Decision no. 50/7 of 29.09.2026 Regarding the amendment of the National Financial Market Commission Decision no. 48/1 of 22.09.2026 regarding the unannounced inspection at OCN „ECOFINANCE TECHNOLOGIES” SRL and the suspension of the administrative procedure

REPUBLIC OF MOLDOVA
NATIONAL FINANCIAL MARKET COMMISSION
Stefan cel Mare și Sfânt Blvd, no. 77, Chisinau, MD 2012, tel: (373 22) 859 401, www.cnpf.md, e-mail: office@cnpf.md DECISION September 29, 2026 No. 50/7 Regarding the amendment of the National Financial Market Commission Decision no. 48/1 of 22.09.2026 regarding the unannounced inspection at OCN „ECOFINANCE TECHNOLOGIES” SRL and the suspension of the administrative procedure In fact, by Decision of the National Financial Market Commission (CNPF) no. 48/1 of
22.09.2026 regarding the unannounced inspection at OCN „ECOFINANCE
TECHNOLOGIES” SRL (Decision no. 48/1/2026), the initiation of the administrative procedure for an unannounced inspection at OCN „ECOFINANCE TECHNOLOGIES” SRL (participant), as a non-bank credit organization and bancassurance agent, was ordered, in relation to contracts (legal acts) concluded in the period 01.07.2025 – 21.09.2026. By the respective Decision, a term of 90 days was set for the completion of the administrative control procedure, in accordance with the Control Plan annexed thereto, which covers the period 22.09.2026 – 20.12.2026. According to point 3 of the Decision and point 5.2 of the Control Plan, the on-site inspection at the participant's headquarters is to be carried out in the period 01.10.2026 – 02.11.2026. By Notification no. 04-5/4629 of 25.09.2026, the CNPF informed the participant about the initiation of the unannounced administrative control procedure and about the period of on-site verifications. Subsequently, the participant's request (Request) accompanied by supporting documents, registered under no. 8782 and, respectively, no. 8806, was received by the CNPF, requesting the postponement of the unannounced on-site inspection for a period of 60 days or its rescheduling after the completion of the ongoing tax inspection carried out by the State Tax Service, as well as the corresponding amendment of the Control Plan. In support of the Request, the participant invokes the simultaneous conduct of a tax inspection at its headquarters, the insufficiency of logistical, space, and personnel resources necessary to ensure the activity of two inspection teams, as well as the involvement of specialists responsible for ensuring access to information systems and data extraction in the process of implementing the e-KYC solution. According to the Decision on the initiation of the inspection no. DICF-201656/1 of 15.09.2026, presented in support of the request, the State Tax Service is conducting an on-site tax inspection at the participant, by the total verification method, planned according to risks, starting on 24.09.2026 and ending on 09.10.2026. In law, according to point 20 sub-point 3) of the Regulation on the administrative control procedure, CNPF Decision no. 60/10/2023 (hereinafter - Regulation), the administrative control procedure may be suspended in cases where the participant submits a reasoned request to this effect, which contains circumstances not attributable to it. At the same time, according to point 23 sub-point 8) of the Regulation, the participant has the right to request the suspension or postponement of the inspection only once, if it demonstrates that its conduct will affect its normal functioning, will lead to the suspension of its activity, or that, for objective reasons, it cannot be subjected to the inspection. Additionally, according to point 43 of the Regulation, “43. In exceptional cases that determine the impossibility of conducting the inspection, within no more than 3 days from the date of receipt of
the decision regarding the inspection, the participant has the right to request the postponement of the inspection, for a period of no more than 30 days, by presenting the reasons for the postponement and by attaching supporting documents.”. Correlatively, according to art. 81 para. (2) of the Administrative Code, “(2) If, within an administrative procedure, the individual administrative act depends on an act or operation of a participant, the public authority suspends the administrative procedure for a reasonable period. Repeated suspension is permitted only if it is based on a reason that could not have been foreseen at the first suspension.”. At the same time, according to art. 81 para. (4) of the Administrative Code, “(4) During the suspension of the administrative procedure, the term provided in art. 60 para. (1) does not run.”. Complementarily, according to art. 61 para. (1) of the Administrative Code, the public authority may set deadlines for participants in the administrative procedure to perform certain actions. Correlatively, art. 63 para. (1) of the Administrative Code grants the authority the right to extend, upon request, the established deadlines. In this case, conducting the verifications implies that the participant ensures access to the documents and information systems necessary for the inspection, as well as working conditions for the inspection team. Relating the period of the tax inspection, confirmed by Decision no. DICF-201656/1 of 15.09.2026, to the invoked organizational difficulties, the CNPF considers it justified to grant a reasonable period to ensure these conditions after the completion of the tax verifications. Given that the completion of the tax inspection is set for 09.10.2026, it is considered reasonable to start the on-site inspection by the CNPF from 12.10.2026, which is the first following working day. Consequently, the participant's request for rescheduling the unannounced on-site inspection after the completion of the tax inspection is considered well-founded. From the submitted documents, the necessity of postponing the unannounced inspection for the entire requested period of 60 days is not argued, and the invocation of the e-KYC solution implementation process does not, by itself, demonstrate the impossibility of ensuring the necessary conditions for the inspection during that period. Under these conditions, taking into account the principles of efficiency and proportionality of the administrative procedure, as well as the necessity of verifying within a reasonable period the aspects that led to the initiation of the unannounced inspection, it is necessary to admit the request, postpone the unannounced on-site inspection until 12.10.2026, suspend the administrative procedure in the period 01.10.2026 – 11.10.2026, with the corresponding amendment of the period for conducting the on-site inspection at the participant's headquarters and the deadlines set in the Control Plan, annexed to Decision no.
