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Regulatory Disclaimer (Verification Note)

Last Updated: 19 August 2026 | Version 2.1

This disclaimer governs the use of the structured compliance workflows provided within the Duely platform. This Regulatory Disclaimer forms part of, and is to be read together with, the Master Subscription Agreement (MSA). In the event of conflict with the MSA, clause 2 of the MSA prevails.

1. Non-Advisory Role

Duely is a technology platform that helps Reporting Entities document and operate their Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) processes.

  • Duely does not provide legal, accounting, or compliance advice.
  • The Platform provides structured workflows, document collection tools, and screening integrations to assist Reporting Entities in meeting their record-keeping and verification obligations under the AML/CTF Act 2006 (Cth).
  • Final compliance responsibility rests with the Reporting Entity (the Firm) and its appointed AML Compliance Officer (AMLCO).

2. Customer Identification and Verification

From 1 July 2026 the reformed AML/CTF Rules require reporting entities to identify and verify their customers on a risk basis, using reliable and independent data or documents appropriate to the customer's money-laundering and terrorism-financing risk.

  • Duely provides workflows designed to support these requirements (for example, identity document capture and analysis with a biometric liveness and face-match check, and sanctions, PEP and adverse-media screening). Duely does not currently use the Document Verification Service (DVS).
  • Completing a verification workflow in Duely does not of itself establish that verification is sufficient for a particular customer, and the outputs of a workflow are Duely's opinion based on the checks performed, not a guarantee of identity.
  • The Firm's AMLCO must decide, for each customer, whether the verification carried out meets the Firm's obligations under the AML/CTF Act, the AML/CTF Rules and the Firm's AML/CTF program, including determining the appropriate risk rating.

3. Independent Reviews (Part 8.6 Audits)

Under Part 8.6 of the AML/CTF Rules, Reporting Entities must subject their AML/CTF program to regular independent review.

  • Duely supports these Part 8.6 independent reviews by providing data export tooling (Evidence Packs) and, where made available in the Platform, read-only "Auditor" access roles.
  • Duely is a tool. The independent review process itself, including the auditor's assessment of the Firm's underlying policies, risk methodologies, and adherence to the Act, remains the responsibility of the Firm and its chosen independent reviewer.

4. No Guarantee of Outcomes

Use of Duely does not guarantee a "Pass" from an AUSTRAC assessment, and does not confer immunity from regulatory action, fines, or penalties under the AML/CTF Act. The Firm must ensure that the data it enters into Duely accurately reflects the reality of its customer relationships.

5. Governing Law

This Regulatory Disclaimer is governed by the laws of New South Wales, Australia.