Unusual activity reports
the safe step before an SMR
Your staff see things you don't. An unusual activity report (UAR) lets them flag a concern without raising it with the customer, without risking an s123 tipping-off offence, and without seeing what the AML/CTF compliance officer (AMLCO) decides next. The AMLCO triages each UAR: dismiss, monitor, or escalate to a full suspicious matter report (SMR).
One report, two views
Illustrative
- The report The submitter sees: Submitted The AMLCO sees: In the review queue
- Triage outcome The submitter sees: Nothing shown The AMLCO sees: Escalate to SMR
- Rationale and time The submitter sees: Nothing shown The AMLCO sees: Recorded
- Linked SMR case The submitter sees: Nothing shown The AMLCO sees: Opened
Why this matters
Section 123 of the AML/CTF Act worries compliance officers for good reason: if a member of staff tells anyone (including the customer) that a matter is being investigated, the firm has committed an offence. Yet the same staff are often the first to notice unusual behaviour. They need a way to escalate that doesn't leak.
In duely, a UAR goes straight to the AMLCO Console. The submitter sees their own input but never the AMLCO's decision. If the AMLCO escalates to an SMR, the submitter cannot see the link, so the s123 protection holds from start to finish.
What's included
Staff submission with redacted feedback
Staff submit a UAR through a simple form. duely shows them their own input but hides everything that happens after triage. They never see whether the AMLCO escalated, dismissed, or chose to monitor.
AMLCO Console review queue
UARs arrive in the AMLCO Console, the AMLCO's own workspace, alongside the SMR case list, SMR detail view and deadline view. The triage queue is kept apart from the engagement screens the rest of the firm uses, so no one outside the role sees it.
Three triage outcomes
The AMLCO closes each UAR as Dismiss, Continue monitoring or Escalate to SMR. The outcome is recorded in the audit trail with a rationale and timestamp.
SMR shadow case linkage
When a UAR is escalated, the platform creates a linked SMR shadow case in the isolated SMR system. The link is visible to AMLCOs only. The submitter never sees that their flag became an SMR.
Reopen on new information
A previously dismissed UAR can be reopened if new information surfaces. The full triage history is preserved, including the original dismissal rationale and the reopening reason.
No indicators on shared surfaces
UAR submissions and outcomes do not appear on the dashboards, lists, calendar feeds, exports or notifications that non-AMLCO users see. The s123 protection is enforced on every read path instead of being left to policy.
AML/CTF Act s123: tipping-off offence
- Section 123 prohibits disclosing SMR information where the disclosure would or could reasonably be expected to prejudice an investigation, whether or not one has started
- The offence applies to anyone with knowledge of the SMR, not just the original submitter
- Penalty is criminal, with imprisonment available
- Prevention requires architectural separation, not policy alone
- Staff still need a safe way to escalate, and the UAR provides it
Related features
Other parts of the compliance workflow this connects to.
SMR Firewall
The UAR is the safe first step into the layered tipping-off firewall, ahead of any SMR.
See details →Customer and Engagement Workflow
Each UAR references the engagement that raised the concern, without showing the SMR link to non-AMLCO users.
See details →Audit Trail
UAR events are written to the immutable audit log but filtered out of non-AMLCO reads.
See details →Give your staff a safe way to escalate
Protection against s123 tipping off, built into the architecture.