KYC (Know Your Customer) Policy

Conducted, inter alia, for the purpose of Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT)

Approved on April 01, 2025

The objectives of this KYC Policy are to protect the interests of the UFO.HOSTING service (hereinafter referred to as “the Company” or “the Service”) and its clients from unscrupulous clients and counterparties, as well as from clients and counterparties whose activities are associated with the legalization (laundering) of proceeds from crime and the financing of terrorism; to comply with the requirements of the legislation of the Russian Federation and international law in the field of AML/CFT; and to maintain the high reputation of the Company.

This KYC Policy has been developed in accordance with:

Federal Law No. 115-FZ “On Counteracting the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism”;
Federal Law No. 152-FZ “On Personal Data”;
Orders of Roskomnadzor (the Federal Service for Supervision of Communications, Information Technology and Mass Media) regarding the processing of personal data.

Additional Objectives of the Policy:

To prevent the use of the Company’s services for fraud, money laundering, cybercrime, and other unlawful activities.
To comply with the requirements of regulators (Rosfinmonitoring, Roskomnadzor, the Bank of Russia).
To protect the personal data of clients.

This KYC Policy is designed to minimize the following types of risks for the Company:

Reputational Risk, which could lead to a negative image of the Service in the market.
Legal Risk, which could result in the Service being held liable for violations of applicable law, the imposition of various sanctions, and the loss of assets.
Minimization of Regulatory Risk, which is integral in nature, as the risk associated with the aggregate of all operations conducted by the Service.
Prevention of the use of the Company’s services for fraud, money laundering, cybercrime, and other unlawful activities.
Compliance with the requirements of regulators (e.g., Rosfinmonitoring, Roskomnadzor, the Bank of Russia).
Protection of clients’ personal data.

KYC Principles:

Legality: All procedures comply with the norms of Federal Law No. 115-FZ, Federal Law No. 152-FZ, and other regulatory acts of the Russian Federation.
Confidentiality: Data is protected in accordance with Federal Law No. 152-FZ and FSTEC Order No. 21.
Identification: The identification of clients—both individuals and legal entities—is mandatory.
Timeliness: Accounts are blocked within 24 hours upon detection of suspicious transactions.

The User expresses their consent to this Policy from the moment they commence a relationship with UFO.HOSTING by entering into an agreement/public offer.

UFO.HOSTING guarantees users full confidentiality and security of personal data, in accordance with the provisions stated on the website https://ufo.hosting/.

The abbreviation AML/CFT stands for “Anti-Money Laundering and Combating the Financing of Terrorism.”

1. General Provisions

1.1. To consolidate efforts in preventing involvement in transactions related to money laundering or the financing of terrorism, UFO.HOSTING employees are obliged to:

Take actions aimed at reducing the risks associated with involvement in money laundering or terrorist financing schemes (AML/CFT);
Coordinate their efforts in developing measures aimed at AML/CFT;
Participate in information sharing to disseminate current information and best practices for internal control for AML/CFT purposes;
Provide mutual assistance in resolving issues related to the functioning of the system or the implementation of internal control rules for AML/CFT purposes, should they arise.

2. Internal Control Procedures for AML/CFT Purposes

2.1. The “Know Your Customer” (KYC) Rule
2.1.1. UFO.HOSTING must obtain the most complete and reliable information necessary to understand the purpose of a potential client’s engagement with UFO.HOSTING, as well as for the subsequent analysis of clients’ activities and their transactions.
2.1.2. The implementation of the KYC rule shall pursue two simultaneous goals: strengthening and developing the business of UFO.HOSTING, and ensuring effective work to prevent the infiltration of unscrupulous clients planning to conduct their activities (transactions) for the purpose of legalizing criminal proceeds or financing terrorism.
2.1.3. Taking into account business needs and in full compliance with applicable law, UFO.HOSTING applies the KYC rule using a risk-based approach. The principle of the risk-based approach consists in the differentiated application of the KYC rule and customer due diligence measures depending on the risk level assigned to the client.
2.1.4. The KYC rule involves not only collecting, analyzing, and processing information about a client upon their initial contact with UFO.HOSTING but also maintaining this information in an up-to-date state, for which UFO.HOSTING ensures the regular updating of previously obtained client information.

2.2 Customer Due Diligence (CDD) Measures

2.2.1. CDD measures are carried out to fulfill the KYC rule and include:
2.2.1.1. Identification of the client and the client’s representative (demographic data, identity documents, constituent documents, documents confirming location (registration), OGRN, INN), as well as other documents stipulated by applicable law.
2.2.1.2. Establishment of the beneficial owners of clients.
2.2.1.3. Identification of persons for whose benefit the client is acting (beneficiaries).
2.2.1.4. Determination of whether the client falls into the category of a Public Official.
2.2.1.5. Obtaining and analyzing information about the purpose and intended nature of the client’s relationship with UFO.HOSTING, information about the objectives of their financial and economic activities, and information about their financial situation.
2.2.1.6. Conducting ongoing due diligence of business relationships and analyzing transactions carried out by clients to confirm or refute that the economic substance of the transactions aligns with the stated purposes of the relationship.

2.3. Enhanced Due Diligence Measures

2.3.1. UFO.HOSTING takes lawful, reasonable, and available measures under the circumstances to prevent establishing relationships with:
2.3.1.1. Individuals and organizations that finance or support terrorist activities, or where there are grounds to suspect their involvement in financing and/or supporting terrorist activities.
2.3.1.2. Persons subject to international sanctions.
2.3.1.3. Persons intending to open anonymous accounts or access services and products under clearly fictitious names or pseudonyms.
2.3.2. UFO.HOSTING shall exercise reasonable caution when onboarding potential clients about whom there is negative information in open sources.

2.4. Monitoring of Client Activity

2.4.1. UFO.HOSTING ensures the ongoing monitoring of client transactions and activities.
2.4.2. Upon identifying transactions or client activities that meet legally established criteria, or transactions (activities) that, in the opinion of UFO.HOSTING, may be related to the legalization of criminal proceeds or the financing of terrorism, including attempts to conduct such transactions (activities), UFO.HOSTING shall mandatorily inform the authorized body. In such cases, UFO.HOSTING also reserves the right to terminate all legal relations with the client unilaterally without any compensation.

3. Staff Training

3.1. UFO.HOSTING recognizes that high-quality training of its employees in the AML/CFT field is the primary tool for building an effective internal control system.
3.2. Staff training is conducted on a regular basis, at least once a year. If necessary, additional staff training is provided in connection with the issuance of new legislative and regulatory requirements in the AML/CFT sphere or is organized to enhance the level of staff knowledge.

4. Final Provisions

4.1. The internal control system of UFO.HOSTING must ensure that audits of AML/CFT measures are conducted on a regular basis. These audits shall be carried out by employees whose functional duties do not include direct participation in the implementation of said measures.
4.2. In accordance with the requirements of applicable law and business ethics, UFO.HOSTING strives to ensure a level of interaction with supervisory and regulatory authorities that allows for the prompt receipt of clarifications and recommendations on the implementation of legally established requirements in the AML/CFT field.
4.3. UFO.HOSTING strictly adheres to the legislation of the Russian Federation and international security standards. We guarantee data protection for our clients and refuse service to individuals who violate the law.