Last updated: 15 April 2026
These Terms of Service (“Terms”) govern the provision of services by AML Watchtower (“we”, “our”, “us”) to our clients (“Client”, “you”). By engaging our services, you agree to these Terms.
1. Scope of Services
AML Watchtower provides Anti-Money Laundering (AML) outsourcing services, including but not limited to:
- Know Your Customer (KYC), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD)
- Customer risk assessment and onboarding support
- Beneficial ownership (UBO) verification
- Sanctions and PEP screening
- Transaction monitoring and alert handling
- Investigation support and case management
- Suspicious Activity / Transaction Report (SAR/STR) drafting
- Ongoing Due Diligence (ODD / EODD) and periodic reviews
The exact scope of services shall be defined in a separate agreement, statement of work (SoW), or engagement letter.
2. Nature of Services
2.1 Operational Support Only
AML Watchtower provides operational AML support and does not act as:
- the Client’s MLRO (unless explicitly agreed in writing),
- a regulated entity,
- or a decision-making authority.
2.2 Final Responsibility
The Client retains full responsibility for:
- regulatory compliance,
- risk decisions,
- SAR/STR submission,
- and interactions with competent authorities.
3. Client Obligations
The Client agrees to:
- Provide accurate, complete, and timely information
- Maintain appropriate AML policies and governance
- Ensure lawful basis for sharing personal data with us
- Review and approve outputs where required
Failure to meet these obligations may impact service delivery.
4. Data Protection and Confidentiality
4.1 Data Processing
Where AML Watchtower processes personal data on behalf of the Client, we act as a data processor.
4.2 Data Processing Agreement (DPA)
A separate DPA may be executed where required under GDPR.
4.3 Confidentiality
We treat all Client data as confidential and implement appropriate security measures.
5. Service Delivery Model
- Services may be delivered remotely or embedded into Client operations
- We may use internal tools and approved third-party systems
- We reserve the right to assign qualified personnel to deliver services
6. Fees and Payment
- Fees are defined in the applicable agreement or proposal
- Unless otherwise agreed in writing, invoices are payable within 7 days from the invoice date
- AML Watchtower reserves the right to suspend services in case of overdue payments
7. Liability
7.1 Limitation of Liability
To the maximum extent permitted by law:
- AML Watchtower shall not be liable for indirect or consequential damages
- Our total liability shall not exceed the fees paid in the preceding 3 months, except in cases of fraud, wilful misconduct, or where liability cannot be limited under applicable law
7.2 Regulatory Outcomes
We are not responsible for:
- regulatory decisions,
- fines,
- or enforcement actions taken against the Client.
8. Intellectual Property
All methodologies, templates, and internal frameworks remain the property of AML Watchtower.
Deliverables provided to the Client may be used internally but not redistributed without permission.
9. Term and Termination
- Services continue as agreed in the contract or SoW
- Either party may terminate with 30 days written notice
- Immediate termination may occur in case of:
- breach of Terms
- non-payment
- unlawful activity
Upon termination, access to services will cease.
10. Force Majeure
We are not liable for failure or delay caused by events beyond our reasonable control, including:
- system failures,
- cyber incidents,
- regulatory changes,
- natural disasters.
11. Governing Law
These Terms shall be governed by the laws of Lithuania.
Any disputes shall be subject to the jurisdiction of Lithuanian courts.
12. Changes to Terms
We may update these Terms from time to time. The latest version will be published on our website.
13. Contact
AML Watchtower, MB
J. Lebedžio str. 1, Vilnius, Lithuania
Email: contact@amlwatchtower.eu