Decision on Approving the Procedure for Supervision of Compliance by Primary Financial Monitoring Subjects with Anti-Money Laundering and Counter-Terrorist Financing Legislation

NATIONAL COMMISSION FOR SECURITIES AND STOCK MARKET DECISION Kyiv On Approval of the Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained by Criminal Means, Terrorism Financing and Financing of Proliferation of Weapons of Mass Destruction by Subjects of Primary Financial Monitoring, State Regulation and Supervision of Whose Activities is Carried out by the National Commission for Securities and Stock Market

In accordance with paragraph 1 of part one of Article 7 of the Law of Ukraine "On State Regulation of Capital Markets and Organized Commodity Markets" and part two of Article 18 of the Law of Ukraine "On Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained by Criminal Means, Terrorism Financing and Financing of Proliferation of Weapons of Mass Destruction", with the aim of bringing normative legal acts into compliance with the requirements of legislation, the National Commission for Securities and Stock Market

D E C I D E D:

1. Approve the Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained by Criminal Means, Terrorism Financing and Financing of Proliferation of Weapons of Mass Destruction by Subjects of Primary Financial Monitoring, State Regulation and Supervision of Whose Activities is Carried out by the National Commission for Securities and Stock Market, attached hereto.

2. Declare invalid the Decision of the National Commission for Securities and Stock Market dated July 17, 2015 No. 1038 "On Approval of the Procedure for Conducting Supervision (Control) over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained by Criminal Means, Terrorism Financing and Financing of Proliferation of Weapons of Mass Destruction by Subjects of Primary Financial Monitoring, State Regulation and Supervision of Whose Activities is Carried out by the National Commission for Securities and Stock Market", registered in the Ministry of Justice of Ukraine on August 06, 2015 under No. 955/27400 (with amendments).

3. The Department of Financial Monitoring and Inspections shall ensure the submission of this decision for state registration to the Ministry of Justice of Ukraine.

4. The Administration of Administrative Activities shall ensure the publication of this decision on the website of the National Commission for Securities and Stock Market.

5. The Department of Legal Support and Internal Compliance Control shall, after state registration of the decision by the Ministry of Justice of Ukraine, ensure the publication of this decision on the official website of the National Commission for Securities and Stock Market.

6. This decision enters into force on the day following the day of its official publication on the official website of the National Commission for Securities and Stock Market.

7. Supervision over the implementation of this decision shall be entrusted to a member of the National Commission for Securities and Stock Market, Yu. Shapoval.

Chairman of the Commission Ruslan MAGOMEDOV

Protocol of the Commission meeting dated 22.08.2025 No. 83

APPROVED Decision of the National Commission for Securities and Stock Market ______________________ No. ______

Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained by Criminal Means, Terrorism Financing and Financing of Proliferation of Weapons of Mass Destruction by Subjects of Primary Financial Monitoring, State Regulation and Supervision of Whose Activities is Carried out by the National Commission for Securities and Stock Market

I. General Provisions

1. This Procedure is a document establishing the mechanism for conducting by the National Commission for Securities and Stock Market (hereinafter – the Commission, NCSPSM) supervision over compliance with the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained by criminal means, terrorism financing and financing of proliferation of weapons of mass destruction (hereinafter – prevention and counteraction) by subjects of primary financial monitoring, state regulation and supervision of whose activities is carried out by the Commission.

The Commission conducts supervision by conducting planned/unplanned on-site inspections (hereinafter – on-site inspections), planned/unplanned off-site inspections (hereinafter – off-site inspections), and sending requests for obtaining documents, information and written explanations (hereinafter – Request), necessary for conducting off-site supervision.

Employees of the State Financial Monitoring Service of Ukraine (hereinafter – StateFinMon) have the right to participate in inspections with the agreement of the Commission.

2. Requirements regarding electronic document flow and the use of electronic signatures during the conduct of an inspection in cases specified by this Procedure are regulated by the Laws of Ukraine "On Electronic Documents and Electronic Document Flow", "On Electronic Identification and Electronic Trust Services", other acts of legislation on electronic documents and electronic document flow, in the field of cryptographic and technical information protection, as well as acts of the NCSPSM.

3. Documents provided for by this Procedure are compiled/provided/sent in paper form in case of impossibility of their compilation/sending in the form of an electronic document.

Interaction between the NCSPSM and the subject of primary financial monitoring (hereinafter – SPFM) regarding the sending/receipt of electronic documents is carried out using the means of the Commission's comprehensive information and communication system (hereinafter – CIS) through the user's electronic cabinet of the CIS.

Electronic documents of the NCSPSM sent (placed) in the user's electronic cabinet of the CIS are considered received by the SPFM.

In case of impossibility of sending electronic documents using CIS means, documents are sent in paper form using postal services (with delivery notification), courier, messenger service or in person.

II. Organization of Conducting Inspections

1. An on-site inspection / off-site inspection is conducted based on a resolution of the Commission on conducting an inspection (Appendix 1).

