Terms of Service

1. Acceptance of Terms & Key Parties

By registering for, accessing, or utilizing the EWRA Platform (including associated web portals, document processors, scoring engines, and reporting APIs), you confirm that you have read, understood, and agreed to be legally bound by these Terms and our Privacy Policy.

If you are entering into these Terms on behalf of a company, financial institution, partnership, or other corporate entity, you represent and warrant that you hold the requisite corporate and regulatory authority to legally bind such entity. If you lack such authority, you must cease all access to the platform immediately.

2. Scope of Platform Services

EWRA provides an integrated financial crime risk management suite comprising:

• Enterprise-Wide Risk Assessment (EWRA): A quantitative and qualitative assessment engine covering 11 critical risk domains aligned to the Financial Action Task Force (FATF) Recommendations and Central Bank of the UAE (CBUAE) supervisory guidelines.
• Customer Onboarding & CRA: Automated Know-Your-Customer (KYC) onboarding wizards, Customer Risk Assessment (CRA) matrix scoring, and document validation.
• AML/CFT/CPF Policy Generation: Customizable, rule-based anti-money laundering policy documentation frameworks adhering to UAE statutory standards.
• Compliance Case Management: Multi-tiered review workflows (including 4-eyes checks, Senior Management Overrides, and MLRO sign-offs).

3. Compliance Disclaimers & Institutional Responsibility

The Subscriber expressly acknowledges and agrees that:

Finrom does not act as an MLRO, compliance officer, or legal advisor to your organization. Calculations, risk tiers (Low, Medium, Significant, High, Severe), and policy outputs generated by the platform must be reviewed, corroborated, and ratified by your institution's qualified compliance personnel before being submitted to regulatory bodies or relied upon for customer onboarding.

4. Account Registration & Tenant Security

Access to the platform is authenticated through secure single sign-on (SSO) and Google Identity credentials managed via Firebase Authentication. You are responsible for ensuring that:

• All user details provided are accurate, verified, and restricted to institutional personnel.
• Access credentials are kept confidential and not shared among multiple employees.
• Multi-factor authentication (MFA) is enabled across all administrative accounts with sign-off or data export privileges.
• Finrom is notified immediately at security@finrom.ae upon discovering any unauthorized access, credential leakage, or security anomalies.

5. Data Ownership, Confidentiality & Privacy

Subscriber Retains 100% Ownership: All customer records, uploaded identification files (e.g. passports, Emirates IDs, trade licenses), assessment responses, reviewer notations, and audit logs remain the exclusive intellectual and proprietary property of the Subscriber.

Finrom does not sell, license, lease, or monetize Subscriber data. Data is processed solely to provide the services contracted under these Terms and in strict compliance with the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021). For complete technical and legal details on data encryption, local storage architecture, and retention periods, please refer to our Privacy Policy.

6. Intellectual Property Rights

Finrom and its licensors retain all right, title, and interest in and to the EWRA Platform, including its underlying software, algorithms, scoring formulas, report templates, user interface designs, brand trademarks, and documentation.

Subject to ongoing compliance with these Terms, Finrom grants the Subscriber a non-exclusive, non-transferable, revocable license during the active subscription term to access the platform and export board reports, PDF assessments, and customer repository archives for internal regulatory and corporate governance purposes.

7. Acceptable Use Policy

You agree that you will not, directly or indirectly:

• Reverse engineer, decompile, disassemble, or derive the source code of the platform.
• Probe, scan, or test the vulnerability of the system without prior written consent.
• Deploy automated scrapers, spiders, or crawlers against authenticated endpoints.
• Upload malicious files, viruses, or corrupted archives into the document processor.
• Use the platform to assess unlawful transactions or evade sanctions obligations.
• Sublicense, resell, or provide bureau services to third parties unless agreed under an enterprise tier.

8. Third-Party Integrations & Optical Character Recognition (OCR)

The platform leverages automated Optical Character Recognition (OCR) powered by Google Gemini Vision APIs to parse structured data from uploaded identity credentials. Document scans processed for OCR are transmitted over encrypted TLS channels and processed ephemerally. Uploaded files are not retained by third-party AI models for public model training.

Watchlist, sanctions, Politically Exposed Persons (PEP), and adverse media screening services are subject to activation of external data provider connectors. Automated results represent probabilistic matches that must be verified by the compliance analyst.

9. Limitation of Liability & Warranties

To the maximum extent permitted by applicable UAE law, the EWRA Platform is provided on an "AS IS" and "AS AVAILABLE" basis. Finrom disclaims all warranties, express or implied, including merchantability, fitness for a particular regulatory purpose, and non-infringement.

In no event shall Finrom, its officers, directors, or affiliates be liable for indirect, incidental, punitive, or consequential damages, including loss of profits, reputational harm, or regulatory fines imposed by supervisory authorities (including the CBUAE, Ministry of Economy, or international bodies) arising from your institutional decisions or risk ratings. Finrom's aggregate liability under these Terms shall not exceed the total fees paid by the Subscriber in the twelve (12) months preceding the claim.

10. Term & Termination

These Terms remain in effect until terminated by either party. The Subscriber may terminate its subscription at any time via account settings or written notice. Finrom may suspend or terminate access immediately upon material breach of these Terms.

Upon termination, the Subscriber shall be provided a thirty (30) day retrieval window to export all customer records, assessment histories, and generated PDF reports before account deletion pursuant to our data retention protocols.

11. Governing Law & Dispute Resolution

These Terms and any non-contractual disputes arising out of or in connection with them shall be governed by and construed in accordance with the federal laws of the United Arab Emirates and the laws of the Emirate of Dubai.

The parties agree that any legal suit, action, or proceeding arising out of or related to these Terms shall be instituted exclusively in the competent civil courts of Dubai, United Arab Emirates.

12. Contact Information & Legal Notices

All official notices, queries regarding these Terms, or requests for enterprise compliance agreements should be directed to: