Terms of Service
Effective Date: September 18, 2026 • Governing Law: British Columbia, Canada
1. Regulatory Status & Scope of Software
FinFile provides workflow automation, machine extraction, deterministic scoring, and custody archiving tools for Canadian reporting entities. FinFile is not a law firm, compliance consultancy, or FINTRAC reporting agent. The subscriber’s designated Compliance Officer and Broker of Record retain statutory responsibility under PCMLTFA for verifying borrower identity, filing Suspicious Transaction Reports (STRs) or Large Cash Transaction Reports (LCTRs), and ensuring regulatory compliance.
2. Two-Role Custody & Authorized Signoff
To uphold compliance integrity, subscriber firms agree to enforce the Two-Role Custody model. Originating brokers cannot authorize or seal their own compliance files; designated Principal Brokers or Compliance Officers must review, approve, and apply signoff to each transaction package.
3. Subscription, SLA & Uptime
FinFile delivers a 99.9% uptime Service Level Agreement (SLA). Maintenance windows are scheduled outside standard Canadian business hours (Pacific and Eastern standard times). All cryptographic hash verifications and archival retrievals remain accessible 24/7.
4. Termination & File Export
Upon termination or cancellation of subscription, FinFile provides a 90-day transition grace period during which subscribers may download complete, cryptographic zip manifests of all historic transaction evidence packs satisfying provincial 7-year document custody requirements.