Terms of Service
Version 1.5 · Effective 2026-09-14 · Applies to all organizations using the Straits Compliance customer due diligence platform.
Version 1.5 withdraws part of what version 1.4 stated. Storage is unchanged and confirmed: your content is stored in the Singapore region (ap-southeast-1) and our application runs there. But we no longer state that ALL PROCESSING happens in Singapore, because it does not — extracting data from an uploaded identity document involves sending that document's content to a third-party AI service outside Singapore. We are confirming which provider, its retention and model-training terms, and where it processes, and we will state the position fully once we have. We are withdrawing the claim now rather than waiting, because leaving an incorrect guarantee published while we work out the correct wording would be the worse of the two.
1. Acceptance of these terms
By creating an organization, accepting an invitation, or otherwise accessing the platform, you agree to these Terms of Service on behalf of your organization and confirm you are authorised to bind it. Acceptance is recorded against your organization together with the accepting user and timestamp.
2. The service
The platform ingests corporate and identity documents, extracts structured data, performs sanctions, PEP and adverse-media screening against configured providers, and produces risk assessments and Annex C audit records for your review.
Outputs are decision-support artefacts. They are generated from the documents and data-provider responses available at the time of processing and may be incomplete or inaccurate.
3. Accounts, tenancy and role segregation
Each organization is an isolated tenant. Cases, documents and audit stamps never cross tenant boundaries. You are responsible for the accuracy of member roles, for maintaining Maker/Checker segregation, and for the security of your credentials.
4. Acceptable use
You must not upload data you are not lawfully entitled to process, attempt to circumvent tenancy or role controls, reverse engineer the service, or use outputs to take an adverse decision about an individual without human review.
5. Fees
Fees, screening volumes and provider entitlements are set out in your order form. Unpaid accounts may be suspended; suspension does not relieve you of record-keeping obligations.
6. Intellectual property
We retain all rights in the platform, its models, rulesets and templates. You retain all rights in the documents and customer data you upload.
7. Customer data and data protection
Processing of personal data is governed by the Data Processing Agreement, which forms part of these terms, including the PDPA data intermediary designation, AWS Singapore (ap-southeast-1) residency and the 5-year ACRA CSP record-retention lifecycle under §6.55.
8. Term and termination
Either party may terminate for material breach that remains uncured for 30 days. On termination you may export your case records; we retain records only as required by the retention lifecycle described in the DPA.
9. Warranties
We warrant that the service will be provided with reasonable skill and care. Except as expressly stated, the service is provided "as is" and we disclaim all implied warranties, including fitness for a particular regulatory purpose.
10. Regulatory disclaimer and accountability
10.1 Non-delegable accountability under the CSP Act 2024
Straits Compliance is a technology provider, not a regulated financial institution, law firm or compliance consultancy. Nothing in the service constitutes legal, regulatory or professional advice. Your obligations under the Corporate Service Providers Act 2024, the ACRA Guidelines for Registered Corporate Service Providers and the CDSA — including customer due diligence, enhanced due diligence, ongoing monitoring, screening, escalation and suspicious transaction reporting — remain at all times your own and are non-delegable. Engaging the platform does not transfer, share or diminish that accountability.
10.2 Human-in-the-loop requirement
Automated extraction, matching and risk scoring are advisory only. Every case must be reviewed and approved by a qualified human officer before any onboarding, rejection, escalation or filing decision is taken. Maker/Checker segregation is mandatory: the officer who prepares a case may not sign off as Checker. You agree not to rely on any output as the sole basis for a regulatory decision, and not to operate the platform in a fully automated manner.
10.3 Limitation of liability
To the maximum extent permitted by law, we are not liable for any regulatory penalty, censure, enforcement action, remediation cost, loss of profit, loss of business, loss of goodwill or indirect or consequential loss arising from your use of the service or from reliance on its outputs. Our aggregate liability under these terms is capped at the fees paid by you in the twelve months preceding the event giving rise to the claim. Nothing limits liability that cannot lawfully be limited.
11. Governing law
These terms are governed by the laws of Singapore and subject to the exclusive jurisdiction of the Singapore courts.
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