1. General provisions

1.1. This Sanctions Compliance Policy (hereinafter referred to as the "Policy") establishes rules and procedures aimed at preventing the use of the 1ADK platform (hereinafter referred to as the "Platform") for purposes that contradict international, regional, and national sanction regimes.

1.2. The policy is mandatory for all Platform Clients and an integral part of the User Agreement and Offer Agreement.

1.3. The Platform is managed by the limited liability company SIA "FinMV" (registration number: 40203378371, legal address: Vesetas iela 10–95, Rīga, LV-1013, Republic of Latvia) (hereinafter referred to as the "Company").

2. Sanction regimes

2.1. The company undertakes to comply with the requirements and restrictions established by: the European Union; the United States of America (OFAC - Office of Foreign Assets Control); the United Kingdom (UK Sanctions List); the United Nations; other national regulators in jurisdictions where the Company operates.

2.2. Clients undertake to independently ensure compliance with the applicable sanction regimes in their jurisdictions.

3. Prohibited categories of clients and transactions

3.1. The company does not provide services and does not allow registration on the Platform to individuals and organizations included in the following categories: individuals and organizations included in the official sanction lists of the EU, OFAC, HM Treasury, or the UN; legal entities controlled or owned by individuals from sanction lists; companies and individuals from countries subject to comprehensive international sanctions; clients whose activities are related to industries directly restricted by sanctions (e.g. defense industry, export/import of dual-use goods).

4. Clients' responsibilities

4.1. Clients undertake to provide accurate information about themselves during registration and to use the Platform solely for purposes that do not violate sanctions regimes.

4.2. Clients are fully responsible for violating sanctions legislation in the course of their activities, including working with the Leads they receive.

5. Company rights

5.1. The company reserves the right to: conduct checks on Clients and their counterparties against open sanction lists (screening); request additional information and documents from Clients (for example, as part of the KYC procedure); refuse to provide services or block a Client's account if a risk of violating sanction regimes is identified; unilaterally terminate contractual relations with a Client in case of identifying a sanction risk, without refunding funds.

6. Responsibility

6.1. The client is solely responsible for any violation of sanctions legislation as a result of using the Platform.

6.2. The company is not responsible for the actions of the Client that are beyond its control, but may provide information about identified violations to the competent authorities.

7. Final provisions

7.1. This Policy shall enter into force upon its publication on the Platform.

7.2. The company reserves the right to unilaterally change this Policy.

7.3. The current version of the Policy is published on the Platform and is mandatory for all Clients.