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TWINNING INTERIM QUARTERLY REPORT

TWINNING INTERIM QUARTERLY REPORT number: 3

EUROPEAN COMMISSION

TWINNING PROJECTSINTERIM QUARTERLY REPORT

Project Title: Development and consolidation of the National Commission for Financial Markets’ operational and institutional capacities in the field of prudential regulation and supervision.Partners: The National Commission for Financial Markets

of the Republic of Moldova (CNPF) The Polish Financial Supervision Authority (KNF)Date: June 2016

Twinning Contract number: Moldova - ENI/2015/363-321

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General instructions

1. Overview

The Interim Quarterly Report/Final Report for the project comprises the following parts:

Section 1 Basic data on the project Section 2 Content: progress achieved in the implementation of the Twinning project during the reporting period and

schedule for the remaining periodSection 3 Expenditure: actual expenditure in relation to budgeted expenditure

2. General guidance

Throughout the entire Twinning project, at three-monthly intervals starting with the date of notification of endorsement / signature, the Project leaders may prepare Interim Quarterly Reports/Final Reports.

Interim Quarterly Reports/Final Reports cover both substance and Finances. The deadline for submission of the Interim Quarterly Reports/Final Reports cannot be altered – The first interim quarterly

report will most often refer to less than three months’ actual project implementation, since the arrival of the RTA in the BC and the beginning of the work schedule rarely coincide with the date of notification.

The MS Project Leader in co-operation with the BC Project Leader will submit, within the month following each quarter, the interim quarterly reports to the concerned authority (see 6.4 of the Twinning manual).

One copy of the Report must be sent at the same moment to the relevant Twinning Team in the Commission Headquarters The Report must be submitted in one of the following three languages: English, French and/or German.

3. Notice

The approval of the Report by the relevant authorities is without prejudice to the Commission's right to suspend the activities of a project, terminate an agreement or take any other appropriate step should subsequent verifications reveal problems or significant divergences from the work plan, the budget or the conditions of the Twinning Contract as approved.

The views expressed in this report do not necessarily reflect the views of the European Commission

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Section 1: Project data

Twinning Contract Number ENI/2015/363-321

Project Title: Development and consolidation of the National Commission for Financial Markets’ operational and institutional capacities in the field of prudential regulation and supervision.

Twinning Partners (MS and BC) MS: Polish Financial Supervision Authority (KNF)

BC: National Commission for Financial Markets of the Republic of Moldova (NCFM)

Report Number: 3

Period covered by the report: 12 February 2016 – 11 May 2016

Duration of the project: 12 August 2015 – 11 November 2017

Rapporteur: Prepared by:

Joanna Lipowczan, Project Manager from the Polish Financial Supervision Authority

Grzegorz Wąsik, Resident Twinning Adviser from the Polish Financial Supervision Authority

Approved by:

Damian Jaworski, Project Leader from the Polish Financial Supervision Authority

Iurie Filip, Project Leader from the National Commission for Financial Markets of the Republic of Moldova

MS signature:

MS signature and date (i.e. MS Project Leader, Mr. Damian Jaworski): ……………………………

MS signature and date (i.e. MS Project Manager, Mrs. Joanna Lipowczan): .................................

RTA signature and date (i.e. MS RTA, Mr. Grzegorz Wąsik): ........................................................

BC signature:

BC signature and date (i.e. BC Project Leader, Mr. Iurie Filip): ……..............................................

RTA counterpart and date (i.e. BC RTA counterpart, Mrs. Veronica Cuhal): .................................

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Section 2: Content

This section describes the activities of the project. It is divided in five sections.

2A – BACKGROUND

2B – ACHIEVEMENT OF MANDATORY RESULTS

2C – ACTIVITIES IN THE REPORTING PERIOD

2D – TIMING AND DELAYS

2E – ASSESSMENT

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2A – BACKGROUNDThis report covers the activities that were carried out in the third quarter of the project, in the period of 12 February 2016 until 11 May 2016. This chapter comprises political developments directly linked to the subject of the project, the state of the achievement of project objectives and the state of project assumptions.

Overall objectives

Overall Objective and indicators of achievement (as in Logframe)

State of achievement/ problems encountered

Overall Objective: Development and implementation of the Risk Based Supervision System for the non-banking financial market participants, including capital market, insurance, pension funds and micro-finance based on the forecasting and evaluation of the risks and preventable consequences of some unfavourable events.Alignment with EU acquis and implementation of best practices of EU in regard to non-banking financial market supervision.

Development and implementation of the Risk Based Supervision System for the non-banking financial market participants, including capital market, insurance, pension funds and micro-finance based on the forecasting and evaluation of the risks and preventable consequences of some unfavourable events accomplished.

A better methodology and standards of supervision of the non-banking financial market including capital market, insurance, pension funds and micro-finance in Moldova will allow a more efficient and secure application of supervisory system based on the forecasting and evaluation of

All activities performed in the third project quarter were successfully implemented..

Within the reporting period the following project activities were implemented in line with the Twinning Work Plan and updated schedule, including: - the experts’ mission focused on the review of

on-site inspections methodology in regard to insurance sector (i.e. Activity No 1.11);

- the experts’ mission concerning the review of on-site and off-site inspections methodology in regard to pension sector (i.e. Activity No 1.12);

- the expert’s mission devoted to the review of on-site and off-site inspections methodology in regard to Anti-Money Laundering and combating the financing of terrorism (i.e. Activity No 1.13);

- the experts’ mission aimed at the review and assessment of supervisory powers in the field of non-banking financial market in regard to international cooperation and exchange of information (part 2) (i.e. Activity No 1.14);

- the experts’ mission concerning the support of Internal Audit on IT (i.e. Activity No 1.15);

- the expert’s mission focused on the support for Internal Audit (IA) and potential application of Public Internal Financial Control (PIFC) system (i.e. Activity 1.16);

- the study visit at the KNF for the NCFM employees (i.e. Activity 1.17);

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risks. A well-functioning non-banking financial market in Moldova will contribute to economic growth, poverty reduction and employment as well as overall security and stability of non-banking financial market participants.

- the experts’ mission focused on the review of regulations for capital market licensed entities (part 1) – in regard to investment firms (i.e. Activity 2.11);

- the experts’ mission focused on the review of regulations for capital market licensed entities (part 2) – in regard to capital market infrastructure: market operators, CSD, clearing and settlement houses, national securities depositary (i.e. Activity 2.12).

The above activities have contributed to achieving the overall project objectives and state a base for further project development.