2. A planned on-site inspection / planned off-site inspection (hereinafter – planned inspection) of an SPFM is conducted in accordance with an annual schedule (hereinafter – schedule), which is approved by the resolution of the Commission before December 1 of the year preceding the planned one.

Information regarding the list of SPFMs, inspections of which are included in the schedule, and amendments to the approved schedule are published on the official website of the Commission.

StateFinMon has the right to participate in the preparation of the schedule with the agreement of the Commission.

3. Inclusion of an SPFM in the schedule for conducting inspections is carried out on the basis of a risk-oriented approach.

Risk criteria are established by the Commission and are taken into account when determining the risk profile of an SPFM by type of professional activity in capital markets and organized commodity markets.

The risk level of an SPFM is established on the date of compilation of the schedule for conducting inspections.

4. A planned inspection involves a planned by the Commission check of the compliance of the SPFM's activities with the requirements of legislation in the field of prevention and counteraction during a period subject to inspection.

A planned inspection is conducted for the period from the date of completion of the previous inspection or for a certain period of the SPFM's activity.

5. The minimum list of issues for a planned inspection must include checking compliance with legislative requirements regarding:

1. appointment of an employee responsible for conducting financial monitoring and verification of his impeccable business reputation;
2. requirements for the qualification of an employee responsible for conducting financial monitoring;
3. development, implementation and updating of financial monitoring rules, a program for conducting primary financial monitoring;
4. conducting due diligence of clients (representatives of clients), including clients whose (ultimate beneficial owners who are) politically exposed persons, members of their families and persons associated with politically exposed persons, and clients who do not have an ultimate beneficial owner, and conducting monitoring of transactions of such clients;
5. conducting analysis and detection of financial operations subject to financial monitoring, and operations regarding which there are sufficient grounds to suspect that they are related to, concern or are intended for legalization (money laundering) of proceeds obtained by criminal means, terrorism financing or financing of proliferation of weapons of mass destruction, registration of such financial operations and provision of information about them;
6. suspension of the implementation of financial operation(s) containing signs of legalization (money laundering) of proceeds obtained by criminal means, terrorism financing and financing of proliferation of weapons of mass destruction;
7. storage of documents and information on financial monitoring, creation and storage of electronic and backup copies of documents;
8. ensuring the functioning of a proper risk management system, application of a risk-oriented approach in its activities and taking appropriate measures to minimize risks;
9. conducting risk management to prevent the use of services and products of an SPFM for legalization (money laundering) of proceeds obtained by criminal means, terrorism financing and financing of proliferation of weapons of mass destruction;
10. conducting risk management related to the introduction or use of new and existing information products, business practices or technologies, including those that ensure the conduct of financial operations without direct contact with the client;
11. conducting by an SPFM internal inspections of its activities regarding compliance with legislation in the field of prevention and counteraction;
12. conducting measures for personnel training regarding proper fulfillment of the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained by criminal means, terrorism financing and financing of weapons of mass destruction;
13. freezing / unfreezing of assets related to terrorism and its financing, proliferation of weapons of mass destruction and its financing;
14. compliance by an SPFM with requirements regarding submission of reports (information) to the State Financial Monitoring Service of Ukraine and processing of reports (information) from the State Financial Monitoring Service of Ukraine.

The listed list of issues is not exhaustive and may be supplemented during the conduct of an inspection within the framework of legislation in the field of prevention and counteraction.

6. A planned inspection is conducted upon prior notification of the SPFM about the conduct of a planned inspection.

A notification about the conduct of a planned inspection in the form of a letter of the Commission, signed by a member of the Commission, and a resolution of the Commission on conducting an inspection are sent to the SPFM no later than 10 working days before the start of the planned inspection.

A notification about the conduct of a planned inspection must contain the following information:

1. grounds for conducting an inspection;
2. term of conduct of an inspection;
3. period subject to inspection;
4. information about the head of the working group / members of the working group / authorized person(s) conducting a planned off-site inspection and contact phone number;
5. list of issues subject to inspection.

7. An unplanned on-site inspection / unplanned off-site inspection (hereinafter – unplanned inspection) involves an inspection not planned by the Commission of the compliance of the SPFM's activities with the requirements of legislation in the field of prevention and counteraction on specific issues defined in the resolution of the Commission on conducting an inspection.

An unplanned inspection may be conducted by the Commission in the presence of at least one of the following grounds:

1. report on signs of violation by an SPFM and/or its separate subdivision of the requirements of legislation in the field of prevention and counteraction;
2. execution of a court decision that has entered into legal force;
3. discovery by the Commission of new documents (circumstances) that were not (could not be) known during the conduct of a planned inspection and which may affect the conclusions based on the results of a planned inspection;
4. non-submission by an SPFM within the established term and/or submission in incomplete volume of documents (information) upon Request, written explanations regarding reasons preventing the submission of such documents (information);
5. discovery of signs of inaccuracy in documents (information) provided by an SPFM upon Request and/or if such documents (information) do not allow assessing the compliance of an SPFM with the requirements of legislation in the field of prevention and counteraction during its activity.

In the event of grounds arising during the conduct of a planned inspection for conducting an unplanned inspection, such issues are subject to inspection within the framework of conducting this inspection.

8. An unplanned inspection is conducted upon prior notification of the SPFM about the conduct of an unplanned inspection.

A notification about the conduct of an unplanned inspection in the form of a letter of the Commission, signed by a member of the Commission, and a resolution of the Commission on conducting an inspection are sent to the SPFM no later than 2 working days before the start of the unplanned inspection.

A notification about the conduct of an unplanned inspection must contain the following information:

1. grounds for conducting an inspection;
2. term of conduct of an inspection;
3. information about the head of the working group / members of the working group / authorized person(s) conducting an unplanned off-site inspection;
4. list of issues subject to inspection.

9. An on-site inspection is conducted in the premises of an SPFM at its location (temporary location, about which the SPFM notified the Commission) and in the premises of the Commission.

The term of conduct of an on-site inspection cannot exceed 45 working days from the day of its start, defined in the resolution of the Commission on conducting an inspection.

An inspection may be completed earlier than the term indicated in the resolution of the Commission on conducting an inspection.

10. An on-site inspection is conducted during the working hours of an SPFM established by the rules of internal labor regulations.

With written agreement of the head of an SPFM or a person performing his duties, an inspection may be conducted during non-working hours of an SPFM.

11. For the conduct of an on-site inspection, the Commission forms a working group and appoints a head from among its members.

The minimum composition of the working group of the Commission for an on-site inspection must consist of two persons among the officials of the Commission.

12. An official of the Commission cannot be included in the composition of a working group in the presence of a potential or real conflict of interest.

An official of the Commission included in the composition of a working group must notify the Chairman of the Commission in writing about the absence of a conflict of interest.

13. An off-site inspection is conducted in the premises of the Commission based on documents, information and explanations obtained from an SPFM upon Request (Appendix 2) necessary for conducting an off-site inspection.

A Request is оформлен as a letter of the Commission and signed by a member of the Commission.

The term of conduct of an off-site inspection cannot exceed 65 working days from the day of its start, defined in the resolution of the Commission on conducting an inspection.

An inspection may be completed earlier than the term indicated in the resolution of the Commission on conducting an inspection.

An off-site inspection may be conducted by one authorized person.

14. Requirements for officials of the Commission included in the composition of the working group of the Commission for conducting an on-site inspection, defined in paragraph 12 of this section, apply to the authorized person(s) conducting an off-site inspection.

15. In case of necessity to change after the start of an on-site inspection / off-site inspection the head or members of the working group / authorized person(s) conducting an off-site inspection, other information specified in the resolution of the Commission on conducting an inspection, the resolution of the Commission on conducting an inspection is amended accordingly. The resolution of the Commission on amendments to the resolution of the Commission on conducting an inspection is sent to the SPFM with a cover letter of the Commission.

16. For the purpose of conducting off-site supervision over compliance with the requirements of legislation in the field of prevention and counteraction, the Commission sends a Request to an SPFM for obtaining documents, information and written explanations (Appendix 3) based on:

1. analysis of reporting data and other information submitted to the Commission in accordance with requirements defined by normative legal acts of the Commission;
2. analysis of information, documents (copies and/or extracts from them) in electronic or paper form, reports obtained from an SPFM;
3. analysis of information and documents obtained from structural subdivisions of the Commission, SPFMs, other state authorities, as well as other information and documents obtained by the Commission during the performance of its functions;
4. verification of the fulfillment by an SPFM of the Commission's requirements regarding elimination of violations of the requirements of legislation in the field of prevention and counteraction.

A Request is оформлен as a letter of the Commission, signed by a member of the Commission in accordance with the distribution of responsibilities for ensuring the fulfillment of tasks assigned to the Commission in the corresponding area of work.

Application of influence measures based on signs of violations discovered during the processing of documents, information and explanations obtained upon Request is carried out in the order established by the Commission.

III. Rights and Duties of the Working Group

1. The head and members of the working group during the conduct of an on-site inspection have the right:

1. free access to the premises of an SPFM upon official identification and access to documents and other materials necessary for conducting an inspection;
2. to receive free of charge from an SPFM any information, materials, documents (copies and/or extracts from them, on specified carriers of such information, with a cover letter), explanations / written explanations regarding its activity, to receive copies of documents confirming / which may confirm violations of legislative requirements, certified in the established order;
3. to use technical means, computers and other electronic information carriers, software, copying machines, scanners, telephones necessary for conducting an on-site inspection and organizing the activity of the working group, to bring into and take out of the premises of an SPFM technical and software means belonging to the Commission;
4. to coordinate organizational issues regarding the conduct of an inspection with an SPFM;
5. to appeal to law enforcement agencies in the presence of a real threat to the life, health of the head and members of the working group or property of the working group, application of violence against the head and members of the working group;
6. to exercise other powers provided by law.

