1. Introduction

NUMAPAY S.R.L. is committed to preventing money laundering, terrorist financing, and other forms of financial crime. The Company applies a zero-tolerance approach to any misuse of its services for illegal purposes and operates in full compliance with applicable Romanian, European Union, and international AML/CTF regulations.

NUMAPAY S.R.L. is supervised by the National Office for the Prevention and Combating of Money Laundering (ONPCSB) and qualifies as a reporting entity under Romanian law.

2. Definitions and abbreviations

The Company’s AML/CTF framework is based on, inter alia:

Romanian Law No. 129/2019 on the prevention and combating of money laundering and terrorist financing;
Government Emergency Ordinance No. 111/2020;
Applicable EU AML Directives;
Recommendations and guidance issued by the Financial Action Task Force (FATF);
International sanctions regimes imposed by the EU, UN, and other competent authorities.

3. Risk-Based Approach

NUMAPAY S.R.L. applies a risk-based approach to AML/CTF compliance. Customers, transactions, products, and jurisdictions are assessed to identify and mitigate potential risks of money laundering or terrorist financing.

Where higher risks are identified, enhanced due diligence and additional controls are applied.

4. Customer Due Diligence

The Company conducts customer due diligence procedures to verify the identity of its customers and, where applicable, their beneficial owners. This includes:

Identification and verification of customers prior to establishing a business relationship;
Understanding the purpose and intended nature of the relationship;
Ongoing monitoring of customer activity.

NUMAPAY S.R.L. reserves the right to refuse or terminate a business relationship if required due diligence cannot be completed or if AML/CTF risks are deemed unacceptable.

5. Politically Exposed Persons

Customers who are identified as Politically Exposed Persons, or who are related to or closely associated with PEPs, are subject to enhanced scrutiny and additional due diligence measures in accordance with applicable laws and regulations.

6. Sanctions Compliance

NUMAPAY S.R.L. screens customers and transactions against applicable international sanctions lists. The Company does not provide services to sanctioned individuals or entities, and any transactions involving sanctioned persons are prohibited.

7. Transaction Monitoring and Reporting

The Company monitors customer activity on an ongoing basis to identify unusual or suspicious behavior. Where required by law, suspicious transactions are reported to the competent authorities.

NUMAPAY S.R.L. cooperates fully with supervisory and law enforcement authorities in the prevention and detection of financial crime.

8. Record Keeping

In accordance with legal requirements, the Company maintains appropriate records related to customer due diligence, transactions, and AML/CTF compliance for the legally prescribed retention periods.

9. Training and Awareness

NUMAPAY S.R.L. ensures that relevant personnel receive appropriate AML/CTF training and maintain awareness of applicable legal obligations and emerging risks.

10. Updates

This AML/CTF Policy may be updated from time to time to reflect changes in applicable laws, regulations, or the Company’s risk profile.