Project purpose

Project purpose and indicators of achievement (as in Logframe) State of achievement/ problems encounteredProject purpose:Development and maintenance of an appropriate and effective regulatory and supervisory framework in accordance with the EU legislation and best practices to enable prudential regulation and supervision on the non-banking financial market.Strengthening operational and institutional capacities of the NCFM accomplished.

Development and maintenance of an appropriate and effective regulatory and supervisory framework in accordance with the EU legislation and best practices to enable prudential regulation and supervision in the field of:

1. capital market and investment funds sector;

2. insurance companies sector;

3. savings and credit associations and pension funds sector.

Activities implemented in the reporting period provided a contribution to the achievement of general project purpose.

During the third quarter of the project all activities of the Component 1 – Strengthening operational and institutional capacities of the NCFM have been successfully accomplished and the activities scheduled within the Component 2 of the project (Capital market and investment funds) have started. The achievement of project’s goals in whole is in progress.

The review of existing on–site inspections’ rules and documents in regard to insurance sector and on–site and off–site inspections rules and documents in regard to pension sector as well as anti-money laundering and combating the financing of terrorism (AML/CFT) matters was carried out. In consequence three Review reports with recommendations regarding the above mentioned subjects were developed. Moreover, presentations on inspection of insurance and pension sector were presented. The relevant Working papers

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with on-site inspection manual in respect to the AML/CFT were prepared.

As regards the international cooperation and exchange of information with foreign authorities on capital markets, the Guidelines on standards of efficient international cooperation and exchange of information with foreign counterparts were elaborated.

The presentation on the IT internal audit was presented and the Guidelines for conducting IT internal audit were drawn up.

Based on the review of existing Moldovan regulations, internal procedures and methodologies concerning the internal audit, the Review report with guidelines was elaborated. Additionally, the Handbook of the internal audit procedures and the Instruction for the functioning of the internal audit were prepared for the NCFM use.

The first study visit to Warsaw was organized by the KNF for the NCFM employees and two members of the Parliament of the Republic of Moldova. During the study visit the participants became familiar with the practical aspects of the non-banking financial market supervision in Poland.

The review of the Moldovan legislation with regard to certain aspects of investment firms’ organization and functioning was performed. The Gap analysis report with recommendation was prepared.

The Moldovan legislation concerning capital market infrastructure was reviewed and the relevant Recommendations were drawn up. The workshop on trading venues, depository system and clearing and settlement took place and related Workshop materials were elaborated and presented to the NCFM staff.

The input provided by the MS experts shall contribute to the establishment of a sound base to facilitate further efforts of the NCFM for development and maintenance of an appropriate and effective regulatory and supervisory framework in accordance with the EU legislation and best practices.

Thus, the NCFM capacities to regulate the non-banking financial market and strengthen its supervision functions in line with the EU acquis and best practices have started to increase.

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Policy DevelopmentsBased on the proposals and comments provided by the Polish experts on the NCFM supervisory powers in the field of non-banking financial market in regard to international cooperation and exchange of information, it has been amended the draft law on the National Commission for Financial Markets which shall be submitted to stakeholders for examination and public consultations. The amendments refer to legislative provisions in order to enable the NCFM to meet the generally accepted standards of international cooperation and exchange of information and to give the ability to require, to obtain and to provide information and documents from / to foreign authorities in line with legislation on domestic secrecy and confidential information.

During the reporting period by NCFM Decision nr.7/11 of 12.02.2016 and Ministry of Finance Resolution nr.61 of 05.05.2016 has been adopted the Regulation on information disclosure by issuers of securities.

Furthermore, based on the Polish experts proposals and comments received during public consultations, NCFM is finishing the draft Regulation on market abuse and draft Instruction on direct and indirect affiliation.

Project AssumptionsIn the reporting quarter the Twinning Project has provided the input for the use of the NCFM to fulfill the commitments of the Republic of Moldova stipulated in the former Partnership and Cooperation Agreement between the European Union and the Republic of Moldova, repealed and replaced by the Association Agreement between the European Union and the European Atomic Energy Community and their Member States, of the one part, and the Republic of Moldova, which is currently in force.

In particular, the Twinning Project has as main objective to contribute to the process of transition of the NCFM from compliance-based supervision to the establishment by the NCFM of the risk-based supervision for the three sectors of the non-banking financial market.

The undertaken activities will be subsequently continued and developed within the relevant project activities in line with the agreed in the Twinning Contract Work Plan.

2B - ACHIEVEMENT OF MANDATORY RESULTSResults and indicators of achievement (as in Logframe) State of achievement/ problems encounteredComponent 1 – Strengthening operational and institutional capacities of the NCFM.

Indicator of achievement (copied from logframe)

Within the reporting period the following successive project activities were performed in line with the Work Plan:

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Strengthening operational and institutional capacities of the NCFM accomplished.

Internal procedures/manuals/rules developed in line with the EU best practice.

Activity 1.11 Review of on-site inspections methodology in regard to insurance sector.

Benchmarks: Review of existing on-site inspections rules and documents in regard to insurance sector was performed.

State of achievement:Activity successfully completed and the result achieved.

During this Activity, the STEs presented the Polish approach to on–site inspections of insurance companies. The experts explained how the inspection is conducted by the KNF employees, what evidence they gather before and during the inspection and how the final inspection report is elaborated.

The STEs also reviewed the current binding Moldovan on–site inspection methodology in regard to insurance sector and held consultations with the relevant NCFM staff about the current practice used by the NCFM.

With regard to the assessed inspection methodology the STEs noted that the respective provisions of the Moldovan law largely appear to grant to the NCFM sufficient powers to conduct on-site inspections towards insurance sector participants.

In the experts’ opinion the NCFM appears to be granted with adequate and proportionate range of on-site inspection powers in order to perform its activity in a proper way.

However, the STEs suggested to grant the NCFM an additional power to conduct on-site inspections towards external entities performing insurance operations and activities for and on behalf of insurance undertakings (outsourcing providers). It was emphasized by the STEs that the abovementioned power for the insurance sector supervision authority is required by the Directive 2009/138/EC of the European Parliament and of the Council of 25 November 2009 on the taking-up and pursuit of the business of Insurance and Reinsurance (Solvency II). The STEs also advised the NCFM to establish a formal procedure regarding preparation of the on-site inspection plan. Both aspects are not formally

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regulated at present.

Detailed assessment and recommendations are provided in the Review report with recommendations prepared by the STEs.

