General Terms and Conditions of Service

These are GENERAL TERMS AND CONDITIONS OF SERVICE of SIGTAX Luxembourg S.A. , a company incorporated and validly existing under the laws of Luxembourg, reg. number B230049, reg. address 45 Boulevard Prince Henri, L-1724, Luxembourg

DEFINITIONS AND INTERPRETATION
1. Definitions
  1. "Agreement" means the Service Agreement together with these General Terms and any Addenda thereto;
  2. "Addenda" means the schedules, exhibits, and other attachments to the Service Agreement;
  3. "Business Day" means any day other than Saturday, Sunday, or a public holiday in Luxembourg;
  4. "Client" means the party contracting for Services as identified in the Service Agreement;
  5. "Confidential Information" means all non-public information disclosed by one Party to the other, whether orally, in writing, or in any other form;
  6. "General Terms" means these General Terms of Service;
  7. "OEC" means the Luxembourg Order of Expert-Comptables (Ordre des Experts-Comptables);
  8. "Parties" means SIGTAX and the Client collectively, and "Party" means either of them;
  9. "Personal Data" means any information relating to an identified or identifiable natural person as defined in Regulation (EU) 2016/679 (General Data Protection Regulation) and applicable Luxembourg data protection laws;
  10. "SIGTAX" means SIGTAX Luxembourg S.A., a company incorporated under the laws of Luxembourg;
  11. "Service Agreement" means any service agreement between SIGTAX and the Client that incorporates these General Terms by reference;
  12. "Services" means the services to be provided by SIGTAX as specified in the Service Agreement and any Addenda;
  13. "Working Files" means files, documents, or data in native software formats used internally by SIGTAX for the provision of Services.
2. Interpretation
  1. Words importing the singular include the plural and vice versa.
  2. References to persons include individuals, corporations, partnerships, and other legal entities.
  3. Headings are for convenience only and do not affect interpretation.
  4. In case of conflict between any Service Agreement and these General Terms, the specific provisions of the relevant Service Agreement shall prevail with respect to the Services described therein.
ACCEPTANCE AND SCOPE OF APPLICATION
1. Agreement to General Terms
  1. By executing the Service Agreement, the Client expressly agrees to be bound by these General Terms, which form an integral part of the contractual relationship between the Parties.
  2. These General Terms apply to all Services provided by SIGTAX to the Client under any Service Agreement, whether specified in a single agreement or across multiple service arrangements.
  3. The Client acknowledges having received, read, and understood these General Terms prior to execution of the Service Agreement.
  4. No variation or modification of these General Terms shall be effective unless agreed in writing and signed by both Parties.
1. Execution and Signatures
  1. This Agreement may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one and the same instrument.
  2. Electronic signatures, including but not limited to DocuSign, Adobe Sign, or other recognized electronic signature platforms, shall have the same legal effect as handwritten signatures.
  3. Signatures transmitted by facsimile or email (in PDF format) shall be deemed originals for all purposes, provided that such signatures are scanned copies of actual handwritten signatures and not digitally inserted images or graphics.
  4. Each Party represents that the person executing this Agreement on its behalf has the full authority to bind such Party to the terms hereof.
  5. Upon execution by both Parties, this Agreement shall be binding and enforceable in accordance with its terms.
SERVICE PROVIDER OBLIGATIONS
1. Professional Standards
  1. SIGTAX shall perform the Services with professional care, skill, and diligence in accordance with recognized professional standards applicable in Luxembourg.
  2. SIGTAX shall comply with all applicable laws, regulations, and professional standards in the provision of the Services.
  3. SIGTAX shall maintain current knowledge of relevant legal and regulatory requirements affecting the Services.
2. Personnel and Insurance
  1. SIGTAX shall assign qualified personnel with appropriate skills and experience to perform the Services.
  2. SIGTAX shall maintain adequate professional indemnity insurance throughout the term of this Agreement.
  3. Upon reasonable written request and not more than once per calendar year, SIGTAX may provide a certificate of insurance confirming the existence and general scope of professional indemnity coverage, without disclosure of specific policy terms, limits, or premiums.
