Terms and conditions of use

1. Who we are

The AMLTracer platform, formerly AMLScreen (the “Platform”), available at amltracer.com, is provided by SYSTHEMA ANALYTICS S.R.L., registered office at Mun. Deva, Str. Dragoș Vodă nr. 2, bl. D5, et. 1, ap. 3, jud. Hunedoara, cod 330034, Romania, tax identification number (CUI) 45945560, Trade Register no. J20/524/2022, e-mail [email protected] (“Systhema” or “we”).

2. What the Platform is

AMLTracer is a software service that supports the anti-money laundering and counter-terrorist financing obligations set out in Romanian Law no. 129/2019: transaction monitoring, risk assessment, case management, screening against politically exposed persons and international sanctions lists, preparation of reports to ONPCSB (the National Office for Prevention and Control of Money Laundering, Romania’s financial intelligence unit) and keeping an audit trail.

The Platform is intended exclusively for organisations (reporting entities) that have signed a contract with Systhema. We do not offer accounts to individuals acting on their own behalf.

3. Relationship with the contract

The relationship between Systhema and each organisation is governed by the contract signed by the parties and its annexes, including the data processing agreement and the service level. If there is any inconsistency, the signed contract prevails over these terms.

4. Accounts and access

• Accounts are created by Systhema or by the organisation’s designated administrator, only for persons authorised by the organisation.
• Each account is personal. Credentials must not be lent or shared.
• Two-factor authentication is mandatory for all accounts.
• The organisation may set the days and hours during which its users have access.
• Users must immediately notify the organisation’s administrator and Systhema at [email protected] if they suspect an account has been compromised or if they have lost the device used for two-factor authentication.

5. Permitted use

The Platform may be used only to fulfil the organisation’s compliance obligations. In particular, it is prohibited to:

• access or attempt to access data of other organisations or functions for which the account has no rights;
• circumvent or test the security measures without Systhema’s written consent;
• extract data automatically, deliberately overload the service or introduce malicious code;
• use information obtained through the Platform for purposes other than the organisation’s compliance work;
• disclose to the person concerned or to third parties that an analysis is being carried out or that a report has been or will be sent to ONPCSB, except where permitted by law.

6. Nature of the results

Scores, alerts, cases and screening results are support tools, not legal conclusions. The decision to report, to close a case or to apply due diligence measures belongs to the organisation and the persons it designates. Results depend on the accuracy and completeness of the data in the organisation’s systems and on the public sources used for screening, which may contain errors, omissions or homonyms.

7. Availability

Availability and support are as set out in the contract. There may be interruptions for maintenance, which we try to schedule outside working hours and announce in advance.

8. Personal data

For the data of customers and other persons in the organisation’s records, the organisation is the controller and Systhema acts as processor, under the signed data processing agreement. How we process the data of visitors and users is described in the Privacy policy, and cookies in the Cookie policy.

9. Intellectual property

The Platform, its code, documentation, risk rules and graphic elements belong to Systhema. The contract grants the organisation a non-exclusive right of use for the term of the contract. The organisation’s data remain the organisation’s.

10. Liability

The parties’ liability is as set out in the contract. Systhema is not liable for decisions taken by the organisation on the basis of the Platform’s results, for incorrect or incomplete data from the organisation’s systems, or for the unavailability of those systems or of the connection to them.

11. Suspension of access

We may temporarily suspend an account or an organisation’s access if there are signs of compromise, of use contrary to these terms or of a risk to the Platform’s security. We inform the organisation of the suspension and its reasons, to the extent permitted by law.

12. Changes

We may update these terms. Each version has a number and a date. A new version is presented to users at their next sign-in and applies from acceptance.

13. Governing law

These terms are governed by Romanian law. Disputes are settled amicably or, failing agreement, by the competent courts at Systhema’s registered office.

14. Contact

For any question: [email protected].