Unusual Activity Reports —
the safe upstream of an SMR
Your staff see things you don't. UARs let them flag suspicion safely — without mentioning the matter to the customer, without risking a s123 tipping-off offence, and without exposing them to whatever the AMLCO decides next. The AMLCO triages each UAR: dismiss, monitor, or escalate to a full SMR.
Why this matters
Section 123 of the AML/CTF Act creates real fear for compliance officers: if a member of staff tells anyone — including the customer — that a matter is being investigated, the firm has committed an offence. But the same staff are often the ones who notice the unusual behaviour in the first place. They need a way to escalate that doesn't leak.
duely's UAR system gives staff a safe escalation path. The submission goes straight to the AMLCO Console. The submitter sees their own input back, but never sees the AMLCO's decision. If the AMLCO escalates to an SMR, the linkage is invisible to the submitter — preserving the s123 firewall through the entire chain.
What is included now
Staff submission with redacted feedback
Staff submit a UAR through a simple form. The platform shows them their own input but redacts everything that happens after triage — they never see whether the AMLCO escalated, dismissed, or chose to monitor.
AMLCO Console review queue
UARs land in the AMLCO Console — the dedicated AMLCO workspace alongside the SMR cases list, SMR detail view, and AMLCO-targeted deadline view. The triage queue is isolated from the matter views the rest of the firm sees, so AMLCOs work it without exposing it to anyone outside the role.
Three triage outcomes
Each UAR is dispatched as Dismiss, Continue monitoring, or Escalate to SMR. Each outcome is recorded with rationale and timestamp for the audit trail.
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 submission and outcome do not appear on dashboards, lists, calendar feeds, exports, or notifications visible to non-AMLCO users. The s123 protection isn't policy — it's enforced at every read path.
AML/CTF Act s123 — tipping-off offence
- Section 123 prohibits disclosing that a matter is, or may be, the subject of an SMR
- 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 escalation path — UAR is that path
Related features
See how this capability connects to the broader compliance workflow.
SMR Firewall
UAR plugs into the seven-layer tipping-off firewall as the safe upstream of every SMR.
Learn more →Matter Workflow
UARs reference the matter that triggered concern — without exposing the SMR linkage to non-AMLCO users.
Learn more →Audit Trail
UAR events feed the immutable audit stream, but stay filtered out of non-AMLCO reads.
Learn more →Give your staff a safe way to escalate
Architectural protection against s123 — built-in, not bolted on.