3. Legal Compliance
  1. SIGTAX shall ensure that all Services are provided in compliance with Luxembourg law and any other applicable jurisdictions as relevant to the Services.
  2. SIGTAX shall maintain appropriate records and documentation as required by applicable professional and regulatory standards.
  3. SIGTAX shall cooperate with any regulatory investigations or inquiries related to the Services, subject to applicable confidentiality obligations.
SERVICE PROVIDER RIGHTS
1. Suspension and Termination Rights
  1. SIGTAX may suspend or terminate the provision of Services in case of material breach by the Client, which includes but is not limited to:
    1. Payment delays exceeding seven (7) banking days from the due date;
    2. Failure to provide required compliance documentation or information within fifteen (15) days of a written request, including KYC/AML documentation under Section 14;
    3. Failure to deliver accounting or operational documentation necessary for the provision of Services within a reasonable period of time;
    4. Provision of false, misleading, or incomplete information;
    5. Any breach of Client representations and warranties under this Agreement.
  2. Before exercising the right to suspend or terminate Services, SIGTAX shall, where appropriate and unless immediate action is required, provide the Client with written notice and a reasonable opportunity to remedy the situation.
  3. SIGTAX shall not be liable for any consequences arising from the suspension or termination of Services in accordance with this section.
2. Right to Refuse Instructions
  1. SIGTAX may refuse to execute any instruction which it reasonably believes to be:
    1. Contrary to applicable laws, regulations, or professional standards;
    2. Outside the scope of the agreed Services;
    3. Potentially damaging to the reputation or professional standing of SIGTAX.
  2. SIGTAX shall promptly inform the Client of any refusal to execute instructions and, where possible, suggest alternative approaches that comply with applicable requirements.
3. Immediate Termination Circumstances
  1. Notwithstanding any other provision of this Agreement, SIGTAX shall have the right to immediately terminate this Agreement without notice if:
    1. The Client is subject to criminal investigation or proceedings;
    2. The Client is found to be involved in money laundering, terrorist financing, tax evasion, fraud, or other illegal activities;
    3. The Client becomes subject to national or international sanctions;
    4. The Client uses the Services for purposes that breach applicable laws or regulations;
    5. Continuing the relationship would expose SIGTAX to legal, regulatory, or reputational risk.
  2. In cases of immediate termination, SIGTAX shall have no liability for any consequences resulting from such termination.
4. Set-off Rights
  1. SIGTAX shall be entitled to set off any amounts due from the Client against any amounts due to the Client.
  2. SIGTAX may exercise set-off rights upon written notice to the Client.
REPRESENTATIONS AND WARRANTIES
1. Service Provider Representations
  1. SIGTAX represents and warrants that:
    1. It has the legal capacity and authority to enter into this Agreement;
    2. It maintains appropriate professional qualifications and licenses required for the provision of the Services;
    3. The execution and performance of this Agreement will not violate any applicable law or regulation;
    4. It has obtained all necessary corporate approvals for entering into this Agreement.
  2. SIGTAX warrants that it will use reasonable efforts to perform the Services in accordance with the agreed timeframes and specifications.
2. Client Representations
  1. The Client represents and warrants that:
    1. It has the legal capacity and authority to enter into this Agreement;
    2. All information provided to SIGTAX is true, accurate, complete, and not misleading;
    3. It has obtained all necessary corporate approvals, board resolutions, or other internal authorizations for entering into this Agreement;
    4. The execution and performance of this Agreement will not violate any applicable law, regulation, or existing contractual obligation;
    5. It will comply with all applicable laws and regulations in its activities.
  2. The Client warrants that it will promptly notify SIGTAX of any material changes to the information previously provided. Material changes include changes affecting legal capacity, ownership structure, business activities, regulatory status, or any information that would affect SIGTAX's risk assessment.
