Terms of Service

The Lead Comply AML Portal is a purpose-built software platform designed to assist Australian real estate agencies and other Tranche 2 reporting entities in managing their obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)("AML/CTF Act") and the AML/CTF Rules 2025.

The Portal provides the following features and functions, which vary by plan:

Features may be updated from time to time. We will notify registered users of any material changes to available features.

2.1 Eligibility. To register for the Portal, you must be:

• At least 18 years of age
• Authorised to act on behalf of the Agency you are registering
• A reporting entity or employee of a reporting entity under the AML/CTF Act, or an entity preparing to become one

2.2 Accurate information. You agree to provide accurate, current, and complete information when registering and to keep your account details up to date. Providing false or misleading information is a breach of these Terms.

2.3 Account security. You are responsible for maintaining the security of your account credentials, including your password and two-factor authentication codes. You must not share your login credentials with any person who is not an authorised user of your Agency's Portal account. You must notify us immediately at info@leadcomply.com.au if you suspect unauthorised access to your account.

2.4 One account per Agency. Each Agency is entitled to one Portal account. Multiple agencies or businesses must each register separately.

2.5 Responsibility for users. As the account administrator (Tenant Admin), you are responsible for all activity conducted by users you invite to your Portal account. You must ensure all invited users comply with these Terms.

3.1 Free Tier. The free tier provides access to the features listed in Section 1 at no charge, subject to the usage limits described (up to 3 users and 5 customers). The free tier is provided on an ongoing basis at our discretion. We reserve the right to modify the features available on the free tier at any time with reasonable notice to registered users.

3.2 Paid Plans. Paid plan access is subject to a separate subscription arrangement agreed between Lead Comply and your Agency. Paid plans provide access to all Portal features listed in Section 1 without the usage limits that apply to the free tier.

3.3 Billing. Paid subscriptions are billed monthly in advance. All fees are in Australian dollars (AUD) and inclusive of GST where applicable. Payment is processed securely via Stripe. Lead Comply does not store your payment card details.

3.4 Cancellation. You may cancel your paid subscription at any time by providing 30 days written notice to info@leadcomply.com.au. Your access to paid features will continue until the end of the current billing period. No refunds are provided for partial months.

3.5 Price changes. We will provide at least 30 days notice of any change to subscription pricing. Continued use of the Portal after a price change takes effect constitutes acceptance of the new pricing.

3.6 Upgrade from free to paid. Free tier users may upgrade to a paid plan at any time by contacting Lead Comply at info@leadcomply.com.au. Upgrades take effect from the next billing cycle or immediately upon agreement.

4.1 No legal advice. Nothing in the Portal — including the training modules, checklists, report templates, risk assessments, or dashboard — constitutes legal advice. The Portal is a software tool only. Lead Comply is not a law firm and does not provide legal advice through the Portal.

4.2 Your compliance responsibility. Your Agency remains responsible for meeting its obligations under the AML/CTF Act 2006, the AML/CTF Rules 2025, and any other applicable AUSTRAC requirements. The Lead Comply AML Portal is purpose-built to support your Agency in fulfilling those obligations — providing the structured workflows, customer due diligence tools, transaction monitoring, staff training, AUSTRAC reporting, and audit trails that form the operational backbone of a sound AML/CTF compliance program. For Agencies seeking a complete compliance solution, Lead Comply also offers the development of a full written AML/CTF Compliance Manual Program — a formal, AUSTRAC-aligned document that covers Part A (risk assessment and customer due diligence framework) and Part B (employee due diligence) as required under the AML/CTF Rules 2025. When the Lead Comply AML Portal is used together with a professionally prepared Compliance Manual Program, your Agency is well-positioned to meet its Tranche 2 obligations with confidence. Contact us at info@leadcomply.com.au or visitleadcomply.com.au to enquire about our Compliance Manual Program service.

4.3 Professional advice. We strongly recommend that your Agency obtains independent legal or compliance advice when designing your AML/CTF Program, assessing your risk profile, or responding to AUSTRAC enquiries. Lead Comply offers professional consulting services separately from the Portal — contact us at info@leadcomply.com.au or visit leadcomply.com.au for more information.

4.4 Regulatory changes. The AML/CTF regulatory environment in Australia is evolving. Whilst we take reasonable care to keep the Portal's guidance and training content current, we do not warrant that all content reflects the most recent legislative or regulatory developments at all times. You are responsible for staying informed of changes to your obligations under Australian law.

By using the Portal, you agree to:

5.1 Lawful use. Use the Portal only for lawful purposes and in compliance with all applicable laws, including the AML/CTF Act 2006, the Privacy Act 1988 (Cth), and all Australian Privacy Principles.

