Omara Jewelry
Omara Jewelry
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Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy for Omara s.r.o.

Date Prepared: October 01, 2025

This Policy applies to the Omara s.r.o.  (further on referred to as “Company”, “Omara”, “we”, “us”, or “our”) and its online e-commerce stores as well as any other media form, media channel, mobile website, or mobile application related, linked, or otherwise connected thereto (collectively, the “Site”). We are registered in Bratislava, Slovakia, and have our registered office on Obchodna Street, Bratislava-Staré Mesto; Company ID:  55091831

We are a EU-based online retailer specializing in customized jewelry products. Omara adheres to the EU's 6th Anti-Money Laundering Directive (6AMLD) and the new AML Package (effective from July 2024, with direct application phases through 2027), including 2025 updates such as the revised high-risk jurisdictions list (June 2025). These regulations expand scope for luxury goods dealers like us, emphasizing harmonized AML/CFT programs, enhanced transparency, and risk-based approaches for precious metals and stones (PMS) under the EU's Conflict Minerals Regulation (2017/821). Our policy mitigates ML/TF risks in e-commerce while ensuring ethical US-and the EU-sourced supply.

We sell exclusively to the EU-based customers via card payments through Stripe (with capability for other EU/US payment gateways) and no cash accepted.

This policy is reviewed annually, with records retained for 5–10 years per 6AMLD.

1. Customer Due Diligence and KYC

Omara applies a proportionate, risk-based CDD/KYC framework under the AML Package's luxury sector guidelines, using simplified due diligence (SDD) for most low-risk EU transactions and enhanced due diligence (EDD) for elevated risks. Measures integrate with payment gateways' verification, completed at checkout to comply with PSD2/6AMLD while minimizing disruption.

  • Simplified Due Diligence (SDD) for Low-Risk Customers (orders under €5,000 from standard EU addresses): Verify basic data from checkout against payment gateway signals and screen against EU sanctions (e.g., Consolidated List, updated 2025 high-risk jurisdictions). No extra ID needed for routine domestic orders;
  • Enhanced Due Diligence (EDD) for Medium/High-Risk Customers (orders €5,000+, atypical patterns, or links to high-risk areas): Mandate ID request and address proof from the buyer. Leverage gateway biometrics if flagged, plus PEP/adverse media screening by Omara. Omara holds transactions pending 24-hour approval.

Ongoing annual reviews for repeat customers align with 2025 AML Package transparency rules. As a small store, we focus on efficiency, documenting all for FIU audits.

2. Criteria for Rejecting Dealing with a Customer

Per 6AMLD and 2025 AML updates, Omara  rejects high-ML/TF risk customers to protect our operations, with decisions by the AML Officer (company owner) logged for traceability. Notifications cite "compliance review," escalating suspicions to the national FIU. Criteria, informed by luxury goods risks, include:

  • Sanctions/Watchlist Hits
  • Elevated Risk Signals from the Payment Gateways
  • Behavioral Red Flags
  • PEP/Adverse Ties
  • Verification Failures

3. Tools for Monitoring Transactions and Reporting Suspicious Activity

Omara leverages embedded AML tools in our primary payment gateway (Stripe) for real-time monitoring, meeting 6AMLD/AML Package requirements without standalone systems—suitable for our low-volume sales. We accept cards only, reducing cash-related risks, and monitor for e-commerce indicators like velocity or geo-anomalies. Integration capability exists for the EU/US gateways  like Mollie for diversified compliance. SARs filed on suspicions only, no volume thresholds, with 2025 high-risk updates integrated via gateway feeds.

4. No Cash Payments

Omara does not accept the cash payments for the goods from the Customers. All payments are done solely via the EU/US based payment gateways like Stripe (currently) and Mollie (expected). 

5. Due Diligence on Suppliers

Omara has a single and exclusive US-based vendor for the customized jewelry and the EU-based vendor for the certified natural and lab-created diamonds. All diamonds are supplied with the GIA-certificates, deemed low-risk under EU AML Package luxury guidelines and US FinCEN PMS rules. Omara does not source the jewelry or components from the high-risk regions/goods. 

Omara does a continuous oversight of its US and the EU vendors vs the public media sources and sanctions/public records.

Policy Approved by Vladyslav Chubuk, Business Owner