Activity 1.12 Review of on-site and off-site inspections methodology in regard to pension sector.

Benchmarks: Review of existing on-site and off-site inspections rules and documents in regard to pension sector was performed.


During this mission the STEs delivered several detailed presentations on the pension sector in Poland, on-site and off-site inspection of pension funds, complaints handling, investment funds accounting and their asset valuation.

As a result of the review of the existing and planned (draft) legal acts concerning on-site and off-site inspections in the field of pension sector, the STEs elaborated the Review report with recommendations.

In drawing conclusions and drafting recommendations referring to inspection of the pension sector the STEs took into account the fact that an important legal act for the pension 3rd pillar of the pension sector in Moldova - the Law on voluntary pension funds, had been not approved by the Parliament at the given time and the fact that the pension funds’ market is not yet operational in practice.

The STEs’ review and assessment were performed with the consideration of the relevant provision of the EU legislation on the activity of the pension sector. In particular, the experts took into consideration the Directive 2003/41/EC of the European Parliament and of the Council of 3 June 2003 on the activities and supervision of institutions for occupational retirement provision.

In the STEs’ opinion, the binding legal acts and drafted Law on voluntary pension funds give sufficient powers

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to the NCFM to perform supervisory duties towards pension funds. The STEs also emphasized that the first stage of implementation of the supervision process of the pension funds should be based on a compliance approach. In the next stage of market development the gradual move to the risk-based approach should be considered.

Assuming further market development, the STEs presented the possible phases of the supervisory process to be considered by the NCFM in the future, e.g.: a development of a reporting system, a risk based approach and an adjustment of the IT tools.

Finally, the STEs also provided certain suggestions and comments regarding the pension funds’ reporting duties, handling of complaints, verification of the pension fund’s members register during an inspection and verification of the pension funds’ investment process.

Activity 1.13 Review of on-site and off-site inspections methodology in regard to Anti-Money Laundering and combating the financing of terrorism.

Benchmarks: Assessment of procedures and methodology used by the NCFM in regard to Anti-Money Laundering and combating the financing of terrorism was performed.


During the five-day mission of the STE, the review and assessment of procedures and methodology used by the NCFM in regard to Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) were performed.

The STE also presented the assumptions for the risk assessment in regard to Anti-Money Laundering and Combating the Financing of Terrorism within the requirements of the Recommendation 1 FATF (Financial Action Task Force).

The most important problems regarding inspections in regard to AML/CFT were analyzed by the STE as well.

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Conclusions of analysis with certain comments and suggestions deriving from that evaluation were presented in the Review report with recommendations. When drawing up the abovementioned report, the STE especially focused on the sufficient international cooperation and collaboration between the supervisor and the financial intelligence unit, a public awareness on the AML/CFT matters, the NCFM organization structure as well as an identification of the beneficial owner of financial institutions.

Additionally, the STE noticed that currently the NCFM uses a general on-site inspection methodology, which does not have a specific AML/CFT component to it. Therefore, the STE recommended the NCFM to create a separate AML/CFT on-site inspection methodology or include broad provisions on this subject in the currently existing methodology. A proposal for major issues which might be investigated during the on-site inspection was introduced in the Working paper elaborated within this Activity.

Activity 1.14 Review and assessment of supervisory powers in the field of non-banking financial market in regard to international cooperation and exchange of information (part 2).

Benchmarks: Assistance in drafting by-laws, rules and regulations as identified in the legal review, concerning sharing the experiences on international cooperation and exchange of information with foreign regulators was performed.


In the scope of this activity the STEs analysed the Law on capital market, the Law on the National Commission on Financial Markets, the draft Law on the National Commission on Financial Markets, as well as several other relevant acts, codes and regulations. In accordance with the gaps identified in the NCFM supervisory powers in the field of non-banking financial market during the previous mission within the same scope (i.e. Activity 1.5) they made recommendations concerning potential amendments to the legislation in order to enable the NCFM to meet

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the generally accepted standards of international cooperation and exchange of information. The results of the assessment of the Moldovan legislation on securities and supervisory practice of the NCFM held during the previous mission within the same scope (i.e. Activity 1.5) showed partial compliance of the legislation with the generally accepted standards of international cooperation and exchange of information.

During the Activity 1.14 the STEs elaborated the Guidelines on standards of efficient international cooperation and exchange of information with foreign counterparts. This document contains certain guidelines and recommendations on potential amendments to the existing and currently drafted legislation with respect to the following area of supervisory powers in the field of non-banking financial:

- the ability to obtain contemporaneous records sufficient to reconstruct all securities and derivatives transactions, including records of all funds and assets transferred into and out of bank and brokerage accounts relating to those transactions;- the ability to obtain records for securities and derivatives transactions;- the ability to obtain information located in the jurisdiction identifying persons who beneficially own or control non-natural persons organized in the jurisdiction;- the ability to take or compel a person’s statement, or, where permissible, testimony under oath;- the ability to provide information to foreign authorities;- the ability to provide to foreign authorities information in response to requests concerning particular aspects of the non-banking financial market;- the ability to provide assistance to a foreign authority, regardless of whether the NCFM has an independent interest in the matter;- the ability to require maintenance information and documents;- the domestic secrecy or blocking laws, rules and regulations that relate to the collection of information for, or provision to foreign authorities; - the specific or general provisions of the laws, rules and regulations which restrict or limit the uses of information and documents by foreign authorities;- the ability to ensure the confidentiality of information.

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Provided guidelines may facilitate the NCFM meeting the international standards on cooperation and exchange of information between authorities.

Activity 1.15 Support of Internal Audit on IT.

Benchmarks: Consultations and presentation of areas of the IT internal audits were performed and the guidelines for conducting IT internal audit (including e.g. main areas of IT audit, assessment of risks related to IT processes, methods for conducting IT audit) were drawn up.


At the beginning of this mission the STEs delivered the presentation on the IT internal audit and explained practical aspects associated with the internal audit in the IT area.

During the consultations with the NCFM staff, the STEs noticed that the NCFM has developed standards for planning and monitoring tasks, as a part of the internal IT audit processes; a tasks monitoring process is performed at an employee level; incidents and problems are reported on demand – on an individual basis; having a limited budget, the NCFM IT team monitors and supports almost all technologies used in the IT infrastructure with its own resources, performing at the same time tasks related to the internal IT audits; based on limited human resources, the IT team fulfills several auditing roles at the same time.

