AML/KYC Policy

LLC 'ONLY' (hereinafter - 'the Company') adheres to the principles of combating the laundering (criminal proceeds) and financing of terrorism (AML/CFT), as well as international sanctions compliance practices. This document describes the basic public principles that the Company follows in its work with clients and operations.

1. Initial Client and Operation Analysis

Before support begins, the Company conducts an initial analysis of the client, its counterparty, documents, country, currency, and economic purpose of the operation. This analysis is necessary to understand the business purpose of the operation and its compatibility with applicable regulatory requirements.

2. Business Purpose of the Operation

The Company does not work with operations lacking a clear business purpose. If the business purpose of the operation cannot be determined from the provided documents and explanations, the Company requests additional information or declines support.

3. Request for Additional Documents

The Company may request additional documents and explanations from the client, including: founding documents, beneficial owner information, contracts, invoices, specifications, transport documents, correspondence with the counterparty, sources of funds, and other information reasonably necessary to understand the operation.

4. Refusal of Support

The Company may refuse to support an operation without a detailed explanation of the internal risk assessment. The decision to refuse may be based on a combination of factors, including: country risk, sanctions restrictions, lack of documentary proof of business purpose, signs of transit nature of the operation, reputational risks, contradictions in the provided information.

5. Compliance with Legislation

The Company does not support operations that contradict the applicable legislation of the Russian Federation, international and national sanctions regimes, banking compliance requirements, and the principles of combating money laundering and terrorist financing.

6. Confidentiality

Information received from the client in the context of the initial review and operation support is processed in compliance with the requirements of personal data legislation and the commercial secrecy regime. Transfer to third parties is carried out only in cases directly provided for by law or with the client's consent.

7. Feedback

Questions related to the application of these principles can be sent to info@only-pays.com.