  3. The Client acknowledges that SIGTAX provides similar services to other clients and agrees that the provision of such services shall not in itself constitute a conflict of interest.
3. No Implied Warranties
  1. Except as expressly set forth in this Agreement, SIGTAX makes no representations or warranties, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, or non-infringement.
  2. SIGTAX does not warrant that all Services will be successfully completed where such completion depends on the actions, decisions, or cooperation of third parties, including but not limited to:
    1. Refusal by notaries to authenticate documents or perform notarial acts;
    2. Refusal by banks to open accounts or provide banking services;
    3. Rejection by government authorities or regulatory bodies to approve applications or issue permits;
    4. Unavailability of required third-party services or systems;
    5. Changes in law or regulatory requirements that prevent completion of Services.
  3. SIGTAX's obligation in such circumstances is limited to using reasonable professional efforts to complete the Services and to promptly inform the Client of any third-party obstacles or refusals that may prevent completion.
  4. SIGTAX does not guarantee any specific timeline for completion of Services where such completion is subject to third-party processes or approvals beyond SIGTAX's control.
4. Independent Verification
  1. The Client specifically acknowledges that SIGTAX does not independently verify Client-provided information unless specifically agreed in writing.
  2. SIGTAX does not provide specialist advice outside the agreed scope of Services as defined in the Service Agreement.
  3. The Client acknowledges that it is responsible for making its own independent assessment of the information and advice provided by SIGTAX, except where such advice constitutes regulated professional services subject to specific professional standards under Luxembourg law.
  4. Where the Services involve reliance on third-party information or systems, SIGTAX's obligations are limited to exercising reasonable care in selecting and instructing such third parties.
CONFIDENTIALITY AND DATA PROTECTION
1. Confidentiality Obligations
  1. Each Party shall treat all Confidential Information received from the other Party as strictly confidential and shall not disclose such information to any third party without the prior written consent of the disclosing Party.
  2. Each Party shall use Confidential Information solely for the purpose of performing its obligations or exercising its rights under this Agreement.
  3. Each Party shall take reasonable measures to protect the confidentiality of Confidential Information, exercising the same degree of care that it uses to protect its own confidential information.
  4. The obligations of confidentiality shall survive termination of this Agreement and shall remain in effect for a period of five (5) years following such termination.
  5. Each Party shall ensure that its personnel with access to Confidential Information are bound by confidentiality obligations no less restrictive than those contained herein.
2. Permitted Disclosures
  1. The confidentiality obligations set forth in Section 6.1 shall not apply to information that:
    1. Is or becomes publicly available through no breach of this Agreement;
    2. Was known to the receiving Party prior to disclosure;
    3. Is independently developed by the receiving Party without use of Confidential Information;
    4. Is received from a third party who has the right to disclose such information.
  2. Either Party may disclose Confidential Information to the extent required by:
    1. Applicable law or regulation;
    2. Court order or legal process;
    3. Regulatory authorities in connection with their supervisory functions;
    4. Professional advisors bound by confidentiality obligations;
    5. Anti-money laundering and know-your-client requirements;
    6. Third parties engaged in the provision of Services, including notaries for corporate procedures, banks for account opening, registered office providers for domiciliation services, translation services, and courier services, where disclosure is necessary for Service performance and such parties maintain professional confidentiality standards.
  3. Where disclosure is required under Section 6.2.2, the disclosing Party shall, where legally permissible, provide prior notice to the other Party and limit disclosure to the minimum extent required. For routine Service provision under 6.2.2(f), general notice in the Service Agreement shall be sufficient.
3. Data Processing and Security
  1. SIGTAX shall process Personal Data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) where applicable.
  2. SIGTAX shall implement appropriate technical and organizational measures to ensure the security of Personal Data against unauthorized access, disclosure, alteration, or destruction.
  3. The Client consents to the processing of Personal Data necessary for the provision of the Services and compliance with applicable legal and regulatory requirements.
  4. Each Party shall promptly notify the other of any actual or suspected data breach that may affect the other Party's information.