As a result of several meetings with the NCFM experts and internal analysis the STEs prepared the Guidelines for conducting IT internal audit. These guidelines were divided into four areas relating to:

- the planning and organization,- the acquisition and implementation,- the delivery and support,- the monitoring and evaluation.

For each individual guideline, experts proposed priorities and frequencies tailored to the specific characteristics and needs of the NCFM’s IT sector.

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The STEs emphasized that conducting internal audits within the IT plays a key role in improving the efficiency and effectiveness of every IT organization. A usage of proper methods of auditing may help in indicating places to improve services efficiency, avoiding failures as well as saving limited resources. It may also facilitate a building an appropriate development strategy and proper conduct of tasks and projects. The STEs pointed out that the NCFM IT team works in conditions of limited human resources and budget and over the past few years has created conditions for initiating the internal IT audit processes.

Finally, the STEs proposed to extend existing areas of IT internal audits to others, worth considering - depending on the needs and capabilities of the NCFM’s IT Team.

Activity 1.16 Support for Internal Audit (IA) and potential application of Public Internal Financial Control (PIFC) system.

Benchmarks: Review on law regulations and internal procedures, methodologies in the field of internal audit and in regard to compliance with the international standards was performed.


During this Activity the STE presented two presentations on the internal audit in the public sector in Poland and internal audit procedures and solutions applied in the KNF. Interactive consultations on essential principles for the efficient and effective internal audit compliant with international standards took place.

Furthermore, the STE took into consideration the fact that an internal audit within the NCFM has been restarted recently; therefore the NCFM has not yet elaborated and applied the detailed internal audit procedures necessary to ensure the performance of the internal audit activities in full compliance with the commonly recognized internal audit standards.

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As a result of this Activity the STE elaborated the Review report with guidelines.

The STE assessed the NCFM’s regulations and internal procedures, methodologies related to the internal audit against International Standards for the Professional Practice of Internal Auditing in the field of Purpose, Authority and Responsibility; Independence and Objectivity; Proficiency and Due Professional Care; Quality Assurance and Improvement Program; Managing the Internal Audit Activity; Nature of Work; Engagement Planning; Performing the Engagement; Communicating Results; Monitoring Progress; Communicating the Acceptance of Risks.

In the expert's opinion expressed in the report, relevant provisions of the Moldovan legislation appear to grant the NCFM sufficient powers to perform the internal audit. The STE has pointed out that in 2 fields the NCFM is generally compliant with the standards, while in 8 areas the NCFM complies with the standards partly and in one case the NCFM does not meet the standards.

In order to supplement the assessment provided in the report, the STE elaborated two additional documents, i.e. Instructions for the Functioning of the Internal Audit and Handbook of Internal Audit Procedures. These documents are based on the KNF experience and present how to implement the International Standards for the Professional Practice of Internal Auditing in practice.

Activity 1.17 Study Visit.

Benchmarks: Study visit organized by the KNF for the NCFM employees with the focus on practical aspect of non-banking financial market supervision took place.


All-in 9 NCFM employees and 2 Members of the Parliament of the Republic of Moldova participated in the study visit to the KNF.

The main objective of the study visit was to sum up the

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joint work done within the particular short-term experts’ missions which took place in Chisinau covering the Component 1 Strengthening operational and institutional capacities of the NCFM.

The study visit participants visited the main premises of the KNF and held several meetings with the Chairman of the KNF, Mr. Andrzej Jakubiak and the respective KNF experts from the Analyses and International Cooperation Department; Legal Department; Trading Surveillance Department; Investment Funds Department; Administration, Finance and IT Department and Insurance and Pension Inspection Department as well as Pension Investments Supervision Department.

The Study visit participants visited in addition the KNF’s secondary premises were operations center is located and there they visited the main server room as well as operations monitoring center.

During this study visit participants had an opportunity to learn practical aspects of work conducted by the KNF with respect to the subjects discussed during the experts’ missions in Chisinau (i.e. supervisory powers, international cooperation and exchange of information, market abuse matters, manipulation and insider transactions, IT systems and infrastructure, certain aspects of investment and pension funds supervision).

Additionally, upon the NCFM’s request, the KNF’s administrative decision process and proceedings, the catalog of penalties being imposed by the KNF, financing rules and the structure of the KNF’s budget were also presented by the Polish experts during the study visit.

Moreover, the meeting with Mr. Andrzej Jakubiak, the Chairman of the KNF, took place in order to familiarize the Moldovan participants with the selected strategic goals and challenges the Polish supervisor has been facing.

During the study visit the emphasis was put on the transfer of knowledge, know–how, experience, lessons learned from the good practices based on the EU legislation. Relevant modern EU supervisory standards were presented as well. The participants were able to discuss practical problems connected with non–banking financial market in Moldova with the KNF experts and receive advice and comments regarding supervisory or operational approach as well

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as further Moldovan legislation plans. Acquired knowledge and experience contributed to the development of the NCFM practice applied on the daily basis.

Moreover, the study visit participants visited the Polish Parliament and participated in meetings with the Chairman of the Economy and Development Committee, Mr. Jerzy Meysztowicz; the representatives of the EU Committee, Mr. Adam Abramowicz and Mr. Marcin Święcicki, and with the Chairman of the Public Finance Committee, Mr. Andrzej Jaworski.

As a result of this Activity the Study visit a report was elaborated by the participants.

Component 2 – Capital Market and Investment Funds.Indicator of achievement (copied from logframe)

Strengthening operational and institutional capacities of NCFM to supervise and regulate capital market and investment funds sector accomplished.

Within the reporting period the following successive project activities were performed in line with the Work Plan:

Activity 2.11 Review of regulations for capital market licensed entities (part 1) – in regard to investment firms.

Benchmarks: Review of Moldovan legislation and regulations for capital market licensed entities with regard to investment firms in accordance with the provisions of the EU legislation and regulations regarding capital requirements was performed.


In the light of the scope of this Activity, discussions over the EU law (i.e. MiFID Directive) and review of the Moldovan law (i.e. Regulation on licensing and authorisation, Law on capital market, Contravention Code, Law on NCFM) in regard to granting, suspension or withdrawal of authorisations, empowerment and penalties took place.

The STEs reviewed the Moldovan relevant legislation in order to draft the gap analysis report together with associated recommendations in the field of markets in financial instruments, especially including:

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1. investment firms - authorisation and operating conditions for investment firms, investor’s protection;

2. conditions and procedures for authorisation;3. operating conditions for investment firms

(conduct of business rules);4. organisational requirements.

