Terms of Engagement — AML/CFT
These are the terms for our AML/CFT annual report and compliance document service in New Zealand. They're written to be read, not skimmed past. If anything here doesn't suit you, say so before you pay and we'll talk about it.
1. Who we are and what this is
Deplexify ("we", "us") provides a document preparation and filing service. We prepare your AML/CFT annual report, and where you've engaged us for it, your written risk assessment and AML/CFT programme. You review what we've prepared, you approve it, and we lodge it through the AML Online portal on your behalf.
Your business is supervised by the Department of Internal Affairs. That relationship is between you and them. We are not a party to it, and nothing here changes who is responsible for your compliance — see section 8.
2. What you get
For the fee in section 4, for one reporting period:
Annual Report Service
- A structured questionnaire, and a working session if you'd rather talk it through
- Preparation of your annual report from the answers you give us
- A currency check on your existing risk assessment — whether it still describes the business you actually run, and what's drifted
- The report put in front of you for review and approval before anything is lodged
- Lodgement through the AML Online portal once you've approved it
- A reminder calendar for next year's window
Full Compliance Pack — everything above, plus:
- A written risk assessment prepared for your firm, your sectors and your client base
- An AML/CFT programme written to sit alongside that risk assessment
- A walk-through of both documents so the people who have to use them understand them
3. What isn't included
- We do not act as your AML/CFT compliance officer. That role sits inside your firm with a person you appoint. We can't hold it, and we won't be described as holding it.
- Customer due diligence on your own clients, ongoing monitoring, transaction screening, or any decision about whether to act for a particular client
- Preparing or lodging suspicious activity reports or prescribed transaction reports — those are yours to make and to judge
- Training your staff, beyond the walk-through in section 2
- Representing you in any dealing with your supervisor about an enquiry, a review or an enforcement matter
- Correcting or completing information you gave us that turns out to be wrong
- Next year's report, or a second reporting period — each is a separate engagement at the then-current fee
3a. Independence — the one that catches people out
The same works in reverse: if you've engaged us only for the annual report and someone else wrote your programme, that doesn't make us your auditor either. We don't provide independent audits at all.
4. Fee and payment
Flat fees, in New Zealand dollars, launch pricing — confirmed to you in writing before you pay anything, and held at the quoted figure for the engagement we quote for:
- NZ$495 + GST — Annual Report Service
- NZ$1,495 + GST — Full Compliance Pack
- Payable in full before work begins, unless we've agreed otherwise with you in writing.
- No hourly billing and no add-ons. The fee covers everything in section 2, including the back-and-forth to get your answers right.
- The fee is for the work described in section 2, not for a particular outcome.
- If it turns out you aren't required to file at all, we'll tell you and refund you in full. We'd rather lose the fee than invoice you for a report you didn't need.
5. The deadline, and your part in it
- Get us your questionnaire answers by 15 August. That leaves time to draft, for you to read it properly, and to lodge with room to spare.
- You have 5 days to respond to any follow-up question from us during the window. They're usually one-liners.
- If we receive your answers after 15 August we'll still do everything we reasonably can to file on time, but we can't guarantee it, and a late or missed filing in that situation isn't something we're responsible for.
- If we can't file because you haven't approved the report, or haven't given us the portal access we need, the work we've done is complete as far as it can go and the fee is treated as earned.
We'll chase you, more than once, before any of that bites. Nothing goes quiet.
6. Refunds
- Before we start work: full refund, no questions.
- If you turn out not to be a reporting entity and don't have to file: full refund, whatever stage we're at.
- Once we've delivered your draft report, risk assessment or programme, the fee is non-refundable. That's where the work sits — the lodgement itself is the easy part.
- If we fail to file an approved report on time for reasons within our control, we refund in full.
7. Starting straight away
The window is short, so we start as soon as you've paid and sent your answers. By accepting these terms you expressly ask us to begin immediately, and you accept that once we've delivered a draft the fee is non-refundable under section 6. If you'd rather we waited, tell us and we will.
8. Your responsibilities
- The information you give us must be true, complete and current. We prepare your report from what you tell us. We don't verify it, and we can't.
- You review and approve every document before it's lodged. The attestation in your annual report is yours. When you approve it you are confirming, as your firm, that what it says is accurate — so read it properly rather than clicking through it.
- We never lodge anything you haven't confirmed. If you haven't approved it, it doesn't get filed, whatever the date is.
- Your AML/CFT obligations remain entirely yours. Appointing a compliance officer, doing customer due diligence, keeping records, reporting suspicious activity, and having a current risk assessment and programme are your firm's responsibilities. Engaging us doesn't transfer any of them.
- You give us the portal access we need, and you don't change the credentials mid-engagement without telling us.
- You tell us promptly if anything material changes during the engagement — new services, new client types, a change of ownership, a supervisor enquiry.
9. Liability
- Our total liability to you, for anything arising out of this engagement, is limited to the fee you paid us.
- We're not liable for any penalty, enforcement action or supervisory consequence arising from information you gave us that was wrong or incomplete, or from a delay in giving it to us.
- We're not liable for lost profits, lost contracts or reputational loss, however they arise.
- Nothing here limits liability for death or personal injury caused by our negligence, for fraud, or for anything else that can't lawfully be limited — including your rights under the Consumer Guarantees Act 1993 where they apply.
10. Your information
- We collect and hold your firm's details and the answers you give us, in order to prepare and lodge your report. That's the only thing we use it for.
- We handle it under the Privacy Act 2020.
- We don't share it with anyone other than your supervisor as part of the filing itself, unless the law requires it.
- We keep your file for 7 years, so next year's report is easier and because you may need it, then delete it.
- You can ask for a copy of your file, or ask us to delete it, at any time: hello@deplexify.com.
11. Record of acceptance
When you tick the box on our intake form we record the version of these terms you accepted, the date and time, and the IP address it came from. That record is kept with your file. It exists so that if there's ever a disagreement about what was agreed, neither of us is relying on memory.
If we change these terms we publish a new version with a new number and date. The version you accepted is the one that governs your engagement.
12. General
- These terms are the whole agreement between us, and replace anything said beforehand.
- Either of us may end the engagement in writing; section 6 governs what happens to the fee.
- We may use subcontractors, and remain responsible for their work.
- This engagement is governed by New Zealand law.
Questions before you sign? Ask. We'd much rather answer now than argue later — hello@deplexify.com.