5.2 Accurate data entry. Ensure that all information you enter into the Portal — including customer details, identification documents, transaction records, and risk assessments — is accurate and complete to the best of your knowledge.

5.3 Authorised use only. Not permit any person to access the Portal using your credentials, and not share login details with unauthorised persons.

5.4 No misuse. Not use the Portal to store data unrelated to your AML/CTF compliance obligations, attempt to circumvent security measures, introduce malware or harmful code, or reverse engineer any part of the Portal.

5.5 Customer consent. Ensure that you have obtained all necessary consents and authorisations from your customers before entering their personal information into the Portal, as required by the Privacy Act 1988 (Cth) and your own Privacy Policy.

5.6 Notification of incidents. Notify us promptly at info@leadcomply.com.au if you become aware of any security incident, data breach, or suspected unauthorised access affecting your Portal account.

5.7 Staff training. Ensure that all staff members who are granted access to the Portal are appropriately trained in AML/CTF obligations and the correct use of the Portal's features.

6.1 Your data. All compliance data, customer records, and other information you enter into the Portal remains your property. Lead Comply does not claim any ownership over data entered by your Agency.

6.2 Data processing. By using the Portal, you authorise Lead Comply to collect, store, process, and use your data solely for the purpose of providing the Portal services to you, as described in our Privacy Policy.

6.3 Data export. You may request an export of your compliance data at any time by contacting info@leadcomply.com.au. We will provide your data in a reasonable format within 30 days.

6.4 Data retention. Following termination of your account, we will retain your compliance data for the minimum period required by the AML/CTF Act 2006 (7 years from the date of the relevant transaction or customer relationship). After this period, data will be securely deleted.

6.5 Privacy Policy. Our collection, use, storage, and disclosure of personal information is governed by our Privacy Policy, which forms part of these Terms. By agreeing to these Terms, you also agree to our Privacy Policy.

7.1 Our intellectual property. All intellectual property in the Portal — including its software, design, training content, report templates, checklists, branding, and documentation — is owned by or licensed to Lead Comply. Nothing in these Terms transfers any intellectual property rights to you.

7.2 Licence to use. We grant you a limited, non-exclusive, non-transferable, revocable licence to access and use the Portal for your Agency's internal AML/CTF compliance purposes, subject to these Terms.

7.3 Restrictions. You must not copy, reproduce, modify, distribute, sell, sublicense, or create derivative works from any part of the Portal or its content without our prior written consent.

7.4 Your content. You retain all rights in the compliance data and content you enter into the Portal. You grant Lead Comply a limited licence to process that data solely for the purpose of providing the Portal services to you.

8.1 Termination by you. You may close your Portal account at any time by contacting us at info@leadcomply.com.au. For paid plans, 30 days written notice is required as set out in Section 3.4.

8.2 Suspension or termination by us. We may suspend or terminate your access to the Portal immediately and without prior notice if:

• You breach any provision of these Terms
• You provide false or misleading information during registration or use
• We reasonably believe your account has been compromised or is being used fraudulently
• You use the Portal for any unlawful purpose
• You fail to pay applicable subscription fees when due
• We are required to do so by law or regulatory authority

8.3 Termination for convenience. We may also terminate your account by providing 30 days written notice to the email address registered on your account. In this case, we will provide a pro-rata refund of any prepaid subscription fees.

8.4 Effect of termination. Upon termination, your right to access the Portal ceases immediately. We will retain your compliance data for the period required by law as set out in Section 6.4. You may request an export of your data prior to termination.

9.1 Availability. We endeavour to make the Portal available 24 hours a day, 7 days a week. However, we do not guarantee uninterrupted availability. The Portal may be unavailable from time to time due to planned maintenance, emergency maintenance, or circumstances beyond our control.

9.2 Maintenance. We will use reasonable endeavours to conduct planned maintenance during off-peak hours and to provide advance notice where practicable.

9.3 No warranty of uninterrupted service. We do not warrant that the Portal will be error-free, uninterrupted, or free of viruses or other harmful components. You are responsible for maintaining your own backup records of compliance data as required by law.

9.4 Updates. We may update, modify, or add features to the Portal at any time. We will use reasonable endeavours to notify users of material changes that affect existing functionality.

10.1 General limitation. To the maximum extent permitted by applicable Australian law, Lead Comply's total liability to you for any loss or damage arising out of or in connection with your use of the Portal — whether in contract, tort (including negligence), or otherwise — is limited to the total subscription fees paid by you to Lead Comply in the 12 months preceding the event giving rise to the claim.