In the elaborated Gap analysis report with recommendation, the STEs emphasised that the Moldovan legislation complies with the MiFID Directive and the MiFID Implementing Directive regime in several regulatory areas. It concerns in particular, the scope of authorisation, requirements for authorisation, conduct of business rules, conflicts of interest, standard of information provided to the clients and internal audit matters.

Moreover, the STEs identified a number of issues that require further clarification, enhancement and amendments to be fully compliant with the abovementioned EU laws, (i.e. the scope of the financial instrument definition, lack of provision on inducements, certain aspects associated with authorisation withdrawing). Detailed remarks, comments and recommendations are provided in the abovementioned Gap analysis. This analysis also contains the EU and Polish regulatory approaches, for instance the ESMA guidelines and experience that may facilitate drafting and implementation of the Moldovan legislation and further regulatory amendments to the currently binding legal framework.

In addition, having reviewed the Moldovan legal acts, the STEs identified some technical and legislation irregularities which may have a significant impact on the proper understanding and using of the Moldovan legislation in practice. The abovementioned irregularities are presented in the Gap analysis with recommendation.

Activity 2.12 Review of regulations for capital market licensed entities (part 2) – in regard to capital market infrastructure: market operators, CSD, clearing and settlement houses, national securities depository.

Benchmarks: Review of existing as well as planned Moldovan regulations concerning capital market infrastructure was performed.

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With reference to topics of this Activity, the STEs presented several presentations on depository house’s activity, clearing and settlement, market operators and supervision over capital market key infrastructure entities. They also reviewed the relevant Moldovan legal acts against corresponding provisions of the Directive 98/26/EC on settlement finality in payment and securities settlement systems and Regulation 648/2012 on OTC derivatives, central counterparties and trade repositories, together with delegated Regulations (the “EMIR”).

In drawing Recommendations, the Experts took also into account that the provisions concerning post-trading (e.g. central securities depository - CSD) will be soon significantly amended in the new law to be adopted by the Moldovan Parliament.

Recommendations presented by the STEs refer to market conditions for trading, sufficient liquidity on a market as well as clearing and settlement safety. The key recommendations relate particularly to the division of clearing and settlement as two separate functions, replacement of pre-funding concept with standard risk management tools and introduction of an improved trading system that will bring the market in line with the current trading standards. In the STEs’ opinion, all of them should be introduced as soon as practicably possible, although the STEs understand that it is not possible to do it all at once in a short term perspective.

Furthermore, the STEs presented models, existing in the EU, of “oversight” and “supervision” over the central securities depositories and explained the importance of clear legal and operational distinction between the institutions i.e. the NCFM and the National Bank of Moldova.

Moreover, the STEs underlined that Moldovan regulators and the NCFM should closely monitor regulatory developments, particularly the global standards for post trading and the ESMA Guidelines and Q&As relating to the MIFID Directive; this is necessary in order to enhance ability to effectively supervise regulated markets’ operators.

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Finally, the STEs underlined that market operators must develop education tools and initiatives that would help to attract investors to the market.

Component 3 – Insurance Companies.Indicator of achievement (copied from logframe)

Strengthening operational and institutional capacities of NCFM to supervise and regulate insurance companies sector accomplished.

Within the reporting period there were no activities foreseen to be implemented within the Component 3.

Component 4 – Savings and Credit Associations (Credit Unions) and Pension Funds.Indicator of achievement (copied from logframe)

Strengthening operational and institutional capacities of the NCFM to supervise and regulate savings and credit associations (credit unions) and pension funds sector accomplished.

Within the reporting period there were no activities foreseen to be implemented within the Component 4.

2C. ACTIVITIES IN THE REPORTING PERIODDuring the reporting period the works were focused on:

- Organization and implementation of eight subsequent experts’ missions in Chisinau and one study visit in the KNF in Warsaw;

- Preparation of the next experts’ missions scheduled for the second half of 2016,

- Development of the schedule covering implementation of the project activities from July to December 2016;

- Development of the 2nd Interim Quarterly Report and organization of the second Project Steering Committee (PSC);

- Conducting the tender procedures in line with the EU and Polish Public Procurement regulations, leading to a successful selection of a Contractor responsible for providing comprehensive English-Romanian translation/interpretation services within the Project.

Project ManagementOn 15th March 2016 the internal working meeting between Twin Partners was organized in the NCFM premises, where presentations and discussions about the project implementation and progress (i.e. following project activities already agreed

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for the next 6 months from July to December 2016, including detailed schedule of particular missions, objectives and mandatory results) took place.

Additionally, on 15th March 2016 the internal MS and BC project management working meeting took place in order to discuss certain aspects of the further project implementation.

In the seventh month of the Project legal duration the second Project Steering Committee meeting took place. The PSC meeting was organized jointly by the Polish and Moldovan partners in the NCFM Conference room in Chisinau on 16th March 2016, in line with the project schedule. The meeting was attended by the Moldovan and Polish Project Leaders, the Polish Project Manager, the RTA and his counterpart from the NCFM, the Project Manager of the EU Delegation to the Republic of Moldova (EUD) as well as the PAO delegate, the members of the board of the NCFM, the High-level Adviser to the Prime-Minister’s Office of the Republic of Moldova and the Counsellor at the Embassy of Poland in Chisinau (as observers). The PSC discussed the progress of the project, verified achievement of the outputs and mandatory results as well as discussed actions to be undertaken in the following quarter and other issues which might affect a smooth implementation of the project. The PSC also discussed the draft of the 2nd Interim Quarterly Report (IQR), covering the period of 12th November 2015 – 11th February 2016, submitted to the PSC participants beforehand. Certain remarks, regarding additional information on the overall very positive assessment of the NCFM of the hitherto project activities, to be included in the second QR were notified by the Project Manager of the EU Delegation to the Republic of Moldova and reflected in the final version of the second QR fully approved by the EUD.

The detailed timing of all project activities in 2016 was mutually agreed by Project Leaders. Detailed information is provided in the section 2D.

The preparatory work on the third Project Steering Committee meeting scheduled for the tenth month of the project implementation was initiated.

In addition, upon the NCFM’s request, the RTA in cooperation with the KNF experts prepared the detailed information on incentives for investors, including related tax provisions, existing on the Polish financial market.

During the reporting period the following project activities took place:

Component 1. Strengthening operational and institutional capacities of the NCFM.

Activity 1.11 Review of on-site inspections methodology in regard to insurance sector.

