This Acceptable Use Policy ("Policy") outlines the acceptable and prohibited use of the Sentine platform. All Authorised Users representing a Subscriber (Firm) must comply with this policy. By accessing Sentine, you agree to adhere to these rules.

1. Fundamental Prohibited Conduct

Sentine is a vital tool for assisting with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. Its integrity is paramount. You must NOT use Sentine to:

Facilitate, conceal, or aid in money laundering, terrorist financing, fraud, or any other criminal or illicit activity.
Store, upload, or transmit any illegal, offensive, or grossly inappropriate content entirely unrelated to the legitimate compliance needs of the Firm.
Knowingly input false, deceptive, or misleading information into verification workflows or screening tools.

2. Integrity of Evidence and Data

The veracity of the audit trail generated by Sentine is essential for regulatory compliance. Users must NOT:

Attempt to deliberately falsify, tamper with, or manipulate verification records, identity documents, risk ratings, or screening results.
Attempt to alter or delete system-generated immutable audit logs or Evidence Packs.

3. Account Sharing and Access

Security and attribution of actions are critical in AML systems.

Individual Credentials: Sentine mandates a strict "one account per individual user" policy. Under no circumstances may login credentials be shared amongst personnel, contractors, or external parties.
Role Limits: Users must not attempt to exploit vulnerabilities to exceed their authorised Role-Based Access Control (RBAC) permissions.

4. Tipping-Off and Circumvention

Section 123 of the AML/CTF Act 2006 (Cth) ("Tipping Off") imposes severe criminal penalties for disclosing the existence of a Suspicious Matter Report (SMR) or related regulatory investigations. Users must NOT:

Attempt to circumvent platform controls designed to restrict access to SMR data.
Export, copy, or screenshot restricted SMR data to share with unauthorised parties, inside or outside the Firm.
Use the platform's communication features (if any) to disclose SMR-related information to the subject of the suspicion.

5. Security Violations

Users must NOT:

Probe, scan, or test the vulnerability of the Sentine system or network without express written permission (e.g., sanctioned penetration testing).
Attempt to introduce viruses, trojans, worms, logic bombs, or other malicious material to the platform.
Engage in denial-of-service (DoS) attacks against the platform.

Note: Security researchers participating in Sentine's Vulnerability Disclosure Program (VDP), as described on our Security & Trust page, are exempt from this restriction when conducting responsible disclosure in accordance with VDP guidelines.

6. Consequences of Violation

Violation of this Acceptable Use Policy is considered a material breach of the Master Subscription Agreement. Sentine reserves the right to:

Immediately suspend or terminate the relevant user account.
Immediately suspend or terminate the Firm's subscription.
Report any suspected criminal activity, deliberate falsification of compliance records, or terrorism financing facilitation to the relevant law enforcement or regulatory authorities (including AUSTRAC, AFP, or state police) as legally required or permitted.

7. Governing Law

This Acceptable Use Policy is governed by the laws of New South Wales, Australia.

Acceptable Use Policy (AUP)