reports and their objective review in accordance with established procedures.

We strive to ensure reliable protection of your financial interests and continuously improve our internal control system.

To facilitate due diligence and compliance risk assessment procedures conducted by international partners, the Bank provides up-to-date information and documents necessary for Due Diligence procedures.

The Bank regularly updates its compliance questionnaire in accordance with the Wolfsberg Group standards (Wolfsberg Group CBDDQ) and provides relevant tax forms and other documents upon request from partners.