Names of MS experts who delivered the activity:

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1. Emilia Kulińska (Key Short Term Expert) – Chief Specialist, Insurance and Pension Inspection Department, Polish Financial Supervision Authority;

2. Tomasz Krupa (Short Term Expert) – Senior Specialist, Insurance and Pension Inspection Department, Polish Financial Supervision Authority;

3. Andrzej Świsłowski (Short Term Expert) – Expert, Insurance and Pension Inspection Department, Polish Financial Supervision Authority.

Experts from the BC who participated in the Activity 1.11 and their departments of origin:

The expert meetings organized within the framework of the Activity 1.11 were attended by 12 NCFM employees in total. The BC experts were from the General Division Insurance Supervision.

Duration of the activity: 8th – 12th February 2016.

The Activity fiche (No 11) for the Activity 1.11, the Evaluation sheet of the Activity 1.11, the Review report with recommendations resulting from the Activity 1.11, the Workshop materials (Presentation) resulting from the Activity 1.11, the Attendance List regarding Activity 1.11 are attached in the Annex no 1.

Activity 1.12 Review of on-site and off-site inspections methodology in regard to pension sector.


1. Sławomir Pomarański (Key Short Term Expert) – Head of Unit, Insurance and Pension Inspection Department, Polish Financial Supervision Authority;

2. Maciej Sierant (Short Term Expert) – Chief Specialist, Insurance and Pension Inspection Department, Polish Financial Supervision Authority;

3. Robert Kuptel (Short Term Expert) – Chief Specialist, Pension Investments Supervision Department, Polish Financial Supervision Authority;

4. Wojciech Jagiełło (Short Term Expert) – Senior Specialist, Insurance and Pension Inspection Department, Polish Financial Supervision Authority.


The expert meetings organized within the framework of the Activity 1.12 were attended by 12 NCFM employees in total. The BC experts were from the General Division of Collective Placements and Microfinance and the General Legal Division.

Duration of the activity: 15th – 19th February 2016.

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The Activity fiche (No 12) for the Activity 1.12, the Evaluation sheet of the Activity 1.12, the Review report with recommendations resulting from the Activity 1.12, the Workshop materials and Presentations resulting from the Activity 1.12, the Attendance list regarding Activity 1.12 are attached in the Annex no 2.

Activity 1.13 Review of on-site and off-site inspections methodology in regard to Anti-Money Laundering and combating the financing of terrorism.

Name of MS expert who delivered the activity:

1. Radosław Obczyński (Key Short Term Expert) – Chief Specialist, Department of Inspections for Banks, Payment Institutions and Credit Unions, Polish Financial Supervision Authority.


The expert meetings organized within the framework of the Activity 1.13 were attended by 11 NCFM employees in total. The BC experts were from the General Executive Division, the General Division of Securities Market Supervision, the General Division of Collective Placements and Microfinance and the General Division of Insurance Supervision.

Duration of the activity: 14th – 18th March 2016.

The Activity fiche (No 13) for the Activity 1.13, the Evaluation sheet of the Activity 1.13, the Review report with recommendations resulting from the Activity 1.13, the Working papers for supervisory use resulting from the Activity 1.13, the Attendance list regarding Activity 1.13 are attached in the Annex no 3.

Activity 1.14 Review and assessment of supervisory powers in the field of non-banking financial market in regard to international cooperation and exchange of information (part 2).


1. Katarzyna Tomczyk (Key Short Term Expert) – Head of Unit, Analyses and International Cooperation Department, Polish Financial Supervision Authority;

2. Bogusław Budziński (Short Term Expert) – Head of Unit, Investment Firms and Capital Market Infrastructure Department, Polish Financial Supervision Authority.


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The expert meetings organized within the framework of the Activity 1.14 were attended by 7 NCFM employees in total. The BC experts were from the Foreign Relations and Development Division/General Executive Division, the General Legal Division and the General Division of Securities Market Supervision.

Duration of the activity: 14th – 18th March 2016.

The Activity fiche (No 14) for the Activity 1.14, the Evaluation sheet of the Activity 1.14, the Guidelines on standards of efficient international cooperation and exchange of information with foreign counterparts resulting from the Activity 1.14, the Attendance list regarding Activity 1.14 are attached in the Annex no 4.

Activity 1.15 Support of Internal Audit on IT.


1. Dariusz Łazar (Key Short Term Expert) – Deputy Director, Administration, Finance and IT Department, Polish Financial Supervision Authority;

2. Marcin Klejman (Short Term Expert) – Head of Unit, Administration, Finance, and IT Department, Polish Financial Supervision Authority;

3. Kien Do (Short Term Expert) – Head of Unit, Administration, Finance and IT Department, Polish Financial Supervision Authority.


The expert meetings organized within the framework of the Activity 1.15 were attended by 7 NCFM employees in total. The BC experts were from the IT Division, the General Division of Securities Market Supervision and the Internal Audit Service.

Duration of the activity: 29th February –4th March 2016.

The Activity fiche (No 15) for the Activity 1.15, the Evaluation sheet of the Activity 1.15, the Guidelines for conducting IT internal audit resulting from the Activity 1.15, the Workshop materials and Presentations resulting from the Activity 1.15, the Attendance list regarding Activity 1.15 are attached in the Annex no 5.

Activity 1.16 Support for Internal Audit (IA) and potential application of Public Internal Financial Control (PIFC) system.

Name of MS expert who delivered the activity:

1. Marlena Zimnota (Key Short Term Expert) – Internal Audit, Polish Financial Supervision Authority.

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Experts from the BC who participated in the activity 1.16 and their departments of origin:

The expert meetings organized within the framework of the Activity 1.16 were attended by 5 NCFM employees in total. The BC experts were from the Internal Audit Service, the General Executive Division, the Economic and Financial General Division.

Duration of the activity: 11th April – 15th April 2016.

The Activity fiche (No 16) for the Activity 1.16, the Evaluation sheet of the Activity 1.16, the Review report with guidelines resulting from the Activity 1.16, the Working papers for supervisory use (the Handbook of Internal Audit Procedures and the Instruction for the functioning of the internal audit) resulting from the Activity 1.16 , the Presentations resulting from the Activity 1.16, the Attendance List regarding Activity 1.16 are attached in the Annex no 6.