  5. The Client expressly consents to SIGTAX sharing Personal Data with third-party service providers where necessary for Service delivery, including notaries, banks, registered office providers, government authorities, and other professional services, provided such sharing is limited to the minimum necessary and subject to appropriate data protection measures.
  6. SIGTAX shall ensure that any third parties receiving Personal Data under this Section maintain appropriate data protection standards and confidentiality obligations consistent with this Agreement and applicable data protection laws.
4. Communications Security
  1. Each Party shall take reasonable measures to prevent unauthorized access to communications under this Agreement.
  2. If either Party becomes aware of any unauthorized access to or disclosure of communications, they shall notify the other Party immediately.
  3. Neither Party shall be liable for any loss or damage resulting from unauthorized access to communications where such Party has implemented reasonable security measures as required under this Agreement.
  4. The Parties may agree to use encrypted communication channels for transmission of particularly sensitive information.
INTELLECTUAL PROPERTY
1. Ownership Rights
  1. Each Party retains ownership of its respective intellectual property rights existing prior to or developed independently of this Agreement.
  2. SIGTAX retains ownership of all intellectual property rights in its methodologies, processes, systems, templates, and proprietary tools used in the provision of Services.
  3. The Client retains ownership of all intellectual property rights in information, data, and materials provided to SIGTAX.
  4. Any work product created by SIGTAX specifically for the Client in the course of providing Services shall be owned by the Client, subject to SIGTAX's retained rights in its underlying methodologies and processes.
2. License Grant
  1. SIGTAX grants the Client a non-exclusive, non-transferable license to use any work product created specifically for the Client during the term of this Agreement and for the purposes contemplated herein.
  2. The Client grants SIGTAX a non-exclusive license to use Client information and materials solely for the purpose of providing the Services under this Agreement.
  3. The Client shall maintain strict confidentiality regarding SIGTAX's proprietary methodologies, processes, and systems, and shall not reverse engineer, copy, or disclose such methodologies to third parties.
3. Third Party Rights
  1. Each Party warrants that its performance under this Agreement will not infringe the intellectual property rights of any third party.
  2. Each Party shall promptly notify the other of any third-party claims of intellectual property infringement related to this Agreement.
  3. SIGTAX shall indemnify the Client against third-party claims arising from the use of SIGTAX's proprietary methodologies or systems, provided:
    1. The Client has used such methodologies strictly in accordance with this Agreement;
    2. The claim does not arise from modifications made by the Client;
    3. SIGTAX's total liability under this Section shall not exceed the total fees paid by the Client in the twelve (12) months preceding the claim.
4. Working Files and Native Formats
  1. SIGTAX retains ownership of all Working Files created in the course of providing Services.
  2. Working Files may contain SIGTAX's proprietary formatting, templates, and methodologies, and are not routinely provided to the Client. Such files are not standard delivery formats nor legally required for compliance. Internal working files and revision histories remain non-transferable.
  3. Upon reasonable request and payment of applicable fees, SIGTAX may provide Working Files to the Client, subject to the removal or protection of proprietary elements.
  4. The Client acknowledges that Working Files may require specific software to access and may not be compatible with the Client's systems.
