Service terms

1.1 These Terms apply to the Independent Regulation 21 AML Audit and any agreed Follow-up Review.

1.2 Customer means the law firm or other business named in the applicable Engagement Schedule. Authorised Contact means the individual nominated by the Customer to give instructions and receive communications. Engagement means the contract formed under these Terms. Evidence means the information and documents agreed for review. Follow-up Fee means the fee agreed for a Follow-up Review, excluding VAT. Follow-up Item means a specific item identified in a Report as eligible for a Follow-up Review. Follow-up Review means the separate, customer-initiated, point-in-time re-consideration described in clause 3.9. Purchase Price means the fee actually paid for the relevant Engagement, excluding VAT. Relevant Persons means the Provider's officers, directors, employees, contractors and any other persons connected with the Provider who are involved in, or whose relationship or circumstances may be relevant to, the independence review. Report means the written output described in the applicable Engagement Schedule.

2.1 An Engagement is formed only through the approved purchase or bespoke engagement process. The Engagement Confirmation records engagement and administrative particulars; it does not create a separate later contract date.

2.2 The person placing an order confirms that they are authorised to bind the Customer. The standard service is intended for customers purchasing wholly in the course of business.

3.1 The Provider will perform the service described in the applicable Engagement Schedule with reasonable skill and care, subject to the agreed assumptions, limitations and exclusions.

3.2 The standard service is a focused, firm-level, point-in-time review of agreed Evidence. Technology may assist analysis, but it does not independently issue an audit opinion: human professional review, challenge, materiality assessment and sign-off remain central.

3.4 The Engagement is not legal advice, a legal compliance opinion, certification, a guarantee of compliance, regulator approval, a prediction of regulatory action, inspection or enforcement, a benchmark, or an ongoing monitoring service.

3.4A References to 'independent' describe that the review is conducted by an external party independent of the Customer. This product, including the optional Follow-up Review described below, is not, and does not by itself constitute or satisfy, the internal independent audit function that regulation 21(1)(c) of the Money Laundering Regulations 2017 requires certain firms to establish, which is an ongoing function that monitors compliance with its own recommendations as a matter of course. The Follow-up Review is a separate, customer-initiated, point-in-time re-consideration of specifically identified items, not continuous monitoring. The Customer remains responsible for determining whether, and how, this Report and any Follow-up Review are relevant to its own regulation 21 obligations.

3.6 Before accepting or commencing the standard audit, the Provider will carry out and document a proportionate independence review, taking account of actual or potential conflicts and other relevant relationships or circumstances involving the Provider and Relevant Persons.

3.7 If the Provider determines before commencement that it cannot act independently, or identifies a potential independence issue that it does not consider can be appropriately managed, it will not proceed and will refund the Purchase Price and VAT paid in full. The refund will be processed within 14 days to the original payment method.

3.7A If the Provider identifies a potential independence issue that it considers manageable, it will provide the Customer with reasonable details of the issue and the proposed safeguards. The Provider may proceed only with the Customer's written agreement to those safeguards.

3.8A If, after commencement, the Provider determines that an independence issue cannot be appropriately managed, it may terminate the Engagement. Clause 6.5 applies.

3.9 A Follow-up Review is optional, customer-initiated and available only after a Report identifies specific Follow-up Items. The Customer may accept or decline the opportunity within 21 days after Report delivery (the Response Window). It is a separate Engagement and is formed and paid for in the same way as the applicable purchase process.

3.9A The Follow-up Fee is from £499 plus VAT. The Provider will confirm the final Follow-up Fee after receiving the remediated material and before the Follow-up Review begins.

3.10 A Follow-up Review is limited to the Follow-up Items submitted by the Customer and is not a re-audit, live-file review or ongoing monitoring service. The Customer must submit the agreed remediated material within 30 days after accepting the opportunity (the Submission Window).

3.11 A Follow-up Review must be purchased and completed within six months after Report delivery. The Provider will confirm independence where there has been a material change in relevant circumstances. A fresh, proportionate review is required if more than 12 months have elapsed since the Report.

3.13 If the Customer declines the Follow-up Review or does not respond within the Response Window, the Provider may record that outcome for administrative purposes. No Follow-up Review will be undertaken unless the Customer later makes a qualifying request within the six-month period and the Provider agrees a separate Engagement.

4.1 The Customer must provide accurate administrative information and the agreed Evidence in a timely, complete and lawful manner.

4.2 For version one, MadeThis is used only for commercial and administrative metadata. It does not receive or store substantive Evidence, audit working papers, detailed analysis or final Reports.

4.3 Unless another method is agreed in writing, the Customer must send one encrypted archive to the notified evidence email address and communicate its password separately through an agreed channel. The Customer must not provide live client identity documents, unnecessary personal information, privileged material or other client-confidential information unless specifically requested, and must anonymise documents where reasonably possible.

5.1 The standard fee is £999 plus VAT for firms with up to 10 partners. Larger firms and non-standard scope require separate agreement.

5.2 Any 48-hour cancellation or service-commencement position applies only where the approved purchase flow has captured and retained the required versioned acceptance and order record. If that record is unavailable, the Provider will use the manual or bespoke engagement route instead.

6.5 If the Provider commits an uncured material breach, or terminates under clause 3.8A because a post-commencement independence issue cannot be appropriately managed, the Provider will refund the Purchase Price and VAT paid in full. The refund will be processed within 14 days to the original payment method.

12.3 A notice must be in writing and sent by email to the address stated in the Engagement Schedule or an address notified in writing. An email is deemed received at the time it enters the recipient's information system, provided that no delivery-failure notice is received; if sent outside normal business hours in the recipient's location, it is deemed received at 9.00am on the next business day.