Activity 1.17 Study Visit.Names of MS experts who delivered the activity:

1. Damian Jaworski – Director, Analyses and International Cooperation Department; MS Project Leader, Polish Financial Supervision Authority;

2. Joanna Lipowczan – Head of Unit, Analyses and International Cooperation Department; MS Project Manager, Polish Financial Supervision Authority;

3. Katarzyna Tomczyk – Head of Unit, Analyses and International Cooperation Department, Polish Financial Supervision Authority;

4. Ewelina Steć – Legal Advisor, Legal Department, Polish Financial Supervision Authority;

5. Anna Pawlik – Legal Advisor, Legal Department, Polish Financial Supervision Authority;

6. Krzysztof Olszówka – Chief Specialist, Legal Department, Polish Financial Supervision Authority;

7. Joanna Banach – Specialist, Legal Department, Polish Financial Supervision Authority;

8. Sebastian Bogdan – Deputy Director, Trading Surveillance Department, Polish Financial Supervision Authority;

9. Aneta Zaniewska – Chief Specialist, Investment Funds Department, Polish Financial Supervision Authority;

10.Bartosz Klimczak – Deputy Director, Investment Funds Department, Polish Financial Supervision Authority;

11.Dariusz Łazar – Deputy Director, Administration, Finance and IT Department, Polish Financial Supervision Authority;

12.Marcin Klejman – Head of Unit, Administration, Finance and IT Department, Polish Financial Supervision Authority;

13.Kien Do – Head of Unit, Administration, Finance and IT Department, Polish Financial Supervision Authority;

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14.Robert Suwała – Head of Unit, Administration, Finance and IT Department, Polish Financial Supervision Authority;

15.Tomasz Krupa – Senior Specialist, Insurance and Pension Inspection Department, Polish Financial Supervision Authority;

16.Andrzej Świsłowski – Expert, Insurance and Pension Inspection Department, Polish Financial Supervision Authority;

17.Sławomir Pomarański – Head of Unit, Insurance and Pension Inspection Department, Polish Financial Supervision Authority;

18.Maciej Sierant – Chief Specialist, Insurance and Pension Inspection Department, Polish Financial Supervision Authority;

19.Robert Kuptel - Chief Specialist, Pension Investments Supervision Department, Polish Financial Supervision Authority


The expert meetings organized within the framework of the Activity 1.17 were attended by 9 NCFM employees and 2 members of the Moldovan Parliament. The BC experts were from the Executive General Division, the General Division of Securities Market Supervision, the General Division of Insurance Supervision, the General Division of Collective Placements and Microfinance, the IT Division; as well as 2 participants from the Committee for Economy, Budget and Finance, Parliament of the Republic of Moldova.

Duration of the activity: 25th – 27th April 2016.

The Activity fiche (No 19) for the Activity 1.17, the Evaluation sheet of the Activity 1.17, the Study visit report resulting from the Activity 1.17, the Working papers for supervisory use, the Study visit program, the Attendance List regarding Activity 1.17 are attached in the Annex no 7.

Component 2. Capital Market and Investment Funds.

Activity 2.11 Review of regulations for capital market licensed entities (part 1) – in regard to investment firms. Names of MS experts who delivered the activity:

1. Andrzej Krawczyk (Key Short Term Expert) – Expert, Investment Firms and Capital Market Infrastructure Department, Polish Financial Supervision Authority;

2. Przemysław Trubicki (Short Term Expert) – Expert, Investment Firms and Capital Market Infrastructure Department, Polish Financial Supervision Authority;

3. Krzysztof Montewka (Short Term Expert) – Senior Specialist, Investment Firms and Capital Market Infrastructure Department, Polish Financial Supervision Authority.

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Experts from the BC who participated in the Activity 2.11 and their departments of origin.

The expert meetings organized within the framework of the Activity 2.11 were attended by 8 NCFM employees in total. The BC experts were from the General Division of Securities Market Supervision and the General Legal Division.

Duration of the activity: 4th –8th April 2016.

The Activity fiche (No. 17) for the Activity 2.11, the Evaluation sheet of the Activity 2.11, the Gap analysis with recommendation resulting from the Activity 2.11, the Attendance List regarding Activity 2.11 are attached in the Annex no 8.

Activity 2.12 Review of regulations for capital market licensed entities (part 2) – in regard to capital market infrastructure: market operators, CSD, clearing and settlement houses, national securities depository.


1. Adam Błasiak (Key Short Term Expert) – Expert, Investment Firms and Capital Market Infrastructure Department, Polish Financial Supervision Authority;

2. Bogusław Budziński (Short Term Expert) – Head of Unit, Investment Firms and Capital Market Infrastructure Department, Polish Financial Supervision Authority;

3. Leszek Kolakowski (Short Term Expert) – Deputy Director, Strategy and Business Development Department, Central Securities Depository of Poland;

4. Daniel Szańca (Short Term Expert) – Legal Counsel, Central Securities Depository of Poland;

5. Artur Wrotek (Short Term Expert) – IT Deputy Director, Trading System Development Section, Polish Power Exchange.

Experts from the BC who participated in the Activity 2.12 and their departments of origin.

The expert meetings organized within the framework of the Activity 2.12 were attended by 8 NCFM employees in total. The BC experts were from the General Division of Securities Market Supervision and the General Legal Division.

Duration of the activity: 18th April – 22nd April 2016.

The Activity fiche (No. 18) for the Activity 2.12, the Evaluation sheet of the Activity 2.12, the Recommendations resulting from the Activity 2.12, the Workshop materials for supervisory use resulting from the Activity 2.12, the Attendance List regarding Activity 2.12 are attached in the Annex no 9.

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2D. TIMING AND DELAYSAdherence to time schedule

Activity/action Planned X Activity/action Performed

Activity/action Delayed by more than 3 months

Year 2015 2016 2017

Month

IX

X XI

XII

I II

III

IV

V VI

VII

VIII

IX

X XI

XII

I II III

IV

V VI

VII

VIII

Project Month

1 2 3 4 5 6 7 8 9 10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

Component 1Activity 0.1

X

Activity 0.2Activity 1.1

X

Activity 1.2

X

Activity 1.3

X

Activity 1.4

X

Activity 1.5

X

Activity 1.6

X

Activity 1.7

X

Activity 1.8

X

Activity 1.9

X

Activity 1.10

X

Activity 1.11

X

Activity 1.12

X

Activity 1.13

X

Activity

X

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1.14Activity 1.15

X

Activity 1.16

X

Activity 1.17

X

Component 2Activity 2.1Activity 2.2Activity 2.3Activity 2.4Activity 2.5Activity 2.6Activity 2.7Activity 2.8Activity 2.9Activity 2.10Activity 2.11

X

Activity 2.12

X

Activity 2.13Activity 2.14Activity 2.15Activity 2.16Activity 2.17Activity

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2.18Activity 2.19Activity 2.20Activity 2.21Activity 2.22Activity 2.23Activity 2.24Component 3Activity 3.1Activity 3.2Activity 3.3Activity 3.4Activity 3.5Activity 3.6Activity 3.7Activity 3.8Activity 3.9Activity 3.10Activity 3.11Activity 3.12Activity 3.13Component 4Activity 4.1Activity 4.2

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Activity 4.3Activity 4.4Activity 4.5Activity 4.6Activity 4.7Activity 4.8

Recuperation of delaysAt this stage of the project implementation the timing of four experts’ missions has been changed within the same QR period depending on the availability of experts both from the KNF and NCFM. The Activity 1.12 was changed from March 2016 to February 2016; the Activity 1.15 was changed from April 2016 to March 2016 as well as the Activities 2.11 and 2.12 were changed from May 2016 to April 2016.

