Disclaimer

RiskBright is an AML support platform built for UK estate agencies. It is designed to help estate agents approach AML considerations in a clearer, more structured and consistent way.

RiskBright supports professional judgement. It does not replace it.

1. Not Legal or Professional Advice

Information, questions, considerations, tools, calculations, guidance summaries, documents and other materials provided through RiskBright are provided for AML support and informational purposes.

They do not constitute legal advice and should not be treated as a substitute for advice from an appropriately qualified professional where such advice is required.

RiskBright does not act as your solicitor, MLRO, compliance officer, regulator or professional adviser.

2. Your AML Responsibilities

RiskBright does not conduct your organisation's AML assessment or make AML decisions on your behalf.

In particular, RiskBright does not:

1. determine whether customer due diligence has been satisfactorily completed;
2. determine whether enhanced due diligence is required or has been satisfactorily completed;
3. determine a customer's, transaction's or matter's final risk classification;
4. make PEP or sanctions clearance decisions;
5. verify the legitimacy of source of funds or source of wealth;
6. determine whether a transaction or business relationship should proceed;
7. decide whether a matter should be escalated or reported; or
8. guarantee compliance with applicable AML legislation, regulations or guidance.

The questions, considerations, information and resources provided by RiskBright are intended to support your organisation's own assessment.

Your agency remains responsible for its own AML assessment, professional judgement, actions, escalation, reporting decisions and record keeping.

3. Customer Journey

The RiskBright Customer Journey provides a structured framework for considering and recording information that may be relevant to an AML assessment.

The questions and considerations presented are points to consider, not an assessment.

Completion of a Journey does not mean that:

1. all relevant AML risks have been identified;
2. customer due diligence is complete;
3. enhanced due diligence is or is not required;
4. a customer or transaction has been approved by RiskBright; or
5. your organisation has satisfied all applicable legal or regulatory requirements.

The generated Journey document records information from the Journey and provides space for your own assessment.

Your organisation is responsible for reviewing the document, completing its own assessment and retaining the document within its own records where required.

4. Identity Verification

RiskBright is not an identity verification provider.

RiskBright is designed to support the wider AML process alongside your existing identity verification provider.

You remain responsible for determining what identity verification, customer due diligence and supporting evidence are required in the circumstances.

5. Source of Funds

RiskBright's Source of Funds functionality can help users record and compare information concerning declared funding sources and supporting evidence.

It does not verify:

1. whether funds exist;
2. whether documents or evidence are authentic;
3. whether funds are legitimate;
4. source of wealth; or
5. whether AML requirements have been satisfied.

Any calculation or output depends on the information entered by the user and should be considered as part of the agency's wider assessment.

6. Beneficial Ownership

RiskBright's Beneficial Ownership functionality may assist with calculations involving direct share ownership and ownership thresholds.

It should not be treated as a definitive determination of beneficial ownership or persons with significant control.

Depending on the circumstances, other factors may need to be considered, including indirect ownership, voting rights, rights to appoint or remove directors and other forms of significant influence or control.

7. HMRC Guidance Search and AI

RiskBright may use artificial intelligence to help users locate and understand relevant information, including through HMRC Guidance Search.

AI-generated or AI-assisted information may contain errors, omissions or incorrect interpretations.

Users should review the underlying HMRC guidance or other authoritative source where appropriate and should not rely solely on an AI-generated response when making an AML, regulatory or legal decision.

HMRC Guidance Search is an information and research-support tool. It does not constitute legal advice or a definitive interpretation of HMRC guidance.

8. External and Official Sources

RiskBright may provide information from, or links to, government bodies, official registers and other external sources.

External information can change, become outdated, contain errors or become temporarily unavailable.

RiskBright does not control third-party or official sources and cannot guarantee their continued availability, completeness or accuracy.

Where information is important to an AML decision, users should check the underlying official source where appropriate.

9. Information Entered by Users

RiskBright outputs may depend on information entered or selected by users.

Incorrect, incomplete or outdated information may affect the relevance or usefulness of the resulting questions, considerations, calculations or documents.

Users are responsible for checking the information they enter and for determining whether additional enquiries, evidence or action are required.

10. No Guarantee of Compliance

RiskBright is designed to support better AML processes and decisions, but use of the platform does not guarantee compliance with any particular law, regulation, regulatory requirement or guidance.

AML requirements and official guidance may change over time and may depend on the particular circumstances of a customer, transaction, business relationship or agency.

Users remain responsible for keeping themselves appropriately informed of the requirements applicable to their organisation.

11. Relationship with Our Terms of Service

This Disclaimer should be read together with RiskBright's Terms of Service, Privacy Policy and, where applicable, Data Processing Agreement.

The Terms of Service contain the contractual provisions governing use of RiskBright, including limitations relating to the Service and liability.

If there is any inconsistency between this Disclaimer and the Terms of Service regarding your contractual rights or obligations, the Terms of Service will take precedence.

12. Contact Us

If you have questions about RiskBright or this Disclaimer, please contact:

RiskBright

A trading name of Shermika Blaise Robinson

Office By31 Curthill House

60 Water Lane

Cheshire

SK9 5AJ

Wilmslow

United Kingdom

Email: hello@riskbright.co.uk