Client and transaction screening policy (AML/KYC)
1. Scope
1.1. This Policy sets the rules for screening clients, authority and transaction circumstances by Limited Liability Company "Great Rock" (the Company, OZTA). Screening is performed to the extent needed to lawfully perform a specific Instruction and manage its related risks.
1.2. The grounds for screening are kept separate: legal requirements, mandatory conditions of a participating bank or other contractor, and the Company's reasonable check of the accuracy of information and the possibility of performing the order.
1.3. This Policy applies together with the General Terms of Service, Sanctions Policy and Privacy Policy.
2. Information requested
2.1. Depending on the service and circumstances identified, the Company may request information needed to identify the client and representative, verify authority, participants and transaction purpose, and establish the lawful use of funds. The request must be proportionate to its screening purpose.
2.2. Registration documents, information about representatives and beneficial owners, source of funds or payment basis are requested when required by law, the terms of a particular channel or the circumstances of the transaction. This Policy does not make full identification a universal condition of every Application or digital product.
2.3. The Company tells the Client what information is needed, why it is requested and how it must be sent. Passwords, access codes and confirmations of operations in personal accounts are not identification documents and must not be provided to the Company.
2.4. The Client must provide accurate information and report changes before the affected stage is performed. The Company may clarify inconsistencies and check information through available lawful sources.
3. Assessment of performance possibility
3.1. The Company considers the transaction, participants, authority, recipient, goods or service, route, settlement method and requirements of the contractors involved. Screening does not guarantee that all risks are absent or that a third party will approve the transaction.
3.2. A positive result of one screening does not confirm that another Instruction is available. A repeat request is permitted when material circumstances change, inconsistencies are found or a new mandatory requirement arises.
3.3. The Company does not accept instructions to conceal the actual payer, recipient or purpose, use forged documents or unlawfully circumvent screening. The legality of an action is not established solely by the Client's consent.
4. Suspension and refusal
4.1. Before accepting an Instruction, the Company may refuse an Application if necessary information is missing, identified inconsistencies have not been resolved or a lawful performance method has not been confirmed.
4.2. For an accepted Instruction, the Company may suspend affected actions if missing or inaccurate required information, refusal of mandatory screening or an identified restriction prevents performance. If the obstacle can be remedied, the notice states the required actions and a reasonable period.
4.3. An immediate suspension is permitted where a mandatory prohibition or threat of unlawful action exists. The Company discloses the reason to the extent permitted by law; a prohibition on revealing protected information does not create a general right to give no explanation for any refusal.
4.4. An existing Instruction may be terminated on a statutory or permissible contractual basis under the Cancellation and Termination Policy. The calculation is made under the Refund Policy. Screening or termination does not create a right to turn the Client's funds into additional remuneration.
5. Data and cooperation with authorities
5.1. Data is used for the stated screening and the obligations for which it was obtained. Transfer to a bank, contractor or authority is allowed on a lawful basis and to the necessary extent. Screening documents may not be used for advertising without a separate lawful basis.
5.2. The retention period is determined by an applicable mandatory period or by the need to document screening, performance and protection of rights. The absence of a mandatory period applicable to the Company is not a basis for indefinite retention. Processing and Client requests are governed by the Privacy Policy.
5.3. The Company complies with lawful requests of authorised authorities and other disclosure duties imposed by law. Confidentiality does not prevent compliance with those duties.
6. Liability and versions
6.1. The lawfulness of a suspension, termination and monetary consequence depends on the reason, procedure and applicable rules. This Policy does not exclude the Company's liability for an unjustified refusal, unlawful use of data or another breach of its own obligations.
6.2. The version included in the accepted Instruction governs contractual screening terms. A new publication does not automatically change the agreed price or scope. Mandatory legal requirements apply from the date set by the relevant rule.
6.3. Requests must be sent to info@ozta.com or through the agreed channel. Applicable law, notices and dispute resolution are governed by the General Terms of Service.