Last Updated: March 2026 · Effective Date: March 15, 2026
By accessing or using the Sanctuary platform, you agree to be bound by these Terms of Service. If you do not agree, do not use the Platform.
Eligibility: You must be at least 18 years of age and have the legal capacity to enter into binding agreements in your jurisdiction. By using the Platform, you represent and warrant that you meet these requirements.
Cooling-off period: If you are a consumer in the United Kingdom or European Union, you have the right to cancel your subscription within 14 days of purchase without giving a reason (Consumer Contracts Regulations 2013, reg. 29). If you request that the Services begin during this 14-day period, you acknowledge that you will lose your right to cancel once the Services have been fully performed, and you may be charged a proportionate amount for Services already provided.
Key terms used throughout these Terms of Service, including definitions of Platform, Services, Merchant, Risk Score, and Critical Risk.
| Term | Definition |
|---|---|
| "Sanctuary" | Sanctuary Compliance Digital Ltd, a company incorporated in England and Wales (Company No. 17150683), its successors, assigns, and affiliates. References to “Sanctuary,” “we,” “us,” or “our” refer to this entity. |
| "Platform" | The Sanctuary software, APIs, and web dashboard accessible at sanctuary.cv. |
| "Services" | AML Intelligence Services: wallet screening, transaction monitoring, risk scoring, compliance reporting, and related analytical tools provided through the Platform. |
| "Risk Score" | A numerical assessment (0–100) of the AML/sanctions risk of a blockchain address, generated by the Platform’s proprietary algorithm. This is an informational output, not a legal determination. |
| "Critical Risk" | A Risk Score of 90 or above, indicating potential association with sanctioned entities, illicit activities, or high-risk sources as defined by applicable sanctions lists. |
Sanctuary is a technology company, not a bank or financial institution. We provide software tools for blockchain risk assessment.
Sanctuary is a technology company that provides software tools for blockchain risk assessment. Sanctuary is not a bank, financial institution, money services business (MSB), electronic money institution (EMI), or payment institution (PI) as defined under Directive 2015/2366/EU (PSD2), Regulation (EU) 2023/1114 (MiCA), the Bank Secrecy Act (31 U.S.C. §5311 et seq.), or equivalent legislation in any jurisdiction.
Legal basis: FATF Updated Guidance (2021), para. 55–58 — “A person who solely develops or sells software... is not a VASP... unless they also engage in exchanging or transferring funds as a business on behalf of others.” MiCA Recital 22 — technical service providers without control over crypto-assets are not CASPs. CIMA VASP Guidance (2024) — “A DeFi application (software program) is not, in and of itself, a VASP.”
Notwithstanding the above, in certain jurisdictions, specific activities performed by the Platform may be subject to registration, licensing, or notification requirements. Sanctuary reserves the right to restrict or suspend Services in any jurisdiction where such requirements are not met or where continued operation would create material legal risk.
The Platform may require identity verification when risk thresholds are triggered or when required by law.
Legal basis: FATF Recommendation 10, EU 6AMLD Art. 13, MiCA Art. 68
The Platform reserves the right, at its sole discretion, to require any User or Merchant to undergo identity verification (Know Your Customer / Know Your Business) procedures at any time, including but not limited to:
Failure to comply with a KYC/KYB request within 14 calendar days shall result in:
Quarantined funds shall be released to the Merchant’s designated Treasury address upon successful completion of KYC/KYB, or returned to the originating address if technically feasible and lawful.
Risk scores are informational only, not legal advice. Aggregate liability is capped. Indirect damages are excluded.
To the maximum extent permitted by applicable law, Sanctuary’s aggregate liability arising from or related to AML Intelligence Services shall not exceed the total fees paid by the Merchant to Sanctuary during the twelve (12) months immediately preceding the event giving rise to the claim.
The Services do not constitute and shall not be construed as legal advice, tax advice, financial advice, investment advice, or regulatory guidance of any kind. Risk Scores are probabilistic outputs of an automated system and carry no legal weight or regulatory authority. The Merchant is solely responsible for obtaining independent legal, tax, and regulatory counsel in all relevant jurisdictions.