LIABILITY AND INDEMNIFICATION
1. Limitation of Liability
  1. SIGTAX's total liability ...
  2. For one-time Services ...
  3. The limitations set forth ...
2. Excluded Damages
  1. In no event shall either Party be liable for:
    1. Loss of profits or revenue;
    2. Loss of business opportunity;
    3. Loss of data or information;
    4. Cost of substitute services;
    5. Damage to reputation or goodwill.
  2. The exclusions in Section 8.2.1 shall apply regardless ...
3. Exceptions to Limitations
  1. The limitations and exclusions set forth in Sections 8.1 and 8.2 shall not apply to:
    1. Death or personal injury caused by negligence;
    2. Fraud or willful misconduct;
    3. Gross negligence;
    4. Breach of confidentiality obligations;
    5. Intellectual property infringement;
    6. Liabilities that cannot be excluded or limited under applicable law.
4. Professional Limitations
  1. SIGTAX's liability is limited to matters within its professional competence ...
  2. SIGTAX shall not be liable for:
    1. Business and commercial decisions ...
    2. Consequences of the Client's failure ...
    3. Changes in law or regulation ...
    4. Third-party actions or omissions ...
    5. Losses arising from the Client's failure ...
5. Indemnification
  1. The Client shall indemnify SIGTAX against claims arising from:
    1. The Client's knowing violation of applicable laws ...
    2. Intentionally false or misleading information ...
    3. The Client's use of Services for unauthorized purposes.
  2. SIGTAX shall promptly notify the Client ...
  3. The Client's indemnification obligations ...
FORCE MAJEURE
1. Definition of Force Majeure
  1. Neither Party shall be liable for any failure or delay in performing its obligations under this Agreement if such failure or delay results from circumstances beyond its reasonable control, including but not limited to:
    1. Acts of God, natural disasters, epidemics, or pandemics;
    2. War, terrorism, civil unrest, or government actions;
    3. Strikes, labor disputes, or other industrial action;
    4. Failure of telecommunications, internet, or power systems;
    5. Fire, flood, earthquake, or other natural catastrophes;
    6. Changes in law or regulation that prevent performance;
    7. Failure or unavailability of essential third-party services or systems.
2. Obligations During Force Majeure
  1. The Party affected by Force Majeure shall:
    1. Promptly notify the other Party in writing of the occurrence and expected duration of the Force Majeure event;
    2. Use reasonable efforts to mitigate the effects of the Force Majeure event;
    3. Continue to perform those obligations that are not prevented by the Force Majeure event;
    4. Provide regular updates on the status of the Force Majeure event and efforts to resolve it.
  2. The affected Party shall resume performance of its obligations as soon as reasonably practicable after the Force Majeure event ceases.
3. Consequences of Force Majeure
  1. During the period of Force Majeure, the affected Party's obligations shall be suspended to the extent they are prevented by the Force Majeure event.
  2. Time periods for performance shall be automatically extended by the duration of the Force Majeure event.
  3. Neither Party shall be entitled to terminate this Agreement solely due to Force Majeure unless the Force Majeure event continues for a period exceeding three (3) consecutive months.
4. Exclusions
  1. Force Majeure shall not excuse:
    1. Payment obligations for Services already performed;
    2. Obligations to maintain confidentiality;
    3. Failures resulting from the affected Party's negligence or willful misconduct;
    4. Economic hardship or increased costs of performance alone.
DISPUTE RESOLUTION
1. Governing Law and Jurisdiction
  1. This Agreement shall be governed by and construed in accordance with the laws of Luxembourg, without regard to its conflict of laws principles.
  2. The courts of Luxembourg shall have exclusive jurisdiction over any disputes arising out of or in connection with this Agreement.
2. Alternative Dispute Resolution
  1. Before initiating formal legal proceedings, the Parties agree to attempt to resolve any dispute through good faith negotiations for a period of thirty (30) days following written notice of the dispute.
  2. If a dispute cannot be resolved through direct negotiations within the specified period, either Party may proceed with formal legal proceedings in accordance with Section 10.1.
  3. Nothing in this Section shall prevent either Party from seeking urgent interim relief from a court of competent jurisdiction where necessary to prevent irreparable harm.
GENERAL PROVISIONS
1. Entire Agreement
  1. This Agreement, together with the Service Agreement and any Addenda, constitutes the entire agreement between the Parties and supersedes all prior negotiations, representations, or agreements relating to the subject matter hereof.
  2. No oral agreements, representations, or warranties exist between the Parties other than those expressly set forth in this Agreement.
2. Amendments
  1. No amendment, modification, or waiver of any provision of this Agreement shall be effective unless in writing and signed by both Parties.
  2. Any purported amendment, modification, or waiver that does not comply with this Section shall be null and void.
3. Severability and Validity
  1. If any provision of this Agreement is held to be invalid, illegal, or unenforceable, the validity, legality, and enforceability of the remaining provisions shall not be affected or impaired.