10.2 Exclusion of consequential loss. To the maximum extent permitted by law, Lead Comply excludes all liability for indirect, special, incidental, or consequential loss or damage, including loss of profits, loss of data, regulatory fines or penalties, or reputational damage arising from your use of or inability to use the Portal.

10.3 Compliance responsibility. Lead Comply is not liable for any failure by your Agency to meet its AML/CTF obligations under the AML/CTF Act 2006, the AML/CTF Rules 2025, or any other law. Your Agency remains solely responsible for its own compliance, regardless of your use of the Portal.

10.4 Australian Consumer Law. Nothing in these Terms excludes, restricts, or modifies any rights or remedies you may have under the Australian Consumer Law(Schedule 2 to the Competition and Consumer Act 2010 (Cth)) that cannot be excluded by agreement. Where the Australian Consumer Law applies, our liability is limited to re-supplying the relevant service or paying the cost of having the service re-supplied, at our election.

You agree to indemnify, defend, and hold harmless Lead Comply and its officers, employees, and contractors from and against any claims, liabilities, losses, damages, fines, penalties, and costs (including reasonable legal costs) arising out of or relating to:

• Your breach of these Terms
• Your use of the Portal in a manner not authorised by these Terms
• Your Agency's failure to meet its AML/CTF obligations under applicable law
• Any inaccurate or incomplete information you enter into the Portal
• Any breach of privacy law in connection with your use of the Portal

The Portal integrates with the following third-party services to deliver its features:

• NameScan — for PEP and sanctions screening (paid plans only). Your use of the screening feature is subject to NameScan's own terms of service.
• Stripe — for payment processing on paid plans. Your payment information is handled by Stripe in accordance with Stripe's terms of service and PCI-DSS standards.
• Resend — for transactional email delivery (invite links, password resets, compliance alerts). Only your name and email address are transmitted.

Lead Comply is not responsible for the availability, accuracy, or conduct of any third-party service. We will use reasonable endeavours to notify you of any material changes to third-party integrations that may affect your use of the Portal.

13.1 Our obligation. Lead Comply will treat all compliance data, customer records, and business information you enter into the Portal as confidential. We will not disclose your confidential information to any third party except as described in our Privacy Policy or as required by law.

13.2 Your obligation. You acknowledge that information about the Portal's features, pricing, and technical design constitutes confidential information of Lead Comply. You agree not to disclose such information to competitors or use it for any purpose other than your own use of the Portal.

13.3 AML/CTF tipping off. You acknowledge that the AML/CTF Act 2006 prohibits tipping off — that is, disclosing to a customer or other person that a Suspicious Matter Report has been or may be lodged, or that AUSTRAC is investigating them. The Portal is designed to assist you in managing compliance records. You remain solely responsible for complying with the tipping-off prohibition under the AML/CTF Act.

14.1 Governing law. These Terms are governed by and construed in accordance with the laws of New South Wales, Australia. You submit to the non-exclusive jurisdiction of the courts of New South Wales for the resolution of any dispute arising under or in connection with these Terms.

14.2 Dispute resolution. If a dispute arises between you and Lead Comply in relation to the Portal or these Terms, we ask that you contact us first at info@leadcomply.com.au to attempt to resolve the dispute informally. We will use our best endeavours to respond within 5 business days.

14.3 Consumer rights. Nothing in this clause limits any rights you may have under the Australian Consumer Law or other non-excludable statutory rights.

15.1 Entire agreement. These Terms, together with our Privacy Policy, constitute the entire agreement between you and Lead Comply in relation to the Portal and supersede all prior agreements or understandings.

15.2 Amendments. We may update these Terms from time to time. We will notify registered users by email and update the effective date above. Continued use of the Portal after notice of an amendment constitutes acceptance of the updated Terms.

15.3 Severability. If any provision of these Terms is found to be invalid, unlawful, or unenforceable, it will be severed from the remaining provisions, which will continue in full force and effect.

15.4 Waiver. A failure or delay by Lead Comply in exercising any right under these Terms does not constitute a waiver of that right.

15.5 Assignment. You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign our rights and obligations to a related entity or successor without your consent, provided we give you reasonable notice.

15.6 Force majeure. Lead Comply is not liable for any delay or failure to perform its obligations under these Terms to the extent caused by circumstances beyond our reasonable control, including natural disasters, cyberattacks, government actions, or failures of third-party infrastructure.

15.7 Contact. For any questions about these Terms, please contact us at info@leadcomply.com.au. We will acknowledge your query within 2 business days.