Cf. FATF Updated Guidance (2021): “Risk scoring by software tools does not constitute a regulatory determination.”
To the maximum extent permitted by applicable law, the Merchant agrees that any dispute resolution proceedings shall be conducted solely on an individual basis and not in a class, consolidated, or representative action. The Merchant waives any right to participate in a class action, class arbitration, private attorney general action, or any other proceeding where any party acts or proposes to act in a representative capacity.
The Platform must not be used for illegal activities, sanctions evasion, money laundering, or unauthorized resale of intelligence data.
References: OFAC SDN List, EU Sanctions Regulation 269/2014, FATF AML/CFT Standards
The Merchant shall not use the Platform to:
Violation of these terms will result in immediate account suspension and may be reported to relevant law enforcement authorities.
The Platform and its outputs may be subject to export control laws and regulations of the United Kingdom, the European Union, and other jurisdictions. The Merchant represents and warrants that it is not located in, and will not export or re-export the Platform or its outputs to, any country or person subject to applicable trade sanctions or embargoes. The Merchant shall comply with all applicable export control and sanctions laws, including HM Treasury financial sanctions, EU Consolidated Sanctions List, UN Security Council Sanctions, and US OFAC regulations.
These Terms are governed by English and Welsh law. Disputes are settled by LCIA arbitration in London.
These Terms shall be governed by and construed in accordance with the laws of England and Wales, without regard to its conflict of law provisions.
Any dispute arising out of or in connection with these Terms shall be finally settled by arbitration under the Rules of the London Court of International Arbitration (LCIA). The number of arbitrators shall be one. The seat of arbitration shall be London, United Kingdom. The language of the arbitration shall be English.
If any provision of these Terms is held to be invalid, illegal, or unenforceable in any jurisdiction, such invalidity, illegality, or unenforceability shall not affect any other provision of these Terms and shall not invalidate or render unenforceable such provision in any other jurisdiction.
The Platform is unavailable in sanctioned jurisdictions, Russia, Belarus, and jurisdictions where crypto services are prohibited.
The Platform is not available and shall not be used in the following jurisdictions:
Users accessing the Platform from restricted jurisdictions shall have their accounts suspended without prior notice. Sanctuary shall not be liable for any losses arising from such suspension.
Sanctuary does not actively market, promote, or solicit users within the European Union. In accordance with Article 61 of Regulation (EU) 2023/1114 (MiCA) and ESMA Guidelines on reverse solicitation (December 2024), Services may be provided to EU-based clients only where the client has initiated the request on their own exclusive initiative, without any prior solicitation or promotion by Sanctuary.
Note: ESMA interprets reverse solicitation strictly. Any promotional activity, advertising, affiliate marketing, or use of disclaimers does not override the factual assessment of client initiation (ESMA Final Report, Dec 2024).
The Platform is not marketed to, and Services are not offered to, individuals or entities domiciled in the United Kingdom. The Platform does not hold FCA registration under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). UK-domiciled persons who access the Platform do so entirely on their own initiative and at their own regulatory and legal risk.
Note: The UK FCA Cryptoasset Gateway (FSMA 2000 Cryptoassets Order 2025) is expected to open for applications in September 2026, with the full regime effective October 2027. Sanctuary may apply for authorization at that time.
The Platform is not available in the United States. Sanctuary does not hold FinCEN Money Services Business (MSB) registration (31 U.S.C. §5311 et seq.) and does not hold state-level Money Transmitter Licenses (MTL) in any US state. US persons (as defined in the US Internal Revenue Code §7701(a)(30)) are prohibited from using the Platform. Violation of this restriction will result in immediate account termination.
Paid plans are billed in USDT or credits. Subscriptions auto-renew. 30-day grace period for payment issues.
