Terms of Use

1. About Flex AML Hub

Flex AML Hub provides practical AML tools, courses, information and decision-support resources designed primarily for virtual office, flexible workspace and trust or company service provider (TCSP) businesses.

Flex AML Hub is intended to support users' understanding and judgement. It does not replace your organisation's own AML responsibilities, policies, procedures, risk assessments or professional judgement.

Use of the Hub does not create a legal, regulatory, consultancy or other professional advisory relationship between Flex AML and you or your organisation unless separately agreed in writing.

2. Free and early access

Flex AML Hub is currently provided on a free trial and/or early-access basis.

Free access does not create a right to continued free access.

We may:

• change or improve features;
• add or remove functionality;
• change questions, content or Calculator logic;
• introduce usage limits;
• introduce paid services or subscriptions;
• temporarily suspend access for maintenance, development or security; or
• change or end the free trial.

The service is still developing and errors, interruptions or changes may occur.

3. Your account

You are responsible for providing accurate account information and keeping your login details secure.

Unless we provide specific team functionality, accounts should not be shared with unauthorised users.

If you create or use an account on behalf of an organisation, you confirm that you are authorised to do so.

We may suspend or terminate access where we reasonably believe an account is being misused, security is at risk or these Terms have been breached.

4. Compliance Calculator

The Compliance Calculator is a practical AML sense-check and decision-support tool.

It may help identify information or combinations of information that deserve consideration or further review.

It is not:

• an AML customer risk assessment;
• approval or rejection of a customer;
• confirmation that a customer is safe, compliant or suitable;
• legal or regulatory advice;
• a substitute for CDD or EDD;
• a substitute for sanctions or PEP screening;
• a substitute for ongoing monitoring;
• a substitute for your organisation's AML policies, procedures or Business-Wide Risk Assessment; or
• a guarantee that every relevant risk or consideration has been identified.

A result showing no particular concern does not mean that a customer is risk-free or should automatically be accepted.

Likewise, a finding generated by the Calculator does not necessarily mean that a customer must be rejected.

5. Your responsibility for AML decisions

You and your organisation remain responsible for determining and meeting the legal, regulatory, supervisory and internal requirements that apply to you.

This includes, where applicable:

• CDD and verification;
• beneficial ownership;
• customer risk assessment;
• EDD;
• PEP and sanctions controls;
• ongoing monitoring;
• record keeping;
• escalation and suspicious activity reporting; and
• customer acceptance, continuation or termination decisions.

The Calculator can only consider the information entered and the indicators and logic available within the tool at that time.

Flex AML does not independently verify information entered into the Calculator unless expressly stated.

You must not rely solely on a Flex AML Hub output when making an AML, regulatory, compliance or customer-acceptance decision.

Where appropriate, findings should be reviewed by your MLRO, nominated officer or another appropriately authorised person.

6. AML Courses

AML Courses are provided for education, awareness and professional development.

They do not constitute legal or regulatory advice and should be used alongside your organisation's own AML policies, procedures and training requirements.

Unless expressly stated otherwise, completing a Flex AML course:

• is not a professional qualification or accreditation;
• does not constitute approval by HMRC or another regulator or supervisory body;
• does not certify an individual or organisation as compliant; and
• does not guarantee that every training requirement applicable to an organisation has been satisfied.

7. Accuracy, changes and automated technology

We aim to make Flex AML Hub practical and accurate, but AML legislation, sanctions, regulatory guidance and other relevant information can change.

We do not guarantee that the Hub will always be complete, error-free or immediately updated following every change.

Flex AML Hub may also use automated rules or artificial intelligence. Automated or AI-assisted outputs may contain errors or omissions and must be considered using appropriate human judgement.

Users remain responsible for checking current official sources and obtaining professional advice where appropriate.

8. Information you enter

You are responsible for ensuring that you are entitled to enter information into Flex AML Hub and have an appropriate lawful basis where personal information about another individual is involved.

Only information reasonably necessary to use the relevant feature should be entered.

Unless specifically requested, do not upload identity documents, passwords, payment card information or unnecessary sensitive personal information.

Our handling of personal information is explained in our Privacy Notice.

9. Feedback and improving the Hub

The free trial is partly intended to help us improve Flex AML Hub ahead of wider launch.

If you voluntarily provide feedback, comments, suggestions or ideas, you agree that Flex AML may use them without payment to develop and improve the Hub, Compliance Calculator, AML Courses and future Flex AML products and services.

Do not provide confidential information belonging to another organisation unless you are authorised to do so.

10. Intellectual property and acceptable use

Flex AML Hub and its original content, including its Calculator logic and frameworks, questions, workflows, AML Courses, training materials, explanations, designs and branding, are owned by or licensed to Flex AML.

You are given a limited right to use the Hub for legitimate internal business purposes.

Unless permitted by law or agreed by Flex AML in writing, you must not:

• copy or redistribute substantial parts of the Hub;
• reproduce Flex AML Courses as your own training;
• resell or sublicense access;
• systematically extract or scrape content;
• attempt to recreate proprietary Calculator logic or methodologies;
• interfere with the security or operation of the Hub;
• use the Hub unlawfully; or
• represent a Flex AML output as legal advice, regulatory approval or customer approval by Flex AML.

11. Availability and liability

Flex AML Hub is currently a free, developing business service.

We do not guarantee uninterrupted availability or that every error, AML consideration or regulatory issue will be identified.

You should not use Flex AML Hub as the sole repository for records your organisation is required to retain.

Nothing in these Terms excludes or restricts liability where it would be unlawful to do so, including liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation.

Subject to that and to the extent permitted by law, Flex AML will not be responsible for losses arising from:

• reliance solely on a Flex AML Hub output;
• inaccurate, incomplete or outdated information entered by a user;
• customer acceptance, rejection or continuation decisions;
• failure to complete appropriate CDD, EDD, screening, monitoring or escalation;
• failure to follow applicable requirements or your organisation's own procedures;
• changes in legislation, guidance or external information not yet reflected within the Hub;
• third-party services or information;
• temporary unavailability of the free service; or
• use of Flex AML Hub outside its intended purpose.

To the extent permitted by law, Flex AML will not be liable for indirect or consequential loss or for loss of profit, revenue, business, opportunity, anticipated savings or goodwill arising from use of the free Flex AML Hub.

12. Ending access, changes and governing law

You may stop using Flex AML Hub and request closure of your account at any time by contacting [email protected].

We may suspend or end access where reasonably necessary, including for misuse, security concerns, breach of these Terms or discontinuation of the free service.

We may update these Terms as Flex AML Hub develops. The latest version will be available through the Hub, and we will take reasonable steps to bring material changes to existing users' attention.

These Terms are governed by the laws of England and Wales, and the courts of England and Wales will have jurisdiction over disputes arising from them, subject to applicable law.

Questions about these Terms can be sent to:

[email protected]