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Terms and Conditions

Last updated 16 October 2026

These Terms and Conditions ("Terms") govern access to and use of eAML, a customer due diligence and AML/CTF program platform provided by Janusoft Pty Ltd ("Janusoft", "we", "us"). By creating an account, subscribing to a plan, or otherwise using eAML (the "Service"), the organisation on whose behalf you act ("you", "your organisation") agrees to these Terms. If you don't agree, don't use the Service.

1. What eAML is

eAML helps reporting entities under Australia's Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) ("AML/CTF Act") run customer due diligence, identity and business verification, sanctions and PEP screening, transaction monitoring, and the recordkeeping AUSTRAC's Tranche 2 obligations require — for real estate, legal, conveyancing, accounting and jewellery businesses.

eAML is a tool, not a substitute for your own compliance program. Your organisation remains the AUSTRAC-regulated reporting entity. You are responsible for the accuracy of the information your organisation enters or approves in the Service, for the compliance decisions that information supports, and for maintaining your own AML/CTF program in accordance with the AML/CTF Act. Nothing in the Service constitutes legal, tax or compliance advice, and using it does not by itself satisfy any AUSTRAC obligation — the checks and records it produces are inputs to your program, not a replacement for it. Section 2 sets out how this applies when casework is done for you.

2. Your compliance responsibility, and casework done for you

2.1 Your obligations stay yours. Under the AML/CTF Act, customer due diligence (including enhanced customer due diligence), ongoing customer due diligence and transaction monitoring, and reporting to AUSTRAC (including suspicious matter reports and threshold transaction reports) are obligations of your organisation as the reporting entity. Using eAML, subscribing to a Managed plan, or relying on work done by a colleague or another firm does not transfer any of those obligations to us or to anyone else. Where your organisation relies on customer due diligence carried out by another party, the AML/CTF Act's requirements for that reliance apply, and your organisation remains responsible for meeting them.

2.2 Casework done for you. On a Managed plan our AML specialists, and on any plan the colleagues, partner firms or contractors your organisation gives access to a case, may compile case files, map and cross-reference data, run and review checks, flag risks, and draft documents, including draft suspicious matter reports. This is administrative and analytical support. It is based on the information your organisation, your customers and connected sources provide (such as accounting software like Xero or MYOB, company registers like ASIC, and identity verification and screening providers). It is not legal advice, a guarantee of compliance, or a final determination of any matter.

2.3 What casework can't guarantee. Casework can only be as complete as the information available to it. We are not responsible for information that is false, incomplete or withheld, for fraud or concealment that could not reasonably have been detected from that information, or for errors in data returned by third-party sources. Any liability we do have for casework is limited as set out in section 10.

2.4 Your officers make the final decision. The Service requires every case to be risk-rated and then approved by your organisation's AML/CTF compliance officer, a senior manager, or another person your organisation has authorised to do so; no one outside your organisation can approve a case on its behalf. Whether to lodge a suspicious matter report, and when, is likewise your organisation's decision. When an authorised person in your organisation approves a case (the Approve action), your organisation adopts that case's assessment as its own and accepts responsibility for it under the AML/CTF Act. If they aren't satisfied with a case, they shouldn't approve it: they should ask for more information, record the concern, or escalate it.

3. Accounts and eligibility

You must be an authorised representative of a real business to register an organisation. You're responsible for the accuracy of your account and organisation details, for keeping login credentials confidential, and for all activity under your account. Tell us promptly if you believe an account has been compromised.

4. Subscriptions, fees and billing

Depending on your plan, charges may include:

  • a one-time setup fee to activate your organisation;
  • on a platform plan (5 Case, 10 Case or Unlimited), a recurring monthly subscription fee, plus metered charges for verification checks that call an external vendor (identity, business, sanctions and PEP screening), drawn from a prepaid wallet in real time or accrued to a standing monthly invoice — whichever you've set up; and
  • on Managed Individual or Managed Trust/Co, a per-case rate that already includes check costs.

