This AML/KYC and Sanctions Compliance Policy describes the risk-based approach adopted by KOTLYARS to identify users, reduce financial crime risks, comply with applicable sanctions requirements, and protect the integrity of its international marketplace and auction platform.
KOTLYARS applies proportionate, risk-based compliance measures designed to prevent money laundering, terrorist financing, sanctions violations, fraud, and other unlawful activity while supporting legitimate international trade.
This Policy supplements the Terms and Conditions, Privacy Policy, Registration Rules, Buyer Rules, Seller Rules, Auction Rules, and other applicable platform policies. Where mandatory law applies, the relevant legal requirements take precedence.
- Purpose and Scope. This Policy applies to user registration, marketplace listings, auctions, communications, transactions, and any other KOTLYARS activity where money laundering, terrorist financing, proliferation financing, sanctions, fraud, or other financial-crime risks may arise.
- Current Operating Model. As of the Effective Date, KOTLYARS does not receive, process, or hold payments for marketplace transactions and does not currently operate an integrated banking-style AML/KYC system. However, the platform may perform manual or third-party risk-based reviews where appropriate. A fully automated compliance solution may be introduced in the future.
- Application of Law. Compliance requirements depend on the user's role, item category, transaction value, jurisdiction, payment method, and applicable law. KOTLYARS does not represent that it is a regulated financial institution or obliged entity in every jurisdiction. Buyers, sellers, intermediaries, payment providers, and other participants remain responsible for their own legal obligations.
- Risk-Based Approach. KOTLYARS assesses user identity, ownership structure, geographic location, item type, provenance, transaction value, payment method, and behavioural indicators. The level of review is proportionate to the identified risk and may range from basic verification to enhanced due diligence.
- When Review May Occur. Reviews may occur during registration, profile updates, high-value listings, unusual platform activity, sanctions screening, disputes, complaints, authority requests, or prior to providing particular services. Additional reviews may also be required when circumstances, ownership, documents, jurisdictions, or legal requirements change.
- Individual Identification. KOTLYARS may request a user's full name, date of birth, nationality, residential address, contact information, government-issued photo identification, proof of address, or biometric verification where appropriate. Only information reasonably necessary for the applicable risk level will be requested.
- Companies and Beneficial Owners. Business users may be required to provide company registration details, registered address, legal status, directors, ownership structure, and information identifying the ultimate beneficial owners. Additional corporate records or registry extracts may also be requested.
- Representatives and Third Parties. Individuals acting on behalf of another person or business must demonstrate both their identity and authority to act. Transactions involving unrelated third parties for payment, ownership, or delivery may require additional explanation and supporting evidence.
- Item and Transaction Information. KOTLYARS may request invoices, provenance documentation, certificates, export records, ownership history, transaction purpose, delivery routes, settlement methods, or other information necessary to assess compliance risk. Precious metals, gemstones, jewellery, artwork, and cultural property may receive additional scrutiny due to their portability and higher inherent risk.
- Source of Funds and Wealth. Where risk warrants enhanced review, KOTLYARS or an authorized service provider may request reasonable evidence regarding the lawful source of transaction funds or overall source of wealth. Appropriate documentation may include bank statements, contracts, inheritance records, dividend statements, employment income, or similar evidence.
- Higher-Risk Factors. Elevated risk indicators may include sanctioned or high-risk jurisdictions, complex ownership structures, nominee arrangements, unexplained urgency, third-party payments, opaque cash or virtual asset transactions, document irregularities, unusual pricing, unclear provenance, rapid resale activity, or attempts to bypass normal platform controls.
- Sanctions Screening. KOTLYARS may screen users, beneficial owners, representatives, counterparties, countries, vessels, addresses, or transactions against applicable sanctions lists issued by the United Nations, European Union, United Kingdom, United States, and other competent authorities. Screening may consider ownership and control relationships in addition to exact name matches.
- Politically Exposed Persons (PEPs) and Adverse Information. Politically exposed person status or association with a PEP does not automatically prevent platform participation but may require enhanced due diligence. Public information concerning fraud, corruption, sanctions violations, smuggling, or other relevant criminal activity may also be considered where appropriate.
- Enhanced Due Diligence. Higher-risk situations may require additional documentation, independent verification, video identification, source-of-funds evidence, provenance review, bank information, counterparty verification, or management approval before activity proceeds. Enhanced due diligence should not be interpreted as a guarantee of legality.
- Unable to Complete Review. Where identity, ownership, authority, source of funds, or legality cannot reasonably be established, KOTLYARS may refuse registration, suspend activity, remove listings, restrict accounts, terminate services, or make reports where required by applicable law.
- Monitoring and Suspicion Reports. Although KOTLYARS does not process marketplace payments, it may analyse user accounts, listings, communications, bidding behaviour, documentation, and other available information for indicators of suspicious activity. Where legally permitted or required, relevant information may be preserved or reported to competent authorities.
- Data Retention and Privacy. Personal information collected during verification and compliance reviews is processed in accordance with the Privacy Policy and applicable data protection laws. Data is retained only for the period required by law, regulatory obligations, disputes, or legitimate business purposes before deletion or anonymisation.
- Providers and Future Integration. KOTLYARS may engage trusted providers offering identity verification, sanctions screening, biometric matching, document authentication, company registry searches, or compliance risk assessment. Future implementation of an automated AML/KYC module will be announced separately together with the applicable processing terms.
- User Duties and Review Limits. Users must provide accurate, complete, and current information, promptly report material changes, and must not conceal ownership, counterparties, transaction purposes, or item provenance. A completed review or successful verification does not constitute a guarantee regarding reputation, authenticity, legality, or future conduct.
- Decisions, Contact and Changes. KOTLYARS may request additional information, correct inaccurate records, restrict platform features, remove listings, suspend or terminate accounts, and cooperate with competent authorities where required by law. This Policy may be updated from time to time to reflect changes in legislation, services, technology, or financial-crime risks.
Current Functionality. This Policy establishes KOTLYARS' compliance framework and authority to perform risk-based reviews. It does not mean that a fully automated banking-style AML/KYC system is currently operational. Future technical implementation, provider selection, and workflow configuration will be introduced as separate development projects.
By using the KOTLYARS platform, users acknowledge that compliance measures may be applied where appropriate and agree to cooperate with reasonable verification requests necessary to protect the marketplace and comply with applicable legal requirements.