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Governance

Generate and maintain
your AML/CTF program

duely builds your AML/CTF program from guided inputs, then keeps its versions, approvals, exports and the appointment of your AML/CTF compliance officer (AMLCO) in one place. That is easier to maintain than a set of scattered templates.

AML/CTF program

Illustrative

  • Version 4 Changes in progress Draft
  • Version 3 Current authorised version Approved
  • Version 2 Kept in the history Superseded
  • AMLCO appointment Recorded in the program On record
  • PDF export With a SHA-256 hash Ready
One authorised version at a time, with every earlier version and approval kept.

Why this matters

Many firms will enter Tranche 2 with policy documents in different folders, unclear approval history, and weak ownership of the current version. That creates governance risk before the first live engagement even starts.

The duely program workflow covers governance, business profile, risk, verification approach, screening and reporting settings, people, and review scheduling in one structured flow.

What's included

01

Guided AML/CTF program wizard

Step-by-step wizard covering governance, risk, verification approach, screening, reporting, and review scheduling.

02

Draft, approved, and superseded versions

Every version is kept with a change log, and the current authorised version is clearly marked.

03

AMLCO appointment record

Formal record of AMLCO appointment, responsibilities, and delegation authorities within the program.

04

Personnel due diligence (PDD) ledger

A PDD record for each staff member, with checklist completion and the rationale for any override. Suspension during leave and reactivation are handled in the same ledger, so each person's PDD status stays accurate as they move in and out of AML-relevant roles.

05

Training register and comprehension quizzes

Training modules supplied by duely, plus your firm's own curriculum. Staff must pass the comprehension quiz at 100% before completion is logged, and each person attests to it. Includes a training-compliance dashboard, a firm-wide training matrix, and CSV and PDF exports for evidence.

06

Approver PDD currency gate

If an approver's own personnel due diligence is not current, duely refuses their approval of an engagement. Only staff whose PDD is current can approve.

07

Compliance health score dashboard

A score from 0 to 100 with a letter grade, calculated across several areas, including training currency, customer due diligence (CDD) coverage, overdue obligations and evidence completeness. It gives leadership a current view of where the firm stands.

08

PDF export with integrity hashing

Export your program as a PDF with SHA-256 hashing for integrity verification.

09

Centralised program history

Every program version, approval and change in one place, instead of in scattered templates.

10

Auto-draft on AMLCO change

When your firm appoints a new AMLCO, duely creates a new program draft with the appointee in the personnel section. The evidence trail continues without manual rework.

11

Independent evaluation reminder and due date

A calendar event and due date for the independent evaluation, required at least every 3 years.

12

Guided onboarding checklist

Step-by-step checklist that takes a new firm from sign-up through firm profile, designated services, AMLCO appointment, member invitations, program build, and training rollout. Completion is tracked so nothing is left half-done before the firm goes live.

13

In-app Help Centre and AML/CTF glossary

Reference material your staff can read without leaving duely. Articles cover the main workflows (program, customers, CDD, evidence packs, reporting) and a glossary defines every AML/CTF term that appears in the product.

Regulatory basis

AML/CTF program requirements

  • An AML/CTF program is an ML/TF risk assessment plus the AML/CTF policies that act on it (the pre-reform Part A / Part B split is repealed)
  • Independent evaluation required at least once every 3 years (s26F(4)(f))
  • AMLCO appointment and responsibilities must be documented
  • Program must be updated when risks or circumstances change

Build the program first, then run live engagements on it

Generate your AML/CTF program with guided inputs and version-controlled approvals.