AML and KYC Policy — Omara s.r.o.

This Policy sets out how Omara s.r.o. prevents money laundering, terrorist financing and sanctions breaches across its online stores, including the store for customers in Austria. It applies to all sales channels, websites and applications operated by Omara.

Company: Omara s.r.o., Obchodná 559/37, 811 06 Bratislava, Slovakia. Company ID (IČO): 55091831.

Business: Omara designs and sells gold, platinum and silver jewelry set with lab-grown and natural diamonds and gemstones. Most items are made to order. Omara sells and delivers only to customers in the European Union.

Legal framework. Omara does not accept cash. It is therefore not currently an obliged entity under Slovak Act No. 297/2008 Coll. on the Prevention of Money Laundering and Terrorist Financing. Omara applies the measures in this Policy voluntarily, on a risk-based approach, because jewelry and precious stones carry elevated money-laundering risk. The Policy also prepares Omara for Regulation (EU) 2024/1624 (AMLR), which applies from 10 July 2027 and extends AML obligations to traders in precious metals and stones.

Omara also complies with:

  • EU restrictive measures (sanctions), including Council Regulations (EU) No 269/2014 and No 833/2014 and the EU ban on Russian-origin diamonds
  • Council Regulation (EC) No 2368/2002 implementing the Kimberley Process certification scheme
  • Regulation (EU) 2016/679 (GDPR) and Slovak Act No. 18/2018 Coll. on personal data protection

AML Officer. The company owner, Vladyslav Chubuk, acts as AML Officer. The AML Officer approves enhanced checks, decides on refusals, keeps the records described in this Policy and reports suspicions to the authorities. Contact: info@omara.sk.

2. Accepted payment methods

Omara accepts only non-cash payments. On the store for customers in Austria, bank transfer is currently the only available payment method. Online payment methods through a regulated payment service provider will be added later, and this Policy will be updated accordingly.

Method

Notes

Bank transfer

From an account held in the customer's name only

Omara does not accept cash, cryptocurrency, money orders or payments from third parties. For every bank transfer, Omara checks that the account holder's name matches the order details. If the name differs and this is not explained and documented, the payment is returned to the sending account and the order is cancelled. Production starts only after the payment has been received and the check has been passed.

3. Customer due diligence (KYC)

Omara applies standard checks to every order and enhanced checks to orders of €10,000 or more, or to any order showing risk signals.

Standard due diligence (orders below €10,000). Omara verifies that the name, billing details and delivery address of the order are consistent, and that the name on the sending account matches the customer. Delivery is made only to addresses in the EU.

Enhanced due diligence (orders of €10,000 or more, or risk signals). Before production starts, Omara:

  1. Requests a valid government-issued photo ID from the customer.
  2. Confirms that the name on the ID matches the holder of the sending account.
  3. Screens the customer against the EU consolidated sanctions list.
  4. Checks whether the customer is a politically exposed person (PEP) or linked to adverse media.
  5. For orders above €30,000 or where the source of funds is unclear, asks the customer to explain the source of funds.

Production starts only after the AML Officer approves the order. Orders from the same customer, from the same account or to the same delivery address within 30 days are added together to decide whether the €10,000 threshold is reached.

Sanctions screening. Omara checks customer names against the EU consolidated list of persons subject to financial sanctions for every enhanced-review order and whenever a risk signal appears. The date, the source checked and the result are recorded. A confirmed match leads to refusal of the order and a report to the authorities.

4. Risk signals, refusals, gift cards and refunds

Omara refuses or cancels any order it cannot verify or that presents an unacceptable risk.

Risk signals that trigger enhanced review:

  • Name mismatch between customer, sending account and delivery recipient
  • Several partial payments from different accounts for one order
  • Pressure to ship urgently or to bypass checks
  • Orders split to stay below €10,000
  • Payment by a third party, or a request to refund to a different account
  • Payments from accounts outside the EU
  • Links to high-risk third countries listed by the European Commission

Refusal criteria. Omara refuses an order when the customer appears on a sanctions list, fails or refuses verification, provides false or inconsistent information, or when the AML Officer has reasonable grounds to suspect money laundering or terrorist financing. Decisions and reasons are logged. The customer is told only that the order could not be accepted after a compliance review.

Gift cards. Omara gift cards are issued up to €1,000 each. Gift cards cannot be exchanged for cash, cannot be purchased with another gift card, and are refunded only to the original payment method. Gift card purchases above €1,000 by one customer within 30 days are reviewed.

Refunds. Refunds are paid only to the account the payment came from. Omara never refunds in cash or to a third party.

5. Supplier due diligence and sourcing

Omara's jewelry is manufactured in Slovakia. When the Slovak manufacturer cannot handle the volume, production is occasionally placed with a manufacturer in India.

Diamonds and gemstones. Omara sells both lab-grown and natural diamonds.

  • Every diamond of 0.20 ct or more is supplied with a grading report from IGI or GIA.
  • Smaller accent stones are supplied by the Slovak manufacturer without individual grading reports. For natural stones, the supplier's invoice must carry a written assurance under the Kimberley Process and the World Diamond Council System of Warranties.
  • Lab-grown diamonds are always disclosed as lab-grown.

No Russian-origin diamonds. In line with EU sanctions, Omara does not buy or sell diamonds mined, processed or originating in Russia, including stones cut in third countries. Each supplier of natural diamonds provides a written declaration of non-Russian origin.

Supplier checks. Before onboarding and at least once a year, Omara verifies each supplier's company registration, screens the supplier and its owners against EU sanctions lists, and reviews public adverse media. Payments to suppliers are made only by bank transfer to accounts in the supplier's own name.

6. Reporting, record keeping and review

Reporting suspicious activity. If the AML Officer suspects money laundering or terrorist financing, Omara suspends the order and reports it to the Slovak Financial Intelligence Unit (Finančná spravodajská jednotka). Omara does not inform the customer that a report has been made. Suspected sanctions breaches are reported to the competent Slovak authorities.

Record keeping. Omara keeps the following for 5 years after the order is completed: order and payment records, the results of enhanced reviews and sanctions screening, refusal decisions with their reasons, and supplier due diligence files.

Data protection. Personal data collected under this Policy is processed only to prevent money laundering, fraud and sanctions breaches, in line with the GDPR and Omara's Privacy Policy. Identity documents are requested only for enhanced reviews. They are stored encrypted, accessible only to the AML Officer, and deleted at the end of the retention period.

Review. The AML Officer reviews this Policy at least once a year and whenever the law, payment methods or supply chain change.

Policy approved by Vladyslav Chubuk, Owner and AML Officer, Omara s.r.o.