Paid plans are billed in USDT or via credits purchased through the Platform. Subscriptions auto-renew unless cancelled before the billing cycle ends. We offer a 30-day grace period for payment issues. Refunds are not provided for partial months. Free tier users are subject to daily usage limits as described on the Pricing page.
Current plans: Free ($0), Professional ($199/mo), Business ($499/mo), Enterprise (custom). Full feature comparison is available on the Pricing page.
If you are a consumer within the meaning of the UK Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 or equivalent EU legislation, you have the right to cancel your subscription within 14 days of purchase. To exercise this right, notify us at [email protected] before the cancellation period expires. If you have requested that the Services begin during the cancellation period and subsequently cancel, you will be charged a proportionate amount for the Services provided up to the point of cancellation. Refunds will be processed within 14 days of receiving your cancellation notice.
All algorithms, scoring models, and intelligence methods are proprietary. API output may not be resold without authorization.
All content, algorithms, risk scoring models, and intelligence aggregation methods are proprietary to Sanctuary. You may not copy, modify, distribute, or reverse-engineer any part of the Service. API output may be used in your internal business operations but may not be resold or redistributed without written authorization.
The Merchant shall not use any output, data, scores, reports, or other information obtained from the Platform to train, retrain, fine-tune, or otherwise develop any artificial intelligence, machine learning, large language model, neural network, or similar system. This prohibition includes uploading, inputting, or submitting any Platform output to any system or service for the purpose of AI training or model improvement.
Platform outputs, including Risk Scores, analytical reports, and graph visualisations, may not be submitted to any court, tribunal, regulatory body, or law enforcement agency without the prior written consent of Sanctuary. Any permitted disclosure shall be limited to static image exports (PNG or PDF format) and shall include a conspicuous disclaimer stating that the output is an informational assessment, not a legal determination.
The Merchant grants Sanctuary a non-exclusive, worldwide, royalty-free licence to use anonymised and aggregated data derived from the Merchant's use of the Platform (including blockchain addresses queried, transaction patterns, and check metadata) for the purpose of improving the Platform's scoring accuracy and intelligence database. This licence does not extend to the Merchant's account data, personal information, or any data that could identify the Merchant or its users. This licence survives termination of these Terms.
Each party agrees to treat as confidential all non-public information received from the other party in connection with the use of the Platform, including API keys, account credentials, risk scoring outputs, and business data. The receiving party shall not disclose confidential information to any third party without the prior written consent of the disclosing party, except as required by law, regulation, or a binding order from a competent authority. Upon termination, each party shall promptly delete or return all confidential information of the other party. These confidentiality obligations survive termination of these Terms for a period of two (2) years.
Risk Scores are probabilistic and may produce false positives or negatives. Sanctuary bears no responsibility for decisions based on Platform outputs.
Risk Scores are generated from publicly available blockchain data, community reports, governed evidence classes, and proprietary analysis. Sanctuary does not guarantee the accuracy, completeness, timeliness, suitability, or validity of any Risk Score, risk assessment, or analytical output.
False positives and false negatives may occur. The Merchant acknowledges that no risk assessment system is infallible and that Risk Scores should be used as one input among many in the Merchant’s own compliance decision-making process. The Merchant shall not rely solely on Risk Scores for making financial, compliance, legal, or regulatory decisions.
Sanctuary bears no responsibility for any decisions made, actions taken, or actions not taken based on information provided through the Platform. The Merchant is solely responsible for interpreting and acting upon the Platform’s outputs in accordance with applicable law.
Accounts may be suspended or terminated for Terms violations. Data deletion available subject to retention obligations.
We may suspend or terminate your account if you violate these Terms, abuse the Service, or submit fraudulent reports. Upon termination, your access to the Service will cease immediately. You may request deletion of your account data at any time, subject to our data retention obligations for audit and compliance purposes (see Privacy Policy).
Users agree to indemnify Sanctuary against claims arising from their use of the Service or violation of these Terms.