  2. The Parties shall negotiate in good faith to replace any invalid, illegal, or unenforceable provision with a valid provision that achieves the same or similar economic effect.
4. Waiver
  1. No waiver of any breach of this Agreement shall constitute a waiver of any other breach or of any subsequent breach of the same provision.
  2. No waiver shall be effective unless in writing and signed by the Party making the waiver.
5. Assignment
  1. Neither Party may assign or transfer its rights or obligations under this Agreement without the prior written consent of the other Party, except that either Party may assign this Agreement to an affiliate or in connection with a merger, acquisition, or sale of all or substantially all of its assets.
  2. Any attempted assignment in violation of this Section shall be null and void.
  3. This Agreement shall be binding upon and inure to the benefit of the Parties and their permitted successors and assigns.
6. Notices
  1. All notices under this Agreement shall be in writing and may be delivered by:
    1. Registered mail with acknowledgment of receipt to the address specified in the Service Agreement;
    2. Email to the email addresses specified in the Service Agreement, provided that receipt is confirmed by the recipient.
  2. Notices shall be deemed given:
    1. Upon confirmed receipt if sent by email during Business Hours, or the next Business Day if sent outside Business Hours;
    2. Upon actual delivery if sent by registered mail;
    3. Seven (7) Business Days after posting by registered mail if delivery cannot be completed due to the recipient's absence, refusal to accept, or change of address not notified to the sender.
  3. For corporate clients, notices delivered to one or more Ultimate Beneficial Owners at their registered or last known address shall be deemed equivalent to delivery to the Client itself, regardless of whether delivery to the Client's specified address was possible or not.
  4. Each Party shall promptly notify the other Party of any change in its contact information or registered address.
  5. Routine operational communications regarding day-to-day Services may be conducted through normal business communication channels and need not comply with the formal notice requirements of this Section.
7. Survival of Provisions
  1. The following provisions shall survive termination of this Agreement:
    1. Confidentiality obligations (Section 6);
    2. Intellectual property rights (Section 7);
    3. Liability limitations and indemnification (Section 8);
    4. Dispute resolution (Section 10);
    5. General provisions (Section 11).
  2. All payment obligations accrued prior to termination shall survive termination.
ADDITIONAL COSTS AND EXPENSES
1. Cost Minimization Efforts
  1. SIGTAX shall use reasonable efforts to minimize additional costs and expenses incurred in the provision of Services.
  2. Where alternative approaches are available that would achieve the same result at different cost levels, SIGTAX shall, where practicable, inform the Client of such alternatives and their respective costs.
  3. SIGTAX shall seek the Client's prior approval for all additional costs and expenses before they are incurred or invoiced to the Client, unless such costs are necessary to prevent immediate harm or comply with urgent legal requirements. Such approval may be obtained via WhatsApp, email, or other agreed communication channels specified in the Service Agreement.
2. Reimbursement Procedures
  1. All reasonable costs and expenses incurred by SIGTAX in the provision of Services shall be reimbursed by the Client, including but not limited to:
    1. Government fees, taxes, and official charges;
    2. Notarial fees and related expenses;
    3. Translation and legalization costs;
    4. Travel expenses when required for Service provision;
    5. Third-party professional fees (legal, accounting, technical experts);
    6. Courier and express delivery charges;
    7. Telecommunications and communication costs directly related to the Services.
  2. SIGTAX shall provide reasonable documentation supporting all reimbursable expenses, including receipts, invoices, or official fee schedules. Where SIGTAX coordinates third-party services on behalf of the Client, SIGTAX may include a reasonable coordination fee as part of the reimbursable expense.
  3. Reimbursable expenses shall be invoiced upon completion of the relevant Services or as otherwise agreed in the Service Agreement.
  4. The Client shall reimburse documented expenses within the same payment terms applicable to professional fees under the Service Agreement.
