AML PROOF Platform Terms of Service

2.1 AML Proof s.r.o. operates the AML PROOF Platform, which is intended exclusively for obliged entities within the meaning of Section 2 of the AML Act (in particular attorneys, real estate agents, accountants, exchange offices, and other entities with AML obligations) for the purpose of fulfilling their statutory obligations.

2.2 These Terms of Service govern, in accordance with Section 1751 of the Civil Code, all contractual relationships between AML Proof s.r.o. and the Client arising in connection with use of the Platform.

2.3 By using the Platform or entering into the Agreement, the Client agrees to these Terms of Service and confirms that they have duly familiarized themselves with them.

2.4 The Platform does not provide legal or compliance advice. Final responsibility for risk assessment, approval of a business relationship, or rejection of a transaction always rests fully with the designated person of the obliged entity.

3.2 Data sources are synchronized automatically, typically once a day. Each Screening result is marked with the date of performance and the version of each data source used. This record forms part of the Audit trail.

3.3 Derived PEP (persons close to primary PEP and persons in a close business relationship with PEP) are not screened as a separate category within automated Screening, given the low quality and reliability of publicly available data on such persons. Identification of derived PEP is the User's responsibility within their own enhanced due diligence under Section 9 of the AML Act.

3.4 AML Proof s.r.o. does not participate in creating third-party data sources and does not assume responsibility for their completeness, accuracy, or timeliness.

4.1 Registration on the Platform is free of charge. The User must provide truthful and complete information when registering.

4.2 The Platform is intended exclusively for obliged entities under Section 2 of the AML Act. The Client declares that they are an obliged entity and will use the Platform solely to fulfill their obligations under the AML Act and legal regulations governing implementation of international sanctions.

4.3 The Client must ensure protection of access credentials to the Platform. The Platform offers optional two-factor authentication (2FA) via an authenticator app; each user may enable 2FA in their account settings. AML Proof s.r.o. is not liable for misuse of access credentials by third parties.

4.4 The User is not entitled to use the Platform for any purposes contrary to these Terms of Service or legal regulations, in particular for purposes other than fulfilling statutory AML obligations.

6.1 Risk assessments generated by the Platform are supportive and informational in nature. They serve to structure analysis and ensure auditability, not as a standalone decision-making mechanism. Final responsibility for client assessment, approval of a business relationship, or rejection of a transaction always rests fully with the designated person of the obliged entity.

6.2 Screening results are generated based on information from third-party databases and data sources, which serve informational purposes only. AML Proof s.r.o. does not participate in creating these sources and does not assume responsibility for their completeness, accuracy, or timeliness.

6.3 The risk methodology is continuously updated in line with developments in the regulatory environment. Each assessment is tied to the methodology version valid at the time it was performed. Methodology changes do not retroactively affect assessments already performed and stored.

6.4 AML Proof s.r.o.'s total liability to the Client is limited to the amount of fees paid by the Client for use of the Platform (in particular credit purchases and training) during the 12 months immediately preceding the claim. This limitation does not apply where exclusion of liability is prohibited by law.

6.5 AML Proof s.r.o. is not liable for indirect, consequential, or punitive damages arising in connection with use or inability to use the Platform.

6.6 Obliged entities are legally required to retain documentation of performed controls for 10 years under Section 16 of the AML Act. The Platform provides technical means to fulfill this archiving obligation; however, as an obliged entity, the Client is responsible for actually retaining documentation in accordance with the law (e.g. by maintaining active access to the Platform or exporting data).

8.1 Registration on the Platform and account maintenance are free of charge. Chargeable actions on the Platform are performed on the basis of consumption of prepaid credits. Organizational and personnel setup of the obliged entity, internal policies, team management, creation of AML cases, and client identification (Steps 1–2) do not deduct credits. Each new Client automatically receives four (4) free credits upon successful creation of the obliged entity profile for full use and testing of the Platform.

