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Worked example · Accounting firm

An individual customer, from first contact to AMLCO approval

An accounting firm takes on an individual customer for a designated service under the AML/CTF Act. The work rates High risk, so it goes through enhanced due diligence (ECDD) before approval.

Customer
Amelia Hartwell (sample)
Type
Individual
Rating
High, so ECDD
Approver
The AMLCO

Sample data. This is an illustrative example, not a real customer, and the screens contain no real customer information.

  1. Stage 1 Onboard the customer
  2. Stage 2 Open the engagement
  3. Stage 3 Assess risk
  4. Stage 4 Approve and conclude
Stage 1

Onboard the customer

Add the customer

The firm adds the client as a customer. An individual is emailed the consent form as soon as they are added. The customer is set up once and stays in the customer list for later work.

Consent goes out as soon as the customer is added.

The duely new customer form filled in for a sample individual. A panel on the right explains that consent is emailed when the customer is added.

Consent, then the verification link

The customer gets the consent form by email. If they haven't signed by the next step, the verification link opens on the consent form, so they sign first and then verify from their own phone with an ID document and a selfie.

One link covers consent, ID and selfie.

The consent tab in duely for a sample customer, showing the consent sent and awaiting a reply.

Verify, screen and sign off

The result comes back to the firm. The customer is screened against sanctions, politically exposed person (PEP) and adverse media lists. Once every check has an outcome, the reviewer signs off, which records the customer's risk rating and the next review date.

Sign-off sets the risk profile every later engagement starts from.

The identity and screening step in duely for a sample customer, with identity verified, screening clear and a sign-off button.
Stage 2

Open the engagement

Open the engagement

The firm opens the engagement, picks the customer and their role, and chooses the services. The customer's existing due diligence is attached automatically, and duely records whether the work is in scope for AML/CTF.

Existing due diligence is attached for you.

The duely review screen for a new engagement, showing the customer with their due diligence attached automatically and the designated services chosen.
Stage 3

Assess risk

Answer the AUSTRAC risk questions

The firm creates the risk assessment and answers the questions from the AUSTRAC starter kit, including whether the work involves physical cash or virtual assets.

The questions come from AUSTRAC's starter kit.

The duely risk assessment questionnaire, with yes and no answers to questions about high value transactions, physical cash and virtual assets.

duely rates the risk

duely works out the engagement's rating from the customer's baseline, the service, the customer type and the countries involved, and shows what drove it. A High rating means enhanced due diligence is required.

The rating shows what drove it.

The risk tab in duely for a sample engagement, showing a High rating, the factors behind it and that enhanced due diligence is required.
If the rating is High

Run enhanced due diligence

A High rating opens an enhanced due diligence case, and so can a confirmed sanctions hit. The checklist covers source of funds and source of wealth documents, open-source checks and approver sign-off, each with its own upload. A Medium or Low rating skips this step.

High risk gets extra scrutiny, and a record of it.

The enhanced due diligence case in duely, with a checklist including source of funds and source of wealth documents.
Stage 4

Approve and conclude

Request approval, then conclude

The firm requests approval and an approver (here the AMLCO) signs off. Once approved, the engagement is live. When the work is finished, the engagement is concluded.

An approver signs off before the work goes ahead.

An approved engagement in duely, showing the approval, the risk and ECDD status and the button to conclude the engagement.

Generate the evidence pack

From an approved engagement, the firm generates the evidence pack: a versioned PDF with a SHA-256 hash, so any later change to the file is detectable. It is generated on demand, and the retention date is set when the engagement is concluded.

A hashed, versioned record you can hand to an auditor.

The evidence tab in duely for an approved engagement, showing a generated pack with its version and SHA-256 hash.

Available at any point

You can do these at any stage.

  • Request documents

    Ask a customer for a document through the portal. They upload it and it lands on their record.

  • Record a threshold transaction report

    When physical cash of $10,000 or more is involved, capture a draft threshold transaction report (TTR) against the engagement.

  • Report unusual activity

    Any staff member can raise a concern. It goes to the AMLCO, who decides whether to file a suspicious matter report (SMR).

What the firm holds at the end

The firm holds a verified, screened customer with consent on file, an engagement with a recorded risk rating and ECDD, the AMLCO's approval, and a hashed evidence pack.

The full step-by-step model is on How it works.

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