AML protocol & Embargo

AML Protocol

1) The company Atomic Star, s.r.o. is an obliged entity pursuant to Act No. 253/2008 Coll., on selected measures against legitimisation of proceeds of crime and financing of terrorism, as amended ("AML Act"). In accordance with the AML Act, a person dealing in works of art according to Annex No. 3 to this Act is the obligated entity, if their value reaches at least EUR 10,000.
The company is the obligated entity and must have a system of internal policies, procedures and control measures ("AML System"). The administrative supervision in the form of preventive and targeted checks regarding the fulfilment of the obligations stipulated by the AML Act is carried out by the Czech Trade Inspection for persons dealing in cultural monuments or objects of cultural value, or mediating such transactions. The AML

Act establishes the following obligations:

• a) Identify the client
• b) Refuse to carry out a transaction if there are any doubts about the veracity of the obtained identification data of the client, if the client refuses to submit to identification or refuses to document authorization, unless the authorization can be ascertained from the public register; the obliged entity informs the Czech Trade Inspection about this fact at the same time
• c) Perform a client check
• d) Store information
• e) Report suspicious transactions
• f) Provide information to the Czech Trade Inspection and the client
• g) Maintain confidentiality.

If the company, as the obliged entity under the AML Act, discovers a suspicious transaction in connection with its activities, it shall report this transaction to the Czech Trade Inspection without undue delay. If the circumstances of the case require it, especially if there is a risk of delay, the obliged person shall report the suspicious transaction immediately after its detection. Suspicious business can also be conduct that does not directly lead to the conclusion of a business, but arouses reasonable suspicion.

Embargo

A Customer of Atomic Star sro (Buyer) always confirmed that:

The Parties undertake to provide each other with the necessary cooperation in deregistering/registering the Subject of Purchase at the relevant authorities.
I confirm that I am the Purchaser of the Products/Services described in Section 2 and I am not listed on any sanctions list maintained by the United Kingdom (the “UK”), the European Union (the “EU”), or the United States of America (the “US”) (a “Sanctions Target”). I certify that the Products/Services will NOT be transferred, re-sold, re-exported or otherwise made available to any person or entity that is a Sanctions Target or to any organisation owned or controlled by a Sanctions Target. I certify that the Products/Services will NOT be transferred, re-exported, re-sold, or otherwise made available to any person or organisation who is in a market which is subject to comprehensive sanctions or are otherwise subject to extraordinary levels of trade controls by the UK, EU or US including the territories listed below (“Sanctioned Market”), whether for use in a Sanctioned Market or to any company (or its subsidiaries) or person(s) who are domiciled, resident or located in a Sanctioned Market.

The territories which are Sanctioned Markets include Iran, Syria, North Korea, Sudan, Cuba and the Crimea, Luhansk, Donetsk, Kherson and Zaporizhzhia Regions of Ukraine, Russia and Belarus. As the Buyer is a [business] the Buyer undertakes the obligation to carry out all necessary checks on any person(s) whom the Purchaser permits to use, transfers, re-exports, re-sells or otherwise makes available the Products/Services whilst the Purchaser so as to ensure compliance due to the EU laws.