As a provider of Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) compliance infrastructure, Sentine may periodically receive requests for data from law enforcement agencies, regulatory bodies (such as AUSTRAC), or via civil subpoenas.

This policy outlines how Sentine handles such requests, with particular attention to our obligations and our Subscribers' obligations under Section 123 of the AML/CTF Act 2006 (Cth) ("Tipping Off").

1. Our Role as a Data Processor

Sentine operates as a Data Processor. The Subscriber (the Firm) is the Data Controller and the primary owner of the matter data, verification records, and compliance logs held within the platform.

Our baseline policy is that law enforcement and regulatory agencies should seek data directly from the Firm concerned. Sentine will not voluntarily disclose a Firm's data to third parties without a valid and binding legal demand, except as strictly required to prevent imminent death or serious physical harm.

2. Handling Legal Demands

If Sentine receives a valid subpoena, warrant, court order, or formal statutory notice (e.g., an AUSTRAC Section 167 notice) demanding access to a Firm's data:

2.1 Standard Procedure (Notice to Subscriber)

Unless prohibited by law, our standard procedure is to:

Promptly notify the Firm's designated Administrator or AML Compliance Officer (AMLCO) of the request.
Provide the Firm with a copy of the legal demand.
Allow the Firm a reasonable opportunity (e.g., 7-14 days, depending on the demand's deadline) to seek a protective order, quash the subpoena, or otherwise formally object to the disclosure in court.
If the Firm successfully quashes the demand, Sentine will not turn over the data. If the Firm cannot quash the demand by the deadline, Sentine will comply and provide the requested data.

2.2 Gag Orders and Non-Disclosure Requirements

Frequently, law enforcement requests in the AML/CTF context are accompanied by non-disclosure orders (gag orders) prohibiting Sentine from notifying the Firm that their data has been requested.

Compliance: Sentine will strictly comply with valid gag orders issued by a competent court or statutory authority. We will not notify the Firm in these circumstances.
Scrutiny: Our legal counsel reviews all gag orders to ensure they are legally valid and properly scoped.

3. The "Tipping Off" Offence (s123 AML/CTF Act)

Section 123 of the AML/CTF Act creates a strict liability criminal offence for "tipping off". A person must not disclose to any person (including the customer) that a suspicion has been formed, that a Suspicious Matter Report (SMR) has been submitted to AUSTRAC, or that a Section 167 statutory notice has been received.

If Sentine receives a direct regulatory request for data that touches upon SMRs or suspicious activity:

Sentine acknowledges the extreme sensitivity of this data.
Our internal legal team will review the request to ensure compliance with s123 restrictions.
In scenarios involving gag orders or specific AUSTRAC notices, Sentine will work directly with the requesting authority to provide the data without tipping off the Firm (and thereby avoiding placing the Firm at risk of inadvertently tipping off the subject).

4. Format of Disclosed Data

When legally compelled to disclose data, Sentine will provide the data in standard, reasonably usable formats (e.g., PDF Evidence Packs, CSV audit logs, or JSON data exports). Sentine is not obligated to build custom reports or undertake forensic data analysis on behalf of the requesting agency unless specifically ordered by a court and compensated accordingly.

5. Contact for Law Enforcement

Law enforcement agencies and regulatory bodies seeking to serve legal process should direct inquiries and formal notices to our legal department:

Email: legal@sentine.com.au
(Note: Service of legal process is only accepted via email if explicitly acknowledged by our legal counsel.)

Mail:
Sentine Compliance Pty Ltd
Attn: Legal Department
Sydney, New South Wales, Australia

(Formal service of legal process may be effected by registered mail to the above address or by email where explicitly acknowledged by our legal counsel.)

6. Governing Law

This Law Enforcement & Regulatory Request Policy is governed by the laws of New South Wales, Australia.