8.2 Credits are obtained through one-off purchase of credit bundles and are recorded in the Client's virtual wallet. Credit consumption works as follows:

• a) Screening (Step 3): one (1) credit per newly screened subject (client, beneficial owner, shareholder, etc.). Re-screening the same subject within the same AML case is not charged again.
• b) Risk assessment (Step 4): one (1) credit per saved WAR model run. Each further recalculation and save is charged again; preview without saving does not deduct credits.
• c) End control (Section 15): one (1) credit when you confirm the Section 15 end-of-control record and lock the case (End control button).
• d) Export of identification documents (step 3): one (1) credit per client included in the export. Each client is charged at most once per day regardless of how many times the same document is downloaded.
• e) Verified client transfer: one (1) credit when transferring a verified client to another obliged entity. Verified client acceptance: one (1) credit when accepting a client from another obliged entity.
• f) Actions without credit consumption: approvals and mock screening (preview). Finalisation and archiving of an AML case (step 6) has been charged at one (1) credit since July 2026.
• g) Scan to fill (step 2): one (1) credit per automatic extraction of client identification data from a scanned identity document. Use of this feature is optional — manually entering data does not consume credits.
• h) E-sign — sending a document for signature: one (1) credit per document sent to signatories for electronic signature. The credit is deducted upon confirming the send; document creation and PDF upload are not charged.
• i) Custom sending domain: five (5) credits per month for operating a custom sending domain (Platform emails are sent from the Client's own domain name). The fee is deducted automatically on the 1st day of each month for as long as the feature is active; if credits are insufficient, the feature is suspended.

A typical single-client AML case usually consumes at least three (3) credits (screening, risk assessment, and export of identification documents). A higher number of screened subjects or repeated risk recalculations increases consumption. The current credit bundle pricing is available at www.amlproof.ai/pricing. AML Proof s.r.o. reserves the right to change credit bundle prices unilaterally at any time without prior notice; this has no retroactive effect on credits already purchased.

8.4 Training of employees and persons in a similar position under Section 23 of the AML Act is available on the Platform as annual certification per team member. The current training price is listed in the Training section on the Platform and at www.amlproof.ai/pricing. AML Proof s.r.o. reserves the right to change training prices unilaterally at any time without prior notice; this has no retroactive effect on training already paid for.

8.5 All stated prices include VAT where applicable; the applicable VAT amount is itemized on the invoice issued at purchase.

8.6 Under the Enterprise tier, credits for screening (Step 3), risk assessment (Step 4), and end control (Section 15) are not deducted; terms and pricing are agreed individually.

8.7 An exception to the rules in Section 8.2(a) and (b) applies to so-called Historical cases (retroactive records of AML identifications and controls already performed). Creation and management of historical cases is unlimited by plan; archiving each historical case deducts one (1) credit from the Client's account.

8.8 Purchased credits remain valid indefinitely for the duration of the Agreement but are non-refundable and cannot later be exchanged back for monetary consideration. If the account is cancelled or the Agreement is fully terminated by the Client, unused credits expire without compensation. The Client is subsequently allowed to export data for a further period of 90 days.

9.1 The parties undertake to maintain confidentiality regarding all confidential information of the other party and not to disclose it to third parties without prior written consent.

9.2 The confidentiality obligation continues after termination of the Agreement.

9.3 The confidentiality obligation does not apply to information whose disclosure is required by law or a binding decision of a public authority, or to information that is generally known without action by the obligated party.

10.1 Personal data processing is carried out in accordance with Regulation (EU) 2016/679 (GDPR) and Act No. 110/2019 Coll., on personal data processing.

10.2 The privacy policy is available at www.amlproof.ai/privacy_policy.

10.3 Information about politically exposed and sanctioned persons is provided by the Platform solely for the purpose of fulfilling statutory obligations under the AML Act and Act No. 69/2006 Coll. Use for any other purpose may be sanctioned under applicable law.

11.1 These Terms of Service are effective from 1 April 2026 and are available at www.amlproof.ai/terms.

11.2 These Terms of Service, the Agreement, and all legal relationships arising from them are governed by the laws of the Czech Republic.

11.3 The court of general jurisdiction for AML Proof s.r.o., i.e. the Regional Court in Hradec Králové, has local jurisdiction to resolve disputes between the Client and AML Proof s.r.o.

11.4 AML Proof s.r.o. is entitled to amend these Terms of Service unilaterally. The Client will be informed of changes at least 30 days before the changes take effect.

11.5 If any provision of these Terms of Service is invalid or ineffective, this does not affect the validity of the remaining provisions.

11.6 The Client assumes the risk of change of circumstances; Section 1765(1) of the Civil Code does not apply.

12.1 The Platform enables sending any PDF document for electronic signature by e-mail. The electronic signature facilitated by the Platform constitutes a simple electronic signature (SES) within the meaning of Article 3(10) of Regulation (EU) No 910/2014 (eIDAS). A simple electronic signature is legally capable of evidencing the signatory's intent but does not constitute an advanced or qualified electronic signature.

