Last updated: 2025-04-11
ЗАО ОнСикс ('Company') warns users against attempts to use the Company's services for money laundering, terrorist financing, fraud, any other illegal activities, or the purchase of prohibited goods and services. The Company also cautions clients against attempts to conceal information linking them to sanctions lists of legal entities and individuals, countries, or other restrictions.
1. General Information
The AML/KYC Policy is developed by the Company in accordance with international and national standards to prevent money laundering, terrorist financing, drug and human trafficking, the proliferation of weapons of mass destruction, corruption, and bribery, as well as to promptly respond to any suspicious activity by users of the site https://onesix.tech/ ('Site') and/or the Company's products/services.
The Policy establishes control systems and mechanisms to prevent the involvement of the Company and/or its services in money laundering, terrorist financing, or sanctions violations, as well as to maintain the Company's reputation when interacting with clients, counterparties, and authorities.
This Policy describes the core standards, principles, rules, and approaches applied by the Company to study its clients and counterparties, conduct risk management measures for money laundering, terrorist financing, sanctions, and countries.
Internal documents on AML/CTF risk management and KYC/CDD procedures are developed by the Company separately and are confidential information with limited access. Such documents comply with this Policy.
The Company ensures compliance with the requirements of this Policy and applicable legislation by all its employees.
In the context of the Policy, the terms 'Site', 'Onesix', 'Company', 'we', 'us', or 'our' refer to ЗАО ОнСикс, including, without limitation, its owners, directors, investors, employees, and other related parties. Depending on the context, 'Onesix' may also denote services, products, the website, content, or other materials provided by Onesix. This Policy is an integral part of the Terms of Use. By accepting the Terms of Use, you automatically agree to this Policy.
All terms in this Policy written in capital letters and not otherwise defined have the same meanings as in the Terms of Use.
2. Definitions
Terms written in capital letters have the following meanings:
Onesix
The Onesix Site and/or the company providing services on the Onesix site.
Onesix System Verifier
The person responsible for the effective implementation and compliance with this Policy.
Money Laundering
Concealing the illegal source of funds by transferring them into assets or investments that appear legitimate.
Prohibited Behavior
Any illegal behavior, including fraud, corruption, money laundering, collusion, terrorist financing, and other criminal actions.
Fraud
The use of deception for personal gain or to harm the interests of Users and/or Onesix by stealing property or acquiring rights to it through deceit.
Scam
A method of fraud aimed at obtaining money or property by providing false information or concealing data for extortion.
Corruption
Offering, providing, receiving, or soliciting values (directly or indirectly) to improperly influence the actions of another party.
Money Laundering
Financial operations aimed at concealing the identity, source, and purpose of illegally obtained funds or financing illegal activities to give them a legitimate appearance.
Anti-Money Laundering (AML)
A set of measures and procedures aimed at identifying and preventing the use of the Company, the Onesix Site, and/or the services provided for money laundering purposes.
Counter-Terrorist Financing (CTF)
A set of measures and procedures aimed at identifying and preventing the use of the Company, the Onesix Site, and/or the services provided for terrorist financing purposes.
Sanctions
Commercial and financial restrictions imposed by one or more countries against states, groups, or individuals.
Red Flags
Warnings or indicators pointing to potential issues or threats in a Client's transactions processed by the Company and/or its services.
Collusion
An arrangement between parties aimed at achieving an improper goal, including improperly influencing the actions of another party.
Transaction
Any operation with digital assets conducted by the User through the Site.
Terrorist Financing
Raising or providing funds for planning or committing terrorist acts, financing terrorist organizations, or using funds for such purposes.
Criminal Behavior
Actions classified as crimes in any jurisdiction worldwide.
Customer Due Diligence (CDD)
Verification of client data and their activities to assess risks when onboarding and during interaction.
Politically Exposed Person (PEP)
An individual who holds a prominent public position in a country or internationally.
Regulatory Requirements
Any applicable law, regulation, order, court decision, rule, policy (including but not limited to the KYC/AML Policy), or guideline adopted by parliament, government, court, authority, or payment system (e.g., banking systems, Visa, MasterCard, or other settlement systems) used to provide services.
3. General Provisions
3.1. This AML/KYC Policy is a set of rules and measures aimed at preventing and minimizing the risks of the Company's involvement in illegal activities, as well as fulfilling obligations to counter money laundering and terrorist financing in accordance with international and national legislation.
3.2. To ensure the quality and timely provision of services, the Company and its clients are required to comply with the requirements of international and national laws on anti-money laundering and counter-terrorist financing, as well as other regulations related to the Company's activities.
3.3. To implement the provisions of this Policy, the Company develops and implements an internal system for assessing client and transaction risks, defines a minimum set of procedures, mechanisms, reports, and control measures. Enhanced procedures are applied to high-risk clients and transactions.
3.4. The Company reserves the right to amend this Policy at its discretion (due to the identification of new risks, the introduction of new products/services, changes in legislation) and to monitor compliance with its provisions.
3.5. This Policy is part of the User Agreement. By accepting the terms of the User Agreement, you automatically agree to the AML/KYC Policy.
3.6. Please carefully review this AML/KYC Policy. For any questions related to the Policy, you may contact us at: compliance@onesix.tech.
3.7. The terms 'User', 'You', 'Your', etc., refer to the person using the Site and/or the Company's products/services, subject to this AML/KYC Policy, the Privacy Policy, and the User Agreement.