All above mentioned changes in the time schedule did not impact the implementation of the project and achieving of mandatory results, and they were discussed and approved in advance by the Twin Partners in order to fulfill the project requirements and timeframes.

2E. ASSESSMENT Overall Assessment of progress The project and the implementation of activities within the third project quarter went smoothly and timely.

The project is being implemented in close cooperation conducted on a daily basis between the KNF and the NCFM.

Nineteen activities within the Component 1 and 2 were provided so far and their planned mandatory results were achieved.

During the third quarter of the project all activities of the Component 1 were accomplished.

The hitherto implemented experts’ missions and the study visit were highly appreciated by the NCFM. All project activities were evaluated by the representatives of the NCFM who participated in the particular experts’ mission and received very positive overall substantive assessment.

Subsequent activities within the Component 2 are planned to be implemented in the next quarters till end of 2016.

In general, the technical and substantive problems arising during the project implementation were resolved quickly and efficiently.

At this stage of the project implementation, there is no risk that future activities will not be completed or that they will be delayed for more than three months.

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Visibility – overview of the progress in the Communication and Visibility Plan implementationThe undertaken communication and visibility activities were implemented in line with the assumptions of the Communication and Visibility Plan. During all project meetings, such as experts’ missions in Chisinau, Twinning project roll-up (banner) was installed accordingly in order to follow the Twinning visibility standards. All types of publications and deliverable outputs foreseen in the Twinning Work Plan, such as presentations, workshop and training materials for supervisory use, reports with recommendations, guidelines and other project publications were prepared in accordance with the project document templates, which had been approved by the EUD following Twinning visibility standards. On the front pages these templates bear information about project, its stakeholders as well as the statement on the project financing provided by the EU. All project visibility products, such as notebooks, folders, pens and USB pen drives, were prepared in accordance with the EU visibility requirements and distributed among the participants of the project activities such as workshops and expert consultations. Moreover, in the reporting period the development of the content on the Twinning project to be uploaded on the website of the MS Partner and possibly of the BC Partner (upon further consultations) was initiated in order to disseminate the information on the project implemented by the Polish and Moldovan partners with the EU financial assistance. Given the technical and expert nature of the project, involving bilateral internal consultation between the Polish and Moldovan supervisory authorities and expert advice (which may require a certain degree of confidentiality) the content of the website need to be adjusted in the scale respectively and more focused on a restricted group of target audience. Thus, only selected publicly available information regarding the project can be disseminated and made available via Partners’ websites, instead of setting up separate project website. Therefore, the summarized information on the goals and progress in the implementation of the Twinning project was published on the KNF’s website (available in Polish and English) and the possibility and scope of information to be uploaded on the NCFM website was analyzed to be decided within next reporting period.

The screenshots of the KNF’s website dedicated to the Twinning project are attached in the Annex no 10.

Annexes:1. Annex 1: The Activity fiche (No 11) for the Activity 1.11, the Evaluation sheet

of the Activity 1.11, the Review report with recommendations resulting from the Activity 1.11, the Workshop materials (Presentation) resulting from the Activity 1.11, the Attendance List regarding Activity 1.11.

2. Annex 2: The Activity fiche (No 12) for the Activity 1.12, the Evaluation sheet of the Activity 1.12, the Review report with recommendations resulting from the Activity 1.12, the Workshop materials and Presentations resulting from the Activity 1.12,the Attendance list regarding Activity 1.12.

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3. Annex 3: The Activity fiche (No 13) for the Activity 1.13, the Evaluation sheet of the Activity 1.13, the Review report with recommendations resulting from the Activity 1.13, the Working papers for supervisory use resulting from the Activity 1.13, the Attendance list regarding Activity 1.13.

4. Annex 4: The Activity fiche (No 14) for the Activity 1.14, the Evaluation sheet of the Activity 1.14, the Guidelines on standards of efficient international cooperation and exchange of information with foreign counterparts resulting from the Activity 1.14, the Attendance list regarding Activity 1.14.

5. Annex 5: The Activity fiche (No 15) for the Activity 1.15, the Evaluation sheet of the Activity 1.15, the Guidelines for conducting IT internal audit resulting from the Activity 1.15, the Working materials from presentations resulting from the Activity 1.15, the Attendance list regarding Activity 1.15.

6. Annex 6: The Activity fiche (No 16) for the Activity 1.16, the Evaluation sheet of the Activity 1.16, the Review report with guidelines resulting from the Activity 1.16, the Working papers for supervisory use (the Handbook of Internal Audit Procedures and the Instruction for the functioning of the internal audit) resulting from the Activity 1.16, the Presentations resulting from the Activity 1.16, the Attendance List regarding Activity 1.16.

7. Annex 7: The Activity fiche (No 19) for the Activity 1.17, the Evaluation sheet of the Activity 1.17, the Study visit report resulting from the Activity 1.17, the Working papers for supervisory use, the Study visit program, the Attendance List regarding Activity 1.17.

8. Annex 8: The Activity fiche (No. 17) for the Activity 2.11, the Evaluation sheet of the Activity 2.11, the Gap analysis with recommendation resulting from the Activity 2.11, the Attendance List regarding Activity 2.11.

9. Annex 9: The Activity fiche (No. 18) for the Activity 2.12, the Evaluation sheet of the Activity 2.12, the Recommendations resulting from the Activity 2.12, the Workshop materials for supervisory use resulting from the Activity 2.12, the Attendance List regarding Activity 2.12.

10.Annex 10: The evidence of communication and visibility activities (the KNF website presence of the Twinning project).


Section 3: Expenditures

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