2. The head and members of the working group during the conduct of an on-site inspection are obliged:

1. to comply with the requirements of the legislation of Ukraine;
2. to notify the head of an SPFM or a person performing his duties about the rights, duties and powers of the working group, the order of conduct, grounds and issues of inspection, rights, duties and responsibility of an SPFM, which is recorded in the Act of an on-site inspection;
3. to send Requests for obtaining documents, information and written explanations necessary for conducting an on-site inspection (Appendix 4), indicating the time and date of their submission. A Request is compiled in two copies in paper form and signed by the head of the working group;
4. to comply with the principles of ethical behavior of employees of the Commission.

3. The rights of the head and members of the working group defined in sub-paragraphs 2, 5 and 6 of paragraph 1 of this section apply to the authorized person(s) conducting an off-site inspection.

4. The head and members of the working group / authorized person(s) conducting an off-site inspection during the conduct of an on-site inspection / off-site inspection are independent, autonomous and act at their own discretion in accordance with the Constitution of Ukraine, laws of Ukraine and normative legal acts of the Commission.

Influence, pressure on the head and members of the working group / authorized person(s) conducting an off-site inspection, interference in their actions during an inspection by any persons is prohibited.

Officials of the Commission participating in the conduct of an inspection are obliged to notify the Chairman of the Commission about interference in their activity.

IV. Rights and Duties of the Subject of Primary Financial Monitoring, Its Officials

1. The head of an SPFM or a person performing his duties during the conduct of an on-site inspection has the right to receive information from the working group about:

1. order of conduct, grounds and issues of inspection;
2. rights and duties of the working group;
3. rights and duties of officials (authorized persons) of an SPFM.

2. The head of an SPFM or a person performing his duties during the conduct of an on-site inspection is obliged:

1. to admit the working group to the premises where an SPFM conducts its activity and to ensure for the period of conduct of an on-site inspection free entry / exit to/from the premises for each member of the working group throughout the entire working day, and if necessary – during non-working hours with agreement of the head of an SPFM or a person performing his duties;
2. to confirm the powers of the head of an SPFM or a person performing his duties with appropriate documents;
3. to provide the working group for the period of conduct of an on-site inspection a workplace in a separate service premises from employees of an SPFM and third parties and to ensure the possibility of using wireless access to the Internet (if available), copying and duplicating equipment;
4. to timely and in full volume provide (compile, certify) to the working group reliable information, documents, copies of documents (in which all written information can be read) or extracts from documents within the terms established by the Request for obtaining documents, information and written explanations;

10 explanations necessary for conducting an on-site inspection. Documents in response to these Requests are provided to the head of the working group with a cover letter indicating the list of provided documents and the date of their provision; 5) provide written explanations to the head of the working group; 6) not create obstacles for the performance of duties imposed on the head and members of the working group. 3. The head and employees of the SPFM do not have the right to exert any pressure on the head and members of the working group and to create obstacles or in any other way restrict their actions regarding the conduct of the inspection. 4. The head of the SPFM or the person performing his duties may appeal the actions of the members of the working group to the Chairman of the Commission. Filing an appeal does not stop the inspection. 5. The duties of the SPFM and its officials during the conduct of an on-site inspection, defined in subparagraphs 4, 5, and 6 of paragraph 2, paragraph 3 of this section, and the rights of the SPFM and its officials, defined in paragraph 4 of this section, apply to the SPFM and its officials during the conduct of an off-site inspection by the Commission. V. Procedure for conducting the inspection and documenting the results

1. During the conduct of an on-site inspection / off-site inspection, the working group / authorized person(s) conducting the off-site inspection, thoroughly studies, analyzes, and evaluates all necessary documents (including those with restricted access) related to the activities of the SPFM in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction.
2. The head of the working group / Commission during the conduct of an on-site inspection / off-site inspection has the right to receive additional materials and explanations from the SPFM in response to a Request of the head of the working group / Commission.
3. An Act on Obstruction in Conducting an On-Site Inspection (Appendix 5) is drawn up by the working group in the event of:

1. absence of the SPFM (separate subdivision) at the location specified in the document of state registration of a legal entity (temporary location, which the SPFM notified the Commission of, location specified in the certificate of structural subdivisions of the SPFM, which have a different location than the SPFM);

11 specified in the certificate of structural subdivisions of the SPFM, which have a different location than the SPFM); 2) denial of access to conduct the inspection, namely: denial by the head of the SPFM or the person performing his duties, other officials of the SPFM, of access to the premises of the SPFM for the working group; 3) creating obstacles for the working group in conducting the inspection, namely: absence of the head of the SPFM or the person performing his duties, at the location specified in the document of state registration of a legal entity (temporary location, which the SPFM notified the Commission of), for no less than three hours of the first and three hours of the second day of the working group's departure to conduct an on-site inspection; 4) failure by the SPFM to provide any documents (information) in response to a Request of the head of the working group, in the absence of signs defined in subparagraph 2 of paragraph 4 of this section, which led to the impossibility of conducting the inspection. 4. An Act on the Impossibility of Conducting an On-Site Inspection (Appendix 6) is drawn up by the working group in the event of:

1. impossibility for the working group, for no less than three hours of the first and three hours of the second day of departure for inspection, to enter the premises of the SPFM due to circumstances not related to the actions of the SPFM;
2. absence of any documents necessary for conducting the inspection, under force majeure circumstances established by the second part of Article 141 of the Law of Ukraine "On Chambers of Commerce and Industry in Ukraine".