48/1/2026. Based on art. 4 para. (2^1) lit. b) and lit. c) and para. (2^3), art. 8 lit. b) and lit. f^1), art. 20 para. (1) and art. 22 para. (3) of Law no. 192/1998 on the National Financial Market Commission, point 20 sub-point 3), point 21, point 23 sub-point 8), point 43 and point 44 of the Regulation on the administrative control procedure (CNPF Decision no. 60/10/2023), art. 61 para. (1), art. 62 para. (1), art. 81 para. (2) and para. (4) of the Administrative Code and point 3, point 6, point 16, point 18 and point 19 of the Regulation on the organization and functioning of the National Financial Market Commission (CNPF Decision no. 57/11/2022), The National Financial Market Commission DECIDES:

1. The request of OCN „ECOFINANCE TECHNOLOGIES” SRL (registered with the
   CNPF under no. 8782 on 28.09.2026), regarding the rescheduling of the period for conducting the unannounced on-site inspection, after the completion of the inspection carried out by the State Tax Service, according to Decision no. DICF-201656/1 of 15.09.2026, is admitted.
2. The unannounced on-site inspection at the participant's headquarters is postponed until
   12.10.2026.
3. The administrative procedure for unannounced inspection, initiated by CNPF Decision
   no. 48/1 of 22.09.2026 regarding the unannounced inspection at OCN „ECOFINANCE TECHNOLOGIES” SRL, is suspended for the period 01.10.2026 – 11.10.2026 inclusive.
4. The National Financial Market Commission Decision no. 48/1 of 22.09.2026 regarding
   the unannounced inspection at OCN „ECOFINANCE TECHNOLOGIES” SRL is amended as follows:
   4.1. at point 3, the text “01.10.2026 – 02.11.2026” is replaced with the text “12.10.2026 –
   13.11.2026”;
   4.2. Point V of the Annex to Decision no. 48/1/2026, is set out in the following wording:
   “V. The term of the administrative control procedure is 90 days and will cover the period 22.09.2026 – 31.12.2026, the administrative procedure being suspended for the period 01.10.2026 – 11.10.2026, with the following actions to be carried out:
   5.1. notification of the decision regarding the inspection: 22.09.2026 – 30.09.2026;
   5.2. conducting the unannounced inspection at the participant's headquarters:
   12.10.2026 – 13.11.2026;
   5.3. drawing up the provisional inspection report and notifying it: 16.11.2026 –
   23.11.2026;
   5.4. submission of objections by the participant: 24.11.2026 – 03.12.2026;
   5.5. drawing up the table of divergences based on the objections to the provisional
   inspection report, submitted by the participant, and finalizing the report on the results of the inspection: 04.12.2026 – 14.12.2026;
   5.6. where applicable, conducting the participant's hearing before issuing the decision
   on the results of the inspection: 15.12.2026 – 21.12.2026;
   5.7. drafting the draft decision on the results of the inspection and adopting it:
   22.12.2026 – 31.12.2026”.
5. This decision constitutes an administrative operation and may be challenged together
   with the individual administrative act, adopted at the completion of the administrative control procedure.
6. This decision enters into force on the date of adoption, is communicated to the recipient
   according to legislation and is published on the official website of the CNPF. Dumitru BUDIANSCHI, PRESIDENT