  5. In case of advance payments required by third parties, SIGTAX may request prepayment from the Client or advance such payments subject to prompt reimbursement.
REGULATED ACTIVITIES
1. Subsidiarity of General Terms
  1. Where SIGTAX provides Services to the Client in the capacity of a regulated professional activity, including but not limited to expert-comptable services under Luxembourg law, these General Terms shall be subsidiary to the applicable professional general terms and conditions governing such regulated activity.
  2. In case of any conflict or contradiction between these General Terms and the General Terms and Conditions for the Execution of Expert-Comptable Assignments in the Grand Duchy of Luxembourg (or any other applicable professional general terms), the professional general terms shall prevail to the extent of such conflict.
  3. The provisions of these General Terms that do not conflict with applicable professional general terms shall remain in full force and effect.
  4. SIGTAX shall notify the Client in the Service Agreement when Services are being provided under regulated professional capacity and identify the applicable professional general terms that shall take precedence.
KNOW YOUR CLIENT AND ANTI-MONEY LAUNDERING COMPLIANCE
1. Legal Framework
  1. SIGTAX is subject to Luxembourg anti-money laundering legislation and regulations, including but not limited to the Law of 12 November 2004 on the fight against money laundering and terrorist financing, as amended.
  2. The Client acknowledges and agrees to comply with all KYC/AML requirements imposed by applicable legislation and SIGTAX's internal policies.
  3. SIGTAX shall maintain appropriate procedures and controls to ensure compliance with all applicable AML/CFT obligations.
2. Client KYC/AML Obligations
  1. The Client shall provide all documentation and information required by SIGTAX for KYC/AML verification prior to the commencement of Services and at any time during the term of this Agreement.
  2. The Client shall complete the KYC/AML verification process within the timeframe specified by SIGTAX.
  3. The Client shall immediately inform SIGTAX of any material changes to information previously provided for KYC/AML purposes, including but not limited to changes in beneficial ownership, corporate structure, or business activities.
  4. The Client shall ensure that all beneficial owners, directors, and other relevant persons cooperate fully with the KYC/AML process and provide all requested documentation in a timely manner.
  5. The Client warrants that all information and documentation provided for KYC/AML purposes is true, accurate, complete, and not misleading.
3. Documentation Requirements and Verification
  1. The scope and nature of KYC/AML documentation required shall be determined by SIGTAX based on applicable legislation, regulations, professional standards, and SIGTAX's risk assessment procedures.
  2. SIGTAX reserves the right to request additional documentation, clarification, or verification at any time during the business relationship.
  3. SIGTAX may engage third parties to assist with verification procedures and may verify information with external sources or databases as part of its compliance obligations.
4. Ongoing Monitoring and Reviews
  1. The Client agrees to undergo periodic KYC reviews as determined by SIGTAX based on its risk assessment and internal policies. SIGTAX may require such reviews on a quarterly, semi-annual, or annual basis depending on the Client's risk profile.
  2. SIGTAX shall conduct ongoing monitoring of the business relationship and transactions to ensure consistency with the Client's known profile and risk assessment.
  3. The Client shall promptly respond to any requests for information or clarification arising from such monitoring activities.
5. Confidentiality and Reporting Obligations
  1. SIGTAX may be required by law to report suspicious activities to relevant authorities, including the Luxembourg Financial Intelligence Unit, without prior notification to the Client.
  2. In such cases, SIGTAX and its employees are prohibited by law from disclosing to the Client or any third parties that such reporting has taken place or that an investigation may be underway.
  3. The Client acknowledges and accepts these reporting obligations and agrees not to hold SIGTAX liable for any consequences arising from such mandatory reporting.
6. Record Keeping
  1. SIGTAX shall maintain records of all KYC/AML documentation and information for the periods required by applicable legislation, which shall be no less than five (5) years following termination of the business relationship.
  2. Such records may be maintained in electronic format and shall be available for inspection by competent authorities as required by law.

📄 Download General Terms and Conditions

General Terms and Conditions dated 29.09.2025