You agree to indemnify, defend, and hold harmless Sanctuary and its officers, directors, employees, and agents against any claims, damages, losses, liabilities, costs, or expenses (including reasonable legal fees) arising from: (a) your use of the Service; (b) your violation of these Terms; (c) your violation of any applicable law or regulation; (d) infringement of any third-party rights through your use of the Platform.
Disputes are reviewed within 5 business days. Pro and Enterprise customers receive credits for confirmed false positives.
If a wallet address you control receives a Risk Score you believe is incorrect, you may submit a dispute through the platform. We review all disputes within 5 business days. If we confirm the score was incorrect, Pro and Enterprise customers receive a credit for that billing period. See our False Positive Policy for full details.
Sanctuary is not liable for failures caused by blockchain congestion, DDoS attacks, regulatory changes, or other events beyond reasonable control.
Sanctuary shall not be liable for any delay or failure in performance resulting from causes beyond its reasonable control, including but not limited to:
Reference: UNIDROIT Principles Art. 7.1.7 (force majeure), Reg. (EU) 2022/2554 (DORA) Art. 11 (ICT-related incident management).
No partnership, joint venture, or agency relationship is created between Sanctuary and the Merchant.
Nothing in these Terms shall be construed to create a partnership, joint venture, employer-employee, agency, or franchisor-franchisee relationship between Sanctuary and the Merchant. Neither party has the authority to bind the other or to incur any obligation on behalf of the other. Sanctuary acts solely as an independent technology provider.
Reference: UK Partnership Act 1890 §1 — no partnership shall be implied from the mere provision of technology services.
These Terms, together with the Privacy Policy, AUP, DPA, and any Order Forms, constitute the entire agreement.
These Terms, together with the Privacy Policy, Acceptable Use Policy, Data Processing Agreement, and any Order Forms or Enterprise License Agreements executed between the parties, constitute the entire agreement between the Merchant and Sanctuary with respect to the subject matter hereof. This agreement supersedes all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral, regarding such subject matter.
Merchants may not assign these Terms without consent. Sanctuary may assign freely in connection with corporate events.
The Merchant may not assign or transfer these Terms, or any rights or obligations hereunder, without the prior written consent of Sanctuary. Sanctuary may assign or transfer these Terms, in whole or in part, without restriction, including in connection with a merger, acquisition, corporate reorganisation, or sale of substantially all of its assets. Any attempted assignment in violation of this section shall be null and void.
Key sections survive termination, including Limitation of Liability, Governing Law, IP, and Indemnification.
The following sections shall survive any termination or expiration of these Terms: §4 (Limitation of Liability), §5 (Prohibited Use), §6 (Governing Law & Dispute Resolution), §10 (Intellectual Property), §11 (Data Accuracy), §13 (Indemnification), §15 (Force Majeure), §16 (Independent Parties), §17 (Entire Agreement), this §19, and any other provisions that by their nature should survive.
By using the Platform, you consent to receiving all communications electronically.
By using the Platform, the Merchant consents to receiving communications from Sanctuary electronically, including via email, in-app notifications, and the Platform dashboard. The Merchant agrees that all agreements, notices, disclosures, and other communications provided electronically satisfy any legal requirement that such communications be in writing.
Reference: Regulation (EU) 910/2014 (eIDAS), US Electronic Signatures in Global and National Commerce Act (E-SIGN).
Material changes are communicated at least 14 days before taking effect. Continued use constitutes acceptance.
Sanctuary reserves the right to modify these Terms at any time. Material changes will be communicated via email to the Merchant’s registered address or via in-app notification at least fourteen (14) calendar days before taking effect. Non-material changes (formatting, clarifications) may be made without prior notice. Continued use of the Platform after the effective date of any modification constitutes acceptance of the revised Terms. If the Merchant does not agree with any modification, the Merchant’s sole remedy is to terminate the account before the effective date.
For questions about these Terms, contact [email protected]. Response time: 5 business days.
For questions about these Terms, contact us at [email protected] or through the Contact page.
Response time for legal inquiries: 5 business days. For urgent compliance matters, include “URGENT” in the subject line.