This disclaimer governs the use of the structured compliance workflows provided within the Sentine platform.

1. Non-Advisory Role

Sentine is a technology platform designed to streamline and document your Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) processes.

Sentine does not provide legal, accounting, or compliance advice.
The platform provides structured workflows, document collection tools, and screening integrations to assist Reporting Entities in meeting their record-keeping and verification obligations under the AML/CTF Act 2006 (Cth).
Final compliance responsibility rests entirely with the Reporting Entity (the Firm) and its appointed AML Compliance Officer (AMLCO).

2. The "Safe Harbour" Provision

The AML/CTF Rules provide certain "safe harbour" provisions for verifying the identity of individual customers (e.g., verifying their name and residential address against specific, independent data sources).

Sentine provides workflows explicitly designed to align with these safe harbour requirements (such as verifying a driver's licence alongside an independent database check like the Document Verification Service).
CRITICAL: Utilising the designated "safe harbour" verification path in Sentine does not automatically confer safe harbour protection upon the Firm.
The Firm's AMLCO must ensure that all qualitative conditions for safe harbour under the prevailing AML/CTF Rules are independently met for that specific customer, including determining the appropriate risk rating.

3. Independent Reviews (Part 8.6 Audits)

Under Part 8.6 of the AML/CTF Rules, Reporting Entities are required to subject their AML/CTF program to regular independent review.

Sentine facilitates these Part 8.6 independent reviews by ensuring data exportability (via Evidence Packs) and providing secure, read-only "Auditor" access roles to your data environment.
However, Sentine is merely a tool. The independent review process itself — including the auditor's assessment of the Firm's underlying policies, risk methodologies, and adherence to the Act — remains entirely the responsibility of the Firm and its chosen independent reviewer.

4. No Guarantee of Immunity

Disclaimer: Using Sentine does not guarantee a "Pass" from an AUSTRAC assessment, nor does it provide absolute immunity from regulatory action, fines, or penalties under the AML/CTF Act. You must consistently ensure that the data you input into Sentine accurately reflects the reality of your customer relationships.

5. Governing Law

This Regulatory Disclaimer is governed by the laws of New South Wales, Australia.