Prove your program keeps working
after it has been approved
The reformed AML/CTF regime expects you to keep your program effective and to show your working. duely runs effectiveness checks (quarterly by default) across your reporting, customer due diligence and enhanced due diligence, tracks corrective actions to closure, schedules the independent evaluation, and keeps a register of every change.
Quarterly effectiveness check
Illustrative
- Suspicious matters How they were handled No findings
- Customer due diligence Corrective action assigned 1 finding
- Enhanced due diligence How it was handled No findings
- Transaction reporting How it was handled No findings
- Corrective action Re-tested at the next check Open
Why this matters
Writing an AML/CTF program is the easy part. The reformed regime expects reporting entities to maintain the program, test that it works, and have evidence of that testing when AUSTRAC asks. Most firms have no structured way to do this, so "effectiveness" becomes a once-a-year scramble, or nothing at all.
duely makes effectiveness a regular routine. Each quarter it prompts a structured review of how your firm handled its core obligations (suspicious matters, customer due diligence, enhanced due diligence and transaction reporting). It records the findings, opens corrective actions and re-tests them. The independent evaluation and ongoing maintenance of the program are scheduled and tracked instead of left to memory.
What's included
Quarterly effectiveness checks
A structured review, quarterly by default, of how the firm handled suspicious matters, customer due diligence (CDD), enhanced due diligence (ECDD) and transaction reporting. Each area is assessed and findings are recorded against it.
Corrective actions with a re-test loop
When a check finds a gap, a corrective action is opened, assigned and tracked to closure, then re-tested at the next check, so you can show the fix worked.
Independent evaluation tracking
The program's independent evaluation (expected at least every three years) is scheduled and tracked, so its due date is always visible instead of discovered late.
Program maintenance register
Every required change to the program is logged in a maintenance register with a turnaround target, so amendments are actioned and recorded rather than forgotten.
Findings feed the evidence pack
Effectiveness findings, corrective actions, and their outcomes are captured as part of the compliance record, so when a regulator or reviewer asks how you know your program works, the answer is already assembled.
Tied to the compliance calendar
Effectiveness quarters, the independent-review horizon, and maintenance turnaround targets all surface as dated obligations in the compliance calendar, with reminders ahead of each.
What each quarterly check covers
Each quarterly check reviews the obligations that best show whether the program is working in practice.
Maintaining and testing the program
- The reformed AML/CTF regime requires the program to be maintained and kept effective, not merely adopted
- Independent evaluation of the program: at least every 3 years
- Evidence of ongoing review and correction supports the firm's position under regulator scrutiny
- Effectiveness testing is how a firm shows the program works in practice
Related features
Other parts of the compliance workflow this connects to.
AML/CTF Program
The versioned program is the thing effectiveness testing keeps under review.
See details →Compliance Calendar
Effectiveness quarters and the independent-review horizon surface as dated obligations.
See details →Audit Trail
Reviews, findings, and corrective actions are captured in the immutable record.
See details →Show that your program keeps working
Quarterly effectiveness checks, a corrective-action loop, and a maintenance register, built in.