Legal / Terms
Terms of service.
These terms cover a firm’s subscription to Koheriant Verify. Verify is provided by Bureau St. James, LLC, a Wyoming limited liability company (“we”). The firm that subscribes is “you”. By subscribing you agree to them.
What Verify is
Software for client due diligence under anti-money-laundering law. Your client completes the form themselves, your staff review the file and record a decision, and the file is kept for the period your law requires and then destroyed. That is the whole of what we provide.
We are not lawyers
We are a software company. We do not practise law, we are not your adviser, and nothing in Verify or on this website is legal advice. We do not review your client files and we do not make due diligence or risk decisions. Verify is not a replacement for your own counsel, and you should confirm with your own legal counsel that your use of Verify meets your firm’s requirements. The wording it produces for your privacy notice, your AML policy and your retention period is a starting point for your adviser to review, and you should not rely on it with a client until they have. If you need to know what your obligations are, ask a lawyer.
You are the obliged entity, and the decisions are yours
Your obligations under your anti-money-laundering law, such as the Wwft in the Netherlands and, from 10 July 2027, Regulation (EU) 2024/1624, are yours and remain yours. Verify does not decide whether to accept a client, whether a risk rating is right, whether a person is who they say they are, or whether a file satisfies your supervisor. Your compliance officer decides, and Verify records that they did, when, and on what they were looking at.
Screening is a provider's answer, not ours
When Verify screens a name against sanctions and politically-exposed-person data, it sends the name to a third-party provider and records what the provider sent back. We hold no sanctions list and no PEP list, and we form no view about any person. What you are shown is a list of possible matches with the provider’s own score and labels beside them: candidates, not findings. Whether a candidate is your client is your decision and nobody else’s. Provider data may be incomplete, out of date or wrong, and a screen that returns nothing is not a statement that there was nothing to find.
The subscription
Verify is licensed per firm, with no limit on the number of your staff who use it. You can take it by the year, paid in advance, or by the month at the higher monthly rate. Each subscription includes 2,400 client files a year (on a monthly subscription, a twelfth of that each month); each file beyond that is charged at €9. The price and the allowance are those stated at checkout or in your order form. Billing is through Stripe. The subscription renews for another term unless you cancel before the renewal date by writing to us. Prices exclude VAT and other taxes, which are added where they apply.
What you are responsible for
You are responsible for having a lawful basis to send us your clients’ personal data, and for telling your clients that you use us, which your own privacy notice does. You are responsible for the accuracy of what you and your clients enter, for who at your firm has access, for removing people who should no longer have it, and for not using Verify unlawfully or for any purpose other than your own due diligence.
Your clients' data
You are the controller of your clients’ personal data and we are your processor. The data processing agreement (verwerkersovereenkomst) forms part of these terms and governs that processing; where it differs from this page on a data protection question, it prevails. The data is stored and processed in the European Union, on Amazon Web Services in Ireland. Verify does not collect copies of passports or identity cards.
What we promise, and what we do not
We will provide Verify with reasonable skill and care, and we will tell you before we change these terms or the sub-processors that handle your clients’ data. Beyond that, and as far as the law allows, Verify is provided as it is: we do not warrant that it is free of faults, that it will be available without interruption, or that using it will satisfy your obligations or your supervisor. Nothing here limits anything we cannot limit by law.
The limit of our liability
Our total liability to you, however it arises and whether in contract, negligence or otherwise, will not exceed the fees you actually paid us in the twelve months before the claim. At the current annual price that is €4,995. We are not liable for lost profit, lost business, lost goodwill, the cost of substitute services, any fine or penalty imposed on you by a regulator or supervisor, or any loss that is indirect or consequential, even if we were told it was possible. None of this applies to liability that cannot lawfully be excluded, including for fraud or for death or personal injury caused by negligence.
You indemnify us
You will indemnify us against any claim, loss, fine or cost we incur arising out of your use of Verify: your decisions about your clients, the data you send us, your breach of these terms or of the data processing agreement, any claim brought by one of your clients or by your supervisor, and any claim that your use of Verify infringed somebody’s rights. We will tell you promptly about any such claim and will not settle it without asking you.
Suspension and ending it
We may suspend access if an invoice is unpaid after we have asked for it, or if your use is unlawful or puts the service or other firms at risk; we will tell you why. You can cancel at the end of your term. Either of us can end the subscription for a material breach the other has not put right within 30 days of being told about it. You can export your data for 30 days after the subscription ends. It is then deleted, except where the data processing agreement or the law provides otherwise. Your law may require you to keep your due diligence records for longer (five years under Article 77 of Regulation (EU) 2024/1624); keeping them after the subscription ends is your responsibility, so export them before access ends.
Changes
If we change these terms, we will email you before the change takes effect. Changes to the sub-processors that handle your clients’ data are notified at least 30 days in advance, as the data processing agreement sets out. If you do not accept a change, you can cancel before it takes effect.
Governing law
These terms are governed by the law of the State of Wyoming, and the courts of Wyoming have jurisdiction. That does not displace the European Union data protection law that applies to your clients’ data or the rights your clients have under it, which are governed by that law and by the data processing agreement. Where you have signed an order form or agreement with us that says otherwise, that document prevails over this page.