Compliance Disclosure

1. SFERA LLC registration

SFERA is a Russian limited liability company. Corporate identifiers:

• Legal name: SFERA LLC (ООО "СФЕРА")
• INN (Taxpayer ID): 9715479324
• KPP (Tax Registration Reason Code): 771501001
• OGRN (State Registration Number): 1247700281685
• Registered office: Dezhnev Passage 1/2-1, 127081 Moscow, Russian Federation
• Director and sole authorised signatory: Zhang Qingshui
• Russian Export Center "Made in Russia" programme participant
• Registered with the Chamber of Commerce of the Russian Federation

2. KYC framework

Before any binding trade contract, every buyer undergoes Know Your Customer verification. Required submissions: certificate of incorporation, beneficial ownership disclosure (ultimate beneficial owner ≥25%), signatory identification (passport or equivalent), Proof of Funds covering at least 30% of CIF value, and trade-history references where available. KYC is reviewed by SFERA's compliance team; complete packages typically clear within three business days. We reserve the right to request additional documentation where any submission raises material questions.

3. Sanctions screening

Every buyer entity, every ultimate beneficial owner, every signatory, and (where applicable) every counterparty bank is screened against:

• OFAC SDN (United States)
• EU Consolidated Financial Sanctions List
• UK HMT Consolidated List
• UN Security Council Consolidated List
• Country-specific sanctions lists relevant to the trade corridor

Screening is repeated at FCO signing, SPA notarisation, and prior to APRG issuance. Any positive match suspends the trade pending compliance review.

4. AML procedures

SFERA operates Anti-Money Laundering procedures aligned with Russian Federal Law No. 115-FZ and FATF recommendations. All cross-border payments are routed through licensed banking infrastructure with full counterparty disclosure. Cash, crypto, and informal value transfer are not accepted. Suspicious activity is escalated internally and, where required by law, reported to the competent authority.

5. Advance Payment Refund Guarantee (APRG)

Buyer tariff payments are protected by an Advance Payment Refund Guarantee issued by a licensed Russian bank within two banking days of tariff receipt. The APRG is a refundable instrument: if SFERA fails to deliver in line with the SPA, the bank returns the tariff to the buyer on demand. The APRG is the mechanical counterpart to the contractual protections in the SPA.

6. CCI Arbitration

SFERA SPAs nominate Chamber of Commerce International (CCI) Arbitration as the binding dispute mechanism. CCI registration of the trade also produces the Authority-to-Verify in the buyer's name, which is the institutional check that lets the buyer's bank confirm SFERA's supply commitment before tariff release.

7. Document authenticity and verification

Every SFERA commercial document carries a unique SFR code. Anyone in possession of an SFR code can verify the document's authenticity at /verify by entering the code. Authenticity is bound to Zhang Qingshui's signature as sole authorised signatory of SFERA LLC.

8. Reporting concerns

To report a compliance concern — fraudulent use of the SFERA name, an SFR code that fails to verify, suspected misrepresentation by a counterparty, or any sanctions-related matter — email sales@sfera-rusexport.ru with subject line "Compliance enquiry". We respond to substantiated reports within five business days.

9. Related documents

See also Terms of Service, Privacy Policy, and Methodology.