1.   Overview

NextGen AML provides subscription-based AML/CTF compliance services. Subscriptions are offered for an initial minimum term of 12 months as specified in the Order Form, which is auto-generated at the time of Stripe checkout in accordance with clause 9.10 of the MSA. Customers accept this Policy at the time of online checkout as part of the click-to-accept process described in the MSA.

2.   Subscription Term and Auto-Renewal

Each Subscription Term commences on the Start Date in the Order Form and continues for the initial period stated. Unless otherwise stated in the Order Form, Subscription Terms will automatically renew for successive 12-month periods.

To prevent automatic renewal, either party must give the other at least 30 days’ written notice before the end of the then-current Subscription Term, consistent with clause 9.1 of the MSA. NextGen AML will send a renewal reminder at least 45 days before the renewal date.

For online subscribers, notice of non-renewal may be given by:

• using the “Cancel Subscription” function in the account management section of the Platform (which constitutes valid written notice under clause 11.3 of the MSA); or
• sending written notice by email to admin@nextgenaml.com.au.

A written cancellation confirmation recording the notice date and effective termination date will be sent to the Client’s registered email address.

3.   Cancellation During Initial Minimum Term

During the initial minimum Subscription Term, Clients may not cancel for convenience unless the relevant Order Form expressly permits it. Termination for convenience during the initial term requires at least 90 days’ written notice and the Client remains liable for all Fees payable up to the effective cancellation date, consistent with clause 11.3 of the MSA.

Termination for cause (e.g., NextGen AML material breach) during the initial term is governed by clause 11.2 of the MSA, which provides a 30-day cure period.

4.   Cancellation After Minimum Term

After the initial minimum Subscription Term, either party may terminate for convenience by giving at least 30 days’ written notice of non-renewal before the next renewal date (see clause 2 above), or at least 90 days’ written notice to terminate mid-term (consistent with clause 11.3 of the MSA).

Where cancellation takes effect mid-Billing Cycle, the cancellation takes effect at the end of the Billing Cycle following expiry of the notice period. The Client remains liable for all Fees payable up to the effective cancellation date.

5.   Refunds

Fees paid to NextGen AML are generally non-refundable, consistent with clause 9.7 of the MSA. Specifically:

• no pro-rata refunds are provided for unused portions of any Billing Cycle;
• subscription fees paid in advance are non-refundable except where expressly required by law or as provided below.

Exceptions where a refund may apply:

• Warranty remedy (clause 10.2 of the MSA): if NextGen AML fails to remedy a breach of the Platform Performance Warranty within 30 days of a written warranty claim, the Client may terminate the affected Order Form and receive a refund of pre-paid, unused Fees attributable to the terminated portion.
• Termination for NextGen AML’s convenience (clause 11.3 of the MSA): NextGen AML will refund pre-paid Fees for the period after the effective termination date, less any applicable early termination fees.
• Modification objection (clause 18 of the MSA): if the Client objects in writing to a material modification to the MSA and NextGen AML elects to allow termination, NextGen AML will issue a pro-rata refund of pre-paid Fees.

6.   Data Access After Cancellation

Following expiry or termination of a Subscription Term, the Client may request a complete export of its Client Data within 30 days of the effective termination date, consistent with clause 3.4 of the MSA. After this 30-day window, NextGen AML may delete or de-identify Client Data in accordance with its standard data retention schedule, unless retention is required by Law (including the 7-year AML/CTF record-keeping obligation under section 104 of the Act).

7.   Consumer Rights

Nothing in this Policy limits or excludes any rights a customer may have under the Australian Consumer Law (Schedule 2 to the Competition and Consumer Act 2010 (Cth)), including any right to a remedy where services fail to meet applicable consumer guarantees. This is consistent with clause 13.6 of the MSA.

8.   Billing via Stripe

For subscriptions originated through NextGen AML’s online platform, billing is processed through Stripe. The auto-generated Order Form (issued at the time of Stripe checkout under clause 9.10 of the MSA) will confirm the billing frequency, Fees, and renewal date applicable to the Client’s subscription. Clients should retain the PDF Order Form delivered to their registered email address as a billing record.

Failed payment processing: if a payment fails, NextGen AML will make reasonable attempts to notify the Client. If the overdue amount is not resolved within 30 days, NextGen AML may suspend access to the Services in accordance with clause 5 of the MSA.

9.   Contact

Customers who believe they may be entitled to a refund or other remedy under this Policy or the Australian Consumer Law should contact NextGen AML at:

10.   Updates to This Policy

NextGen AML may update this Policy from time to time in accordance with the modification process in clause 18 of the MSA. Material changes will be notified at least 30 days in advance via email and/or in-platform notification. Continued use of the Services after an updated Policy takes effect constitutes acceptance.

11.   Governing Law

This Policy is governed by the laws of the State of Victoria, Australia, consistent with clause 20.1 of the MSA. Any dispute arising under this Policy is subject to the dispute resolution process in clause 19 of the MSA.

NextGen AML Pty Ltd  |  ABN 31 551 154 091  |  Effective Date: 10 June 2026   |  Version 2.0