Prove your program keeps working
not just that it was written
The reformed AML/CTF regime doesn't only ask you to have a program. It asks you to keep it effective and to show your working. duely runs quarterly effectiveness checks 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. A program isn't finished when it's approved.
Why this matters
Writing an AML/CTF program is the easy part. The reformed regime expects reporting entities to maintain the program and test that it actually works, and to 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 turns effectiveness into a standing rhythm. 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), records findings, opens corrective actions, and re-tests them. The independent evaluation and the ongoing maintenance of the program are scheduled and tracked, not left to memory.
What is included now
Quarterly effectiveness checks
A structured quarterly review across how the firm handled suspicious matters, customer due diligence (CDD), enhanced due diligence (ECDD), and transaction reporting. Each domain is assessed and findings are recorded against it.
Corrective actions with a re-test loop
Where a check surfaces a gap, a corrective action is opened, assigned, and tracked to closure, then re-tested at the next check, so a fixed issue is demonstrably fixed, not just noted once.
Independent evaluation tracking
The program's independent evaluation (expected at least every three years) is scheduled and tracked, so the review horizon is always visible rather than 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
Every quarter, duely prompts a structured review across the obligations most likely to reveal 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 a capability few Tranche 2 tools address directly
Related features
See how this capability connects to the broader compliance workflow.
AML/CTF Program
The versioned program is the thing effectiveness testing keeps under review.
Learn more →Compliance Calendar
Effectiveness quarters and the independent-review horizon surface as dated obligations.
Learn more →Audit Trail
Reviews, findings, and corrective actions are captured in the immutable record.
Learn more →Show that your program keeps working
Quarterly effectiveness checks, a corrective-action loop, and a maintenance register, built in.