5. Based on the results of the on-site inspection and the provision by the SPFM of all or part of the available documents (information) of the SPFM, the working group draws up an Act of a planned / unplanned on-site inspection of compliance with the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction (hereinafter – Act of on-site inspection) in the established form (Appendix 7) in the form of an electronic document, which is signed by the head and members of the working group no later than the end date of the inspection specified in the Commission's resolution on conducting the inspection.
6. Based on the results of the off-site inspection and the provision by the SPFM of all or part of the available documents (information) of the SPFM, the authorized person(s) who conducted the off-site inspection draws up an Act of a planned / unplanned off-site inspection of compliance with the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction (hereinafter – Act of off-site inspection) in the established form (Appendix 8) in the form of an electronic document, which is signed by the authorized person(s) who conducted the off-site inspection, no later than the end date of the inspection specified in the Commission's resolution on conducting the inspection.
7. In the event that the SPFM fails to provide any documents (information) in response to a Request of the authorized person(s) conducting the off-site inspection, provided there is information about the receipt of the Request, which led to the impossibility of conducting the inspection, an Act on Obstruction in Conducting an Off-Site Inspection (Appendix 5) is drawn up.
8. In the event of loss by the SPFM of documents necessary for conducting an off-site inspection, under force majeure circumstances established by the second part of Article 141 of the Law of Ukraine "On Chambers of Commerce and Industry in Ukraine", the authorized person(s) conducting the off-site inspection draws up an Act on the Impossibility of Conducting an Off-Site Inspection (Appendix 6).
9. In the event that the SPFM provides documents not in full volume, provides inaccurate information (documents), provides copies of documents in which it is impossible to read all the information indicated in them, in response to a Request of the head of the working group / Commission, a record is made in the Act of on-site inspection / Act of off-site inspection, and an explanation from the head of the SPFM, or the person performing his duties, regarding the specified facts is attached.
10. The Act of on-site inspection / Act of off-site inspection sets out all circumstances and facts revealed during the inspection that indicate signs of violation in the activities of the primary financial monitoring subject regarding legislation in the field of prevention and counteraction. In the event that the primary financial monitoring subject eliminates deficiencies in the activities of the primary financial monitoring subject revealed by the working group / authorized person(s) conducting the inspection during the conduct of the inspection, corresponding records are made in the Act of on-site inspection / Act of off-site inspection.
11. It is not allowed to include assumptions and facts not confirmed by documents in the Act of on-site inspection / Act of off-site inspection.
12. Within five working days from the date of signing the Act on Obstruction in Conducting an On-Site Inspection / Off-Site Inspection / Act on the Impossibility of Conducting an On-Site Inspection / Off-Site Inspection / Act of On-Site Inspection / Act of Off-Site Inspection in the form of an electronic document, the Commission sends the SPFM the corresponding act via the CIS along with a cover letter signed by a member of the Commission. In the event of impossibility of sending the SPFM the Act on Obstruction in Conducting an On-Site Inspection / Off-Site Inspection / Act on the Impossibility of Conducting an On-Site Inspection / Off-Site Inspection / Act of On-Site Inspection / Act of Off-Site Inspection in the form of an electronic document, the Commission sends the SPFM a paper copy of the corresponding electronic document, certified in the manner established by the legislation of Ukraine, via postal communication (with notification of delivery) along with a cover letter signed by a member of the Commission.
13. Any corrections and additions to the Act on Obstruction in Conducting an On-Site Inspection / Off-Site Inspection / Act on the Impossibility of Conducting an On-Site Inspection / Off-Site Inspection / Act of On-Site Inspection / Act of Off-Site Inspection after its signing are not allowed. Upon discovery of typos after signing the corresponding act, the SPFM is notified in writing.
14. To the copy of the Act of on-site inspection / Act of off-site inspection kept in the Commission, inspection materials are attached – copies of documents (extracts from documents, certified by the primary financial monitoring subject), explanations, and other documents according to the list specified in the Act of on-site inspection / Act of off-site inspection, which confirm the conclusions of the inspection act on the issues inspected and/or the presence of signs of violations of legislation in the field of prevention and counteraction.
15. The Act of on-site inspection / Act of off-site inspection and inspection materials regarding compliance with the requirements of legislation in the field of prevention and counteraction are not subject to transfer to legal and natural persons, as well as other state authorities, except for cases provided for by legislation. Information contained in these documents is not subject to disclosure by Commission officials who became aware of it.
16. A copy of the Act of on-site inspection / Act of off-site inspection is sent via the system of electronic interaction of executive bodies of the State Financial Monitoring Service, if its employee participated in conducting the inspection.
17. The SPFM within five working days from the date of receipt of the Act on Obstruction in Conducting an On-Site Inspection / Off-Site Inspection / Act on the Impossibility of Conducting an On-Site Inspection / Off-Site Inspection / Act of On-Site