4. Verifier
4.1. To implement and monitor the procedures provided for in the AML/KYC Policy, the Company appoints a Verifier.
4.2. The Verifier develops procedures for User identification, verification, and monitoring of unusual transactions. The Verifier's responsibilities include:
- collecting the User's personal data;
- developing and updating internal policies and procedures for preparing, reviewing, storing reports, and records in accordance with the law;
- monitoring the User's actions and analyzing deviations from standard activity;
- implementing a record-keeping system for storing and retrieving documents, forms, and logs;
- regularly updating risk assessments;
- providing law enforcement agencies with information in accordance with the law.
4.3. The Verifier acts as the Company's contact person when interacting with law enforcement agencies to prevent money laundering, terrorist financing, and other illegal activities.
5. Company Rights Under the AML/KYC Policy
5.1. User identification is conducted by analyzing their data and behavior patterns. The Company uses data analysis as a tool for risk assessment and identifying suspicious activity, collecting and systematizing data, maintaining records, and reporting.
5.2. In accordance with this Policy, the Company undertakes to monitor User actions and reserves the right to:
- interact with law enforcement agencies by reporting suspicious activity;
- request additional information or documents from the User if suspicious actions are detected;
- suspend (fully or partially) the User's access to the account on the Site if there are reasonable suspicions of involvement in illegal activities.
5.3. This list is not exhaustive. The Verifier determines whether the User's actions are suspicious and whether they require notification of law enforcement agencies.
6. Verification Procedure
6.1. Proper User verification is an international standard for preventing illegal activities. The Company establishes its own verification procedures under this AML/KYC Policy.
6.2. The Verifier has the right to require Users to provide documents confirming their identity.
6.3. To complete verification, the User must provide official documents from independent sources (e.g., national ID, international passport, bank statement, utility bill). The Verifier may request personal data and take measures to confirm their authenticity, as well as collect information about the User if their actions are classified as suspicious.
6.4. The Verifier is not obligated to verify the legality of the provided documents but may request additional data in case of obvious discrepancies. The User must provide the requested data within 5 days. Refusal to provide information or an attempt to mislead the Verifier may result in denial of services.
6.5. The Verifier may conduct regular checks of the User's identity, especially in case of changes to personal data or suspicious activity, and request updated documents, even if the User has previously passed verification.
6.6. The collection, storage, disclosure, and protection of personal data are carried out in accordance with the Privacy Policy and only to the extent necessary for the provision of services.
6.7. After establishing the User's identity, the Verifier may disclaim liability if the Company's services are used for illegal activities.
6.8. If signs of suspicious activity (e.g., related to money laundering, terrorist financing, corruption) are detected, the information is forwarded to the competent authorities without prior notice to the User.
6.9. The Verifier relies on lists published by local and international authorities (e.g., OFAC, EU, UN), including individuals suspected of terrorism, terrorist organizations, high-risk countries, or sanctioned jurisdictions, to determine the User's status or jurisdiction.
6.10. The Company collects personal data only to the extent necessary for the provision of services. Data may be transferred to third parties only in cases provided by law, requests from authorities, or the Privacy Policy.
6.11. The Company may suspend an account associated with suspicious activity (e.g., money laundering, scams) and request additional documents for enhanced KYC verification. If documents are not provided or are insufficient, the Company may temporarily or indefinitely suspend services, up to blocking the account and assets.
6.12. The Company may request additional information about high-risk Users or when their data changes, even if they have previously passed verification.
7. Risk Assessment
7.1. To fulfill obligations to counter money laundering and terrorist financing, the Company conducts an annual risk assessment to prevent the use of the Site and/or services for illegal purposes. The assessment includes risk analysis and the effectiveness of control measures.
7.2. The Verifier is responsible for managing financial crime risks, identifying general and specific money laundering risks, assessing control measures, and determining residual risk.
7.3. Any transaction related to money laundering, terrorist financing, sanctions violations, or scams is considered suspicious.
7.4. The Company develops mechanisms to detect such transactions, including 'red flag' criteria. Suspicion may arise from employee observations, KYC data, analytical programs, and other sources.
7.5. The Company regularly monitors transactions, updates 'red flag' criteria, and implements best international practices to identify suspicious activity.
7.6. If necessary, the Company notifies regulatory or law enforcement agencies of suspicious transactions and provides information upon their requests without notifying the User.
7.7. The Company uses the following lists to analyze clients and transactions:
- sanctions lists, terrorist or suspected terrorist lists (OFAC, EU, UN, etc.);
- jurisdictions with insufficient anti-money laundering measures (by FATF standards);
- high-risk or sanctioned countries (OFAC, EU, UN).
7.8. The Company conducts ongoing checks of clients and their transactions to ensure compliance with client information, their business, and income sources.
7.9. The Company does not establish relationships with clients listed in sanctions lists, registered in prohibited jurisdictions, or controlled by such individuals.
7.10. If an unacceptably high level of risk is identified, the Company may refuse further service to the client.
7.11. If suspicious transactions are detected, the Company may request additional documents, suspend or terminate the account, freeze assets, and take other measures appropriate to the risks.
8. Third Parties
8.1. To perform certain functions, the Company may engage third-party service providers or counterparties. The Company examines their reputation, licenses, permits, and investigations against them before establishing business relationships.
8.2. The Company does not cooperate with suppliers or counterparties listed in sanctions lists, registered in prohibited jurisdictions, or controlled by such individuals.
9. Changes to the AML/KYC Policy
9.1. The Company reserves the right to amend this AML/KYC Policy at any time. The current version is published on the site https://onesix.tech/.
9.2. The User is obliged to periodically review the AML/KYC Policy and familiarize themselves with the changes.
10. User Obligations
By using the Site and/or the Company's services, the User guarantees that they do not intend to commit prohibited actions described in this Policy. The User agrees to undergo checks as part of investigations under the AML/KYC Policy and promptly cooperate with the Verifier and authorized persons. Refusal to cooperate or failure to provide necessary data may result in suspension or termination of services.