Sanctions Policy
1. General provisions
1.1. This Policy sets out how Limited Liability Company "Great Rock" (the Company, OZTA) takes applicable sanctions and other restrictive measures into account when reviewing Applications and performing Instructions.
1.2. The Company distinguishes mandatory prohibitions and restrictions applying to a particular transaction, contractual requirements of a participating bank or contractor, and its own assessment of whether performance is possible. A foreign restrictive measure does not automatically become mandatory for all of the Company's relationships merely because it exists.
1.3. The possibility of performance is assessed with regard to the participants, goods or service, origin, purpose, route, currency and actually available channel. A general country or service page does not confirm that every transaction in that direction is permissible.
2. Review of circumstances
2.1. Within the necessary scope of review, the Company may compare participants with official lists relevant to the transaction and clarify participants' authority and connections, the goods' characteristics, the recipient and the end use. Sources and circumstances are assessed as at the review date.
2.2. A contractor's refusal to participate is treated as a condition affecting that contractor's availability, not as an unconditional statement that the law prohibits the transaction. The permissibility of another performance method is checked separately before it is agreed.
2.3. The Company's review is not a legal opinion or a guarantee that no restrictions exist. The Company is not required to undertake to find any alternative performance method unless that search is separately agreed.
3. Client obligations
3.1. The Client provides accurate information needed to assess the transaction and notifies the Company of changes to participants, purpose, goods, route and other material circumstances.
3.2. Forged documents, concealment of the actual participants or purpose, and fictitious changes intended to circumvent restrictions unlawfully are prohibited. The Company may refuse to follow such instructions regardless of the Client's confirmation.
3.3. Requested information must relate to the transaction being reviewed. Personal data is processed and transferred under the Privacy Policy.
4. Suspension and termination
4.1. Before an agreement is concluded, the Company may refuse an Application if permissible performance or the necessary channel has not been confirmed or the necessary information is missing.
4.2. Under an existing Instruction, the Company may suspend affected actions if it identifies a mandatory prohibition, refusal by a necessary participant, a material inconsistency in documents or an inability to complete a necessary review. The suspension must be connected with an actual obstacle to performance.
4.3. If an obstacle can be remedied, the Company notifies the Client of the required measures and a reasonable period for taking them. An immediate stop is permitted where an unlawful or irreversible action is threatened, followed by notice to the extent permitted by law.
4.4. A contractor's refusal, a change in restrictions or failure to provide information does not automatically terminate the agreement. The Company determines whether lawful continuation is possible or terminates the Instruction on a ground provided by the Cancellation and Termination Policy. A new method, scope and price must be agreed before performance.
4.5. The calculation of the completed part, external expenses and balance is made under the Refund Policy. Lawful restrictions on disposing of funds are considered separately; the fact that a review was conducted is not, by itself, a ground for retaining funds as the Company's income.
5. Liability and final provisions
5.1. The Company is liable for its own breaches under the law and the agreement. Whether release from liability due to an external restriction is lawful depends on its effect on performance, the parties' actions and applicable rules. This Policy does not establish unconditional immunity for every refusal or suspension.
5.2. The Company cooperates with authorised authorities in the cases and manner required by law. A private company's review does not replace a state permit or the authority required for an operation.
5.3. This Policy applies together with the Client and transaction screening policy (AML/KYC) and the General Terms of Service. The contractual version is determined when the Instruction is accepted; new mandatory rules apply regardless of whether an updated text has been published.
5.4. 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, subject to the Client's mandatory rights.