13 inspection / Act of Off-Site Inspection has the right to submit written remarks to the corresponding act using the means of the CIS. Written remarks to the Act on Obstruction in Conducting an On-Site Inspection / Off-Site Inspection / Act on the Impossibility of Conducting an On-Site Inspection / Off-Site Inspection / Act of On-Site Inspection / Act of Off-Site Inspection, along with their documentary confirmation, are an integral part of the corresponding act. 18. The Act on Obstruction in Conducting an On-Site Inspection / Off-Site Inspection / Act on the Impossibility of Conducting an On-Site Inspection / Off-Site Inspection / Act of On-Site Inspection / Act of Off-Site Inspection, which was sent to the SPFM, is considered brought to the attention of the SPFM and without remarks, in the event of non-receipt by the Commission of written remarks within 15 working days from the date of sending the corresponding act by the Commission. 19. The Act on Obstruction in Conducting an On-Site Inspection / Off-Site Inspection / Act on the Impossibility of Conducting an On-Site Inspection / Off-Site Inspection / Act of On-Site Inspection / Act of Off-Site Inspection is kept in the Commission and is the basis for it to make appropriate decisions within the powers provided by law. 20. The application of influence measures based on the results of revealed signs of violations during the conduct of an on-site inspection / off-site inspection is carried out in the manner established by the Commission. Director of the Department of Financial Monitoring and Inspection Conducting Oleh MISYURA

NATIONAL COMMISSION ON SECURITIES AND STOCK MARKET R E S O L U T I O N Kyiv On Conducting an Inspection

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(name of SPFM) In accordance with the first and second paragraphs of the second part of Article 18 of the Law of Ukraine "On Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained Criminally, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction", the Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained Criminally, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction by Primary Financial Monitoring Subjects, whose state regulation and supervision of activities is carried out by the National Commission on Securities and Stock Market, The National Commission on Securities and Stock Market R E S O L V E S :

1. Conduct within the period from ""________ to ""_________ _________________ an inspection __________________________________________ Appendix 1 to the Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained Criminally, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction by Primary Financial Monitoring Subjects, whose State Regulation and Supervision of Activities is Carried out by the National Commission on Securities and Stock Market (point 1 of Section II)

2 Continuation of Appendix 1 (planned / unplanned) (full name of the primary financial monitoring subject,

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identification code of the legal entity in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations) regarding compliance with the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction. 2. For the conduct of an on-site inspection, create a working group in the composition: ____________________________________________ - head of the working group (position, surname, first name, and patronymic (if any)) ____________________________________________ - member of the working group (position, surname, first name, and patronymic (if any)) 3. For the conduct of an off-site inspection, appoint authorized persons (person):

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(position, surname, first name, and patronymic (if any))

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(position, surname, first name, and patronymic (if any)) 4. Determine the grounds for conducting the inspection __________________________

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(plan-schedule for planned inspection / grounds defined in point 7 of Section II of this Procedure, for unplanned inspection) 5. Approve the period of activity for which the inspection is conducted (for planned inspection) and the list of inspection questions __________________________

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6. Establish legal protection measures for the person regarding whom the inspection is conducted:

1. appeal the actions of the members of the working group to the Chairman of the Commission;
2. receive information from the working group regarding the procedure for conducting the inspection;
3. provide oral and written explanations.

3 Continuation of Appendix 1 7. Inform the person regarding whom the inspection is conducted about the establishment by legislation of liability for obstructing the subject of state financial monitoring in the exercise of its supervision in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction, including denial of access to conduct an inspection on issues of compliance with the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction, creating obstacles in its conduct and/or failure to provide, providing not in full volume, providing inaccurate information / documents, providing copies of documents in which it is impossible to read all the information indicated in them, in response to a request of the subject of state financial monitoring, necessary for the exercise of its supervision in the field of prevention and counteraction. The head of the working group / authorized person conducting the off-site inspection, by ""______, ensure sending __________________________________________________________ (full name of the primary financial monitoring subject) notification of conducting the inspection. 8. Control over the execution of this resolution is entrusted to _________________ Chairman of the Commission First Name SURNAME Protocol of the Commission Meeting from ___________ No. ____

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Appendix 2 to the Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds, Obtained Criminally, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction by Primary Financial Monitoring Subjects, whose State Regulation and Supervision of Activities is Carried out by the National Commission on Securities and Stock Market (point 13 of Section II) On the letterhead of the National Commission on Securities and Stock Market

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(name of SPFM) Request for obtaining documents, information, and written explanations necessary for conducting an off-site inspection Based on the Commission's resolution on conducting the inspection,

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(date, number of resolution) I demand by "____" ____________ 20__ year to provide for the inspection of compliance with the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction duly certified copies of such documents or information contained in them:

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Member of the Commission First Name SURNAME

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Appendix 3 to the Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds, Obtained Criminally, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction by Primary Financial Monitoring Subjects, whose State Regulation and Supervision of Activities is Carried out by the National Commission on Securities and Stock Market (point 16 of Section II) On the letterhead of the National Commission on Securities and Stock Market

