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What Duely Is

Duely is an AML/CTF compliance system of record for Australian firms brought into the regime by Tranche 2. It replaces the AUSTRAC starter kit as the place where compliance work happens.

The starter kit is a set of document templates. It states the rules and supplies forms to complete. It cannot tell you which clients need a check, whether a check was finished, or what evidence you hold if AUSTRAC asks. That work ends up in spreadsheets, shared drives, and inboxes.

Duely is where that work lives instead.

Who it is for

Tranche 2 brings five groups of professional services firms into the AML/CTF regime on 1 July 2026. Duely ships tailored program and risk content for each:

  • Accounting firms, including tax agents, BAS agents, and auditors
  • Real estate agencies brokering sales, purchases and transfers of real estate
  • Legal practices providing designated services
  • Conveyancers conducting property settlement
  • Jewellers and other dealers in precious metals and stones

Obligations attach to the service you provide. The designated services are set out in s 6 of the AML/CTF Act across six tables. An obligation only arises when your firm provides one, and the matter scoping step answers that engagement by engagement.

What it produces

The output is an audit-ready evidence pack: a versioned snapshot of the decisions and records behind a matter, with the rationale and approver attached to each decision. Each version renders to a PDF. Duely computes the PDF's SHA-256 hash after rendering and stores it with the pack record, so you can confirm the file has not changed since it was produced. If someone asks how you reached a conclusion about a client, the pack answers it, so nobody has to reconstruct the story months later.

A firm running Duely also holds its own AML/CTF program as a versioned document, a customer register with due diligence attached, risk assessments, and reporting records.

Where the boundary sits

Duely is a system of record and a structured compliance workflow. It stops at three boundaries:

  • It is not a reporting rail. Duely prepares the report record; the firm lodges with AUSTRAC.
  • It does not watch a feed of payment transactions. Its monitoring is ongoing customer monitoring, at the customer level.
  • It does not make the suspicion judgment. A person, normally your AML/CTF Compliance Officer, decides whether a suspicious matter report is required. Duely holds the record and controls who may see it.

A note on the regime

Duely is built to AUSTRAC's published guidance and the AML/CTF Act 2006 as amended, including the AML/CTF Rules 2025. It is software, so it does not certify your compliance. Nothing on the market can.

It makes the work visible, ordered, and evidenced, so that when you are asked to demonstrate your program there is something concrete to produce.

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