1. Source the duty
Identify the legal and contractual sources that actually apply: statute, secondary acts, licence conditions, banking covenants, processor clauses. Unsourced “best practice” is parked until it is tied to a requirement.
Overview / Practice
Firm profile
A Chișinău desk for people who have to prove control.
Alexandr Vascan is a named independent practice. The work is compliance consulting: reading the duty, fitting it to the operating model, and leaving a file that a manager can defend. It is not a substitute for a law firm, a licensed auditor, or an appointed compliance officer unless that appointment is documented separately.
Dossier 02
About the practice
digitalustranis.cc
Position
Why the practice exists
Operators in Moldova sit at a junction: domestic statutes, sector supervisors, correspondent banks, and European counterparties who import their own questionnaires. Those sources rarely arrive as a single instruction. They arrive as overlapping asks. The practice exists to turn that overlap into an owned control set.
Clients are typically past the “we should have a policy” stage. They have a licence condition, a product launch, a bank that will not open a file, or an inspection date. They need someone who will sit with the actual process — onboarding, payments, HR files, vendor access — and write controls that match how the organisation really works.
Independent No product placement, no software resale, no traffic-driven advice.
File-first Deliverables are working papers, matrices and walk-through notes.
Bounded Scope, exclusions and review cadence are written before drafting begins.
Method
Methodology used on every mandate
2. Trace the work
Walk the real path of a customer, payment, employee file or vendor. Controls that do not touch a real step are rewritten or dropped.
3. Assign an owner
Every control receives a name, a system, a frequency and an evidence artefact. Shared ownership is treated as no ownership.
4. Rehearse the ask
Before close-out, we run the file as an inspector or bank analyst would: “Show me this control operating last month.” Gaps become the punch list. See engagement.
Principles
- Write in the language staff will use, then keep a technical annex for the supervisor.
- Prefer fewer controls that operate over a long catalogue nobody opens.
- Record uncertainty. If a rule is unsettled, the file says so and names the decision-maker.
- Keep legal privilege questions with counsel; this practice produces advisory work product, not court filings.
Values
- Directness over atmosphere. Clients get the gap list early.
- Confidential handling of files. Access is limited to the mandate team.
- No cloaked recommendations. If a control is cosmetic, it is labelled as such.
- Location honesty: work is based in Chișinău and described as consulting, not as a public authority.
Office: Strada Alexandru Hajdeu 57, MD-2001, Chișinău, Republica Moldova. Mail: [email protected].