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(name of SPFM) Request for obtaining documents, information, and written explanations necessary for conducting off-site supervision Based on subparagraph _____ of point 16 of Section II of the Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained Criminally, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction by Primary Financial Monitoring Subjects, whose State Regulation and Supervision of Activities is Carried out by the National Commission on Securities and Stock Market, I demand by "____" ____________ 20__ year to provide for conducting supervision over compliance with the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction duly certified copies of such documents or information contained in them: Member of the Commission First Name SURNAME

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Appendix 4 to the Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained Criminally, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction by Primary Financial Monitoring Subjects, Whose State Regulation and Supervision of Activities is Carried out by the National Commission on Securities and Stock Market (subparagraph 3 of point 2 of Section III) NATIONAL COMMISSION ON SECURITIES AND STOCK MARKET "_" ____________ 20 year To the Head of _________________________ Location

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Request for obtaining documents, information, and written explanations necessary for conducting an on-site inspection I, ____________________________________________________________________________________ (surname, first name, and patronymic (if any)) head of the working group for inspecting compliance with the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction __________________________________________________________________________

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(name of the primary financial monitoring subject, identification code of the legal entity in the Unified State Register of Legal Entities, Individual Entrepreneurs, and Public Formations) based on the Commission's resolution on conducting the inspection

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(date, number of resolution) I demand by ___ o'clock "_" ____________ 20 year to provide for the inspection of compliance with the requirements of legislation in the field of prevention and counteraction to legalization (money laundering) of proceeds obtained criminally, terrorist financing, and financing of the proliferation of weapons of mass destruction such materials:

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2 Continuation of Appendix 4 Head of the Working Group First Name SURNAME

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Appendix 5 to the Procedure for Conducting Supervision over Compliance with the Requirements of Legislation in the Field of Prevention and Counteraction to Legalization (Money Laundering) of Proceeds Obtained Criminally, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction by Primary Financial Monitoring Subjects, Whose State Regulation and Supervision of Activities is Carried out by the National Commission on Securities and Stock Market (points 3, 7 of Section V) NATIONAL COMMISSION ON SECURITIES AND STOCK MARKET Act on Obstruction in Conducting an On-Site Inspection / Off-Site Inspection

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(name of the primary financial monitoring subject, identification code of the legal entity in the Unified State Register of Enterprises and Organizations of Ukraine) city __________________ "____" _________________ 20__ year Based on the Commission's resolution on conducting the inspection

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(date, number of resolution) by the working group in the composition / authorized person(s) who conducted the inspection:

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(position, surname, first name, and patronymic (if any)) upon departure for inspection of the primary financial monitoring subject (location is indicated), upon conducting an off-site inspection (facts of obstruction in conducting the inspection are indicated) established:

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(brief description of the circumstances of obstruction in conducting the inspection, in accordance with points 3, 7 of Section V of this Procedure) Head of the Working Group / authorized person who conducted the inspection First Name SURNAME

2 Continuation of Appendix 5 Member of the Working Group / authorized person who conducted the inspection First Name SURNAME

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NATIONAL COMMISSION FOR SECURITIES AND STOCK MARKET Act on the impossibility of conducting an on-site inspection / off-site inspection City __________________ "____" ____________ 20__ year

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(name of the primary financial monitoring subject, identification code of the legal entity in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations) Based on the Commission's resolution on conducting an inspection _____________________________________________________________________________________________________________________, (date, number of the Commission's resolution on conducting an inspection) The working group consisting of / authorized person(s), who conducted the inspection: _____________________________________________________________________________________________________________________, (position, surname, first name and patronymic (if available)) upon arriving at the inspection of the primary financial monitoring subject (location is indicated), upon conducting an off-site inspection (facts of obstruction to the inspection are indicated) it was established:

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(brief summary of the circumstances making the inspection impossible, in accordance with paragraphs 4, 8 of Section V of this Procedure) Head of the working group / authorized person who conducted the inspection First Name SURNAME

Appendix 6 to the Procedure for carrying out supervision over compliance with the requirements of legislation in the field of prevention and counteraction to legalization (laundering) of income obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction by primary financial monitoring subjects, state regulation and supervision of activities of which is carried out by the National Commission for Securities and Stock Market (paragraphs 4, 8 of Section V)

2 Continuation of Appendix 6 Member of the working group / authorized person who conducted the inspection First Name SURNAME

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Appendix 7 to the Procedure for carrying out supervision over compliance with the requirements of legislation in the field of prevention and counteraction to legalization (laundering) of income obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction by primary financial monitoring subjects, state regulation and supervision of activities of which is carried out by the National Commission for Securities and Stock Market (paragraph 5 of Section V) NATIONAL COMMISSION FOR SECURITIES AND STOCK MARKET Act of planned / unscheduled on-site inspection of compliance with the requirements of legislation in the field of prevention and counteraction to legalization (laundering) of income obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction ___________________________________________________________________________________________________________________, (full name of the primary financial monitoring subject) City __________________ "" ____________ 20 year

1. Introductory part Type of inspection:

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(planned / unscheduled on-site) Inspection period: from "" ________ 20 year to "" _______ 20 year. Location where the inspection was conducted:

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(postal index, city, district, region, street, building number) Identification code of the legal entity in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations:

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Bank details: _____________________________________________________ Contact information: _____________________________________________________________ (telephone, email address)

2 Continuation of Appendix 7 The inspection was conducted by a working group consisting of: Group leader ___________________________________________________________________

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(position, surname, first name and patronymic (if available)) Group members _____________________________________________________________________ (position, surname, first name and patronymic (if available)) Grounds for conducting the inspection

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(date, number of the Commission's resolution on conducting an inspection) The on-site inspection was conducted in the presence of officials of the primary financial monitoring subject:

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(position, surname, first name and patronymic (if available))

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(position, surname, first name and patronymic (if available)) 2. General part List of questions checked: 1.________________________________________________________________________ 2. ____________________________________________________________________________________ Period of activity of the primary financial monitoring subject for which the inspection was conducted: from "" ____________ 20 year to "" ____________ 20 year (in case of conducting a planned inspection). Data on the state registration of the primary financial monitoring subject:

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(date, number of issuance, by whom issued) Information about the head or person performing his duties:

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Information about the employee responsible for conducting financial monitoring:

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Information about the structural subdivisions of the primary financial monitoring subject:

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3 Continuation of Appendix 7 3. Descriptive part During the inspection of compliance with the requirements of legislation in the field of prevention and counteraction to legalization (laundering) of income obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction it was established:

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(brief description of the questions checked, in case of establishing signs of a violation, a detailed description of the signs of the violation is carried out, facts of obstruction to the inspection are indicated (if any)) 4. Conclusions Identified signs of violation of legislation in the field of prevention and counteraction to legalization (laundering) of income obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction: No. Identified signs of violation Subparagraph, paragraph, article, section, chapter etc. Regulatory legal act 1 2 List of inspection materials confirming the signs of violation, attached to the On-site Inspection Act: No. Document Name Document details Number of pages 1 2 Head of the working group First Name SURNAME Member of the working group First Name SURNAME

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NATIONAL COMMISSION FOR SECURITIES AND STOCK MARKET Act of planned / unscheduled off-site inspection of compliance with the requirements of legislation in the field of prevention and counteraction to legalization (laundering) of income obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction ___________________________________________________________________________________________________________________, (full name of the primary financial monitoring subject) City __________________ "" ____________ 20 year

1. Introductory part Type of inspection: ____________________________________________________________________ (planned / unscheduled off-site) Inspection period: from "" ________ 20 year to "" _______ 20 year. Identification code of the legal entity in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations:

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Bank details: ________________________________________________________________ Contact information: _____________________________________________________________________ (telephone, email address) Person(s) who conducted the inspection

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(position, surname, first name and patronymic (if available)) Appendix 8 to the Procedure for carrying out supervision over compliance with the requirements of legislation in the field of prevention and counteraction to legalization (laundering) of income obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction by primary financial monitoring subjects, state regulation and supervision of activities of which is carried out by the National Commission for Securities and Stock Market (paragraph 6 of Section V)

2 Continuation of Appendix 8

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(position, surname, first name and patronymic (if available)) Grounds for conducting the inspection:

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(date, number of the Commission's resolution on conducting an inspection and grounds in accordance with paragraphs 2 and 7 of Section II of the Procedure carrying out supervision over compliance with the requirements of legislation in the field of prevention and counteraction to legalization (laundering) of income, obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction by primary financial monitoring subjects, state regulation and supervision of activities of which is carried out by the National Commission for Securities and Stock Market) List of materials, documents etc., received by the Commission upon Request, on the basis of which the inspection was conducted: No. Document Name Document details Number of pages 1 2 2. General part List of questions checked: 1.__________________________________________________________________ 2.___________________________________________________________________ Period of activity of the primary financial monitoring subject for which the inspection was conducted: from "" ____________ 20 year to "" ____________ 20 year (in case of conducting a planned inspection). Data on the state registration of the primary financial monitoring subject:

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(date, number of issuance, by whom issued) Information about the head or person performing his duties:

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Information about the employee responsible for conducting financial monitoring:

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Information about the structural subdivisions of the primary financial monitoring subject

3 Continuation of Appendix 8

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3. Descriptive part During the inspection of compliance with the requirements of legislation in the field of prevention and counteraction to legalization (laundering) of income obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction it was established:

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(brief description of the questions checked, in case of establishing signs of a violation, a detailed description of the signs of the violation is carried out, facts of obstruction to the inspection are indicated (if any)) 4. Conclusions Identified signs of violation of legislation in the field of prevention and counteraction to legalization (laundering) of income obtained by criminal means, financing terrorism and financing the proliferation of weapons of mass destruction: No. Identified signs of violation Subparagraph, paragraph, article, section, chapter etc. Regulatory legal act 1 2 List of off-site inspection materials confirming the signs of violation, attached to the Off-site Inspection Act: No. Document Name Document details Number of pages 1 2 Authorized person who conducted the inspection First Name SURNAME Authorized person who conducted the inspection First Name SURNAME

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