12.2 The signatory receives an e-mail containing a one-time link valid for 30 days. After clicking the link, the signatory verifies their identity via a one-time passcode (OTP) sent to their e-mail address, confirms consent to the document content, and completes the signature. Each signature is recorded with the IP address, timestamp, and consent statement. Once all parties have signed, the Platform generates an audit PDF containing the complete signing history.

12.3 Sending a document for signature consumes one (1) credit pursuant to Article 8.2(h) of these Terms. The audit PDF and signature metadata are archived as part of the relevant AML case for the period specified by the Platform's data retention policy and in accordance with applicable AML regulations.

12.4 The Platform acts as a technical intermediary for collecting electronic consents; the legal effects of the signature are assessed solely by the Client in accordance with applicable law. AML Proof s.r.o. bears no responsibility for the legal validity of the signature in any specific legal context or for the content of the signed documents.

13.1 Pursuant to Section 8(9) of Act No. 253/2008 Coll. (Czech AML Act), the obliged entity is required to periodically update the AML review of clients with whom it maintains a business relationship. The Platform automatically sets the ongoing review deadline upon finalisation of a case designated as a business relationship: 12 months from the last review.

13.2 The Platform automatically monitors the ongoing review deadline for archived cases designated as a business relationship. 30 days before the deadline, the Platform sends an e-mail reminder to the Client's authorised users (owner / admin). After the deadline passes, the Platform sends repeated reminders every 14 days until the Client completes a new review or marks the business relationship as ended.

13.3 14 days after the deadline has passed, the escalation reminder is also sent to the Client's designated AML officer (MLRO). The Platform serves as a technical reminder tool; the obligation to conduct the ongoing review in a timely manner and comply with statutory duties rests solely with the Client as the obliged entity.

13.4 The Client (with the role of owner or admin) may mark a business relationship as ended in the Platform with a stated reason. Once the business relationship is marked as ended, reminder notifications for that case will cease and the ongoing review deadline will be removed.

14.1 The Platform enables ongoing monitoring of client transactions in accordance with Section 9(2)(d) of Act No. 253/2008 Coll. The feature is available for clients with an active business relationship (completed AML case, relationship not yet terminated).

14.2 Monitoring is performed by uploading a bank statement (CSV/XLSX), comparing transactions against the client's transaction profile, and automated evaluation against seven (7) detection rules (R1–R7): cash flows, unusual transaction count or volume, economically senseless transactions, payment structuring, high-risk counterparty country, and counterparty sanctions match. Evaluation outputs are supportive — the designated person assesses each finding and makes the final decision.

14.3 Credit consumption for monitoring: evaluating a monitoring session costs two (2) credits (1 credit for AI analysis + 1 credit for counterparty sanctions re-screening); closing and archiving a session costs one (1) credit. Monitoring results are archived together with the AML case for the period required by Section 16 of Act No. 253/2008 Coll.

14.4 The Platform is a technical tool for monitoring; final responsibility for assessing unusual transactions and any suspicious transaction report (STR) filing always rests with the obliged entity's designated person under Section 22a of Act No. 253/2008 Coll.

15.1 The Platform allows sharing a remote identification form with the client. The client fills in their identification data and uploads required documents via a secure link sent by e-mail. The obliged entity reviews and approves the form before use.

15.2 Responsibility for the accuracy, completeness and currency of data entered by the client rests with the obliged entity — which must verify consistency with submitted documents and actual facts before finalising the AML case. Client completion of the remote form does not replace the identification and verification obligation under Sections 7–9 of Act No. 253/2008 Coll.

15.3 Uploaded documents are stored in a secure storage (Vercel Blob, EU) accessible only to the obliged entity's designated person. Remote form drafts are retained for the period set by the Platform's operational policy; upon case finalisation they become part of the AML documentation archived under Section 16 of Act No. 253/2008 Coll.

16.1 The Platform provides a technical module for an internal reporting system in accordance with Act No. 171/2023 Coll. on the protection of whistleblowers. The system allows employees and persons in equivalent positions to submit reports of possible unlawful conduct, including anonymously.

16.2 The administrator of the reporting system (the designated person) is the obliged entity. AML Proof s.r.o. acts solely as a processor of the technical infrastructure — it does not receive reports in its own name, assess them, or participate in investigations. The obliged entity is responsible for appointing a designated person and operating the system in compliance with Act No. 171/2023 Coll.

16.3 Whistleblower identity is protected: anonymous submissions do not require contact details; each report receives a random tracking key for follow-up status checks. Report attachments are stored in a secure, access-restricted storage. Personal data processed within the reporting system is retained for the period required by Act No. 171/2023 Coll.