AML/CFT and supervision

Legal status

As a payment organisation and a payment system operator licensed by the National Bank, MONTRA falls within the scope of the law of the Kyrgyz Republic on countering the financing of terrorism and the legalisation (laundering) of criminal proceeds. It requires client identification, transaction monitoring, record keeping and reporting to the competent authority.

• Payment system operator · № 2069290126
• Payment organisation · № 3071290126

Internal AML/CFT policy

The company maintains an approved internal policy covering every service it provides. An officer responsible for its implementation — the compliance officer — is appointed; staff are trained, and the policy is reviewed when the law changes and periodically.

The policy itself is an internal document and is not published: it contains the monitoring criteria.

Client identification at onboarding

Before a contract is signed we establish and verify:

• the registration details of the legal entity or sole trader and its actual address;
• the identity and authority of the director or of a representative acting under a power of attorney;
• the beneficial owners — holders above the statutory ownership threshold and persons who actually control the company;
• the actual line of business, the website, and what the goods and services are;
• that the business is not in the restricted list;
• that any licences or permits the activity requires are held;

The information must stay current for the whole term of the contract: the client notifies us of changes, and we refresh the documents periodically.

Business types we do not onboard

Sanctions screening

The client, its director and its beneficial owners are screened at onboarding and periodically afterwards — against the lists applied in the Kyrgyz Republic and against international sanctions lists relevant to the transactions. Where a match is found, onboarding is refused or service is discontinued.

Transaction monitoring

Transactions are checked by automated rules and by human analysis. Transactions showing signs of suspicion are reviewed separately and, in the cases the law provides for, reported to the competent authority.

The right to suspend a transaction and request documents

The law and the contract give us the right to:

• suspend a transaction or the client’s service for the duration of a check;
• request additional documents and explanations about the transaction and the source of funds;
• refuse to carry out a transaction and, where the law provides, terminate the contract;
• pass information to the competent authority in the cases established by law.

The law limits what we may tell the client: the fact that information has been passed to the competent authority, and the monitoring parameters, are not disclosed. That is why in some cases the reason is given only in general terms — a legal requirement, not indifference from support.

What we do not disclose

Monitoring scenarios, thresholds, the list of suspicion indicators and the names of the tools in use are not published. A published criterion stops working the same day, so this limitation is deliberate.

Supervision

The company’s activity is supervised along two lines:

the competent state authority in this area (the financial intelligence unit)

Providing the information the law requires, answering requests, and inspection of AML/CFT compliance.

National Bank of the Kyrgyz Republic

Supervision of licence conditions, reporting and inspections.

Contacting compliance

Questions can be sent to the compliance officer. We do not publish employees’ names or photographs: that would create a target for social engineering.

Compliance officer contact: compliance@montra.kg

Related pages

Security · Business types we do not onboard · Licences · Enquiries, claims and disputes