All fees are in Australian dollars and, unless stated otherwise, exclude GST, which is added where it applies. Payments are processed by Stripe, Inc.; we never see or store your full card details. Fees are non-refundable except where required by the Australian Consumer Law or stated otherwise at the time of purchase. We may change our fees on reasonable notice; continuing to use the Service after a fee change takes effect means you accept it.

An overdue invoice may result in new AML cases being blocked until it's paid — see your Billing page for what's currently owing.

5. Data you submit

In the course of using the Service, your organisation submits personal information about third parties — your own clients, vendors, buyers and their beneficial owners — for identity verification, screening and CDD purposes. You warrant that you have the right to collect and disclose that information to us for this purpose (including, where relevant, having given those individuals the notices Australian Privacy Principle 5 requires), and that you will not submit information you are not lawfully entitled to provide. You appoint us to process that information solely to provide the Service to you, as described in our Privacy Policy.

6. Acceptable use

You agree not to:

  • use the Service for any organisation you are not authorised to act for;
  • submit information you know to be false, or that infringes another person's rights;
  • attempt to circumvent, probe or disrupt the Service's security or infrastructure;
  • resell or provide the Service to a third party as your own product; or
  • use the Service in a way that breaches the AML/CTF Act, the Privacy Act 1988 (Cth), or any other applicable law.

7. Third-party services

Certain features rely on third-party providers acting on your instructions. Currently these are:

  • Didit: identity verification, and company register checks (company details, officers, shareholders and ultimate beneficial owners);
  • Dilisense: sanctions, PEP and adverse media screening, with NameScan as a backup provider;
  • ABN Lookup (the Australian Business Register): Australian Business Number checks;
  • Xero and MYOB: where your organisation connects its accounting software, to bring in its clients and transactions;
  • Anthropic (Claude): drafting investigation summaries for your officers to edit, only where your organisation turns AI summaries on;
  • Google: "Sign in with Google", where you choose to use it;
  • Resend: sending the Service's emails; and
  • Stripe: payments.

We may change these providers from time to time and will keep this list current. Those providers' own terms and privacy practices apply to the services they provide; we select and configure them but don't control their underlying data or decisions. Some checks (for example the high-risk country lists and the DFAT Consolidated List) are run within the Service itself from published government sources.

8. Availability and changes

We aim to keep the Service available and accurate but don't guarantee it will be uninterrupted, error-free, or available at all times — including where third-party providers we rely on (identity verification, sanctions screening, payments) are themselves unavailable. We may change, suspend or discontinue features on reasonable notice where reasonably practicable.

9. Intellectual property

eAML, its software, and its content (excluding the data your organisation submits) are owned by Janusoft or its licensors. You're granted a non-exclusive, non-transferable right to use the Service for your organisation's own AML/CTF program for as long as your subscription is active. You retain ownership of the data your organisation submits.

10. Liability

To the maximum extent permitted by law, and subject to any consumer guarantees under the Australian Consumer Law that cannot be excluded, our total liability arising from or in connection with the Service, including casework done for you under section 2, is limited to the fees your organisation paid us in the 12 months before the event giving rise to the claim. We are not liable for indirect or consequential loss, for the accuracy of results returned by third-party verification or screening providers, or for any penalty, sanction or loss arising from your organisation's own compliance decisions, including its approval of a case. Nothing in these Terms excludes or limits liability that cannot lawfully be excluded or limited.

11. Termination

You may stop using the Service and cancel your subscription at any time from Billing. We may suspend or terminate an account for a material breach of these Terms, non-payment of an overdue invoice, or where required by law. We will retain records for the periods AUSTRAC's recordkeeping obligations require, as described in our Privacy Policy, even after an account is closed.

12. Changes to these Terms

We may update these Terms from time to time. We'll post the updated version here with a new "last updated" date; continuing to use the Service after that means you accept the change. For a material change, we'll make reasonable efforts to notify account holders directly.

13. Governing law

These Terms are governed by the laws of the Commonwealth of Australia and the state or territory in which Janusoft Pty Ltd is registered, and each party submits to the non-exclusive jurisdiction of the courts of that state or territory.

14. Contact

Questions about these Terms can be sent to your organisation's compliance administrator or to Janusoft Pty Ltd directly at [email protected].