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Regulatory Disclaimer (Safe Harbour Note)

Last Updated: 19 May 2026 | Version 2.0

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. The Safe Harbour Provision

The AML/CTF Rules provide certain "safe harbour" procedures for verifying the identity of individual customers (for example, verifying a customer's name and residential address against specific independent data sources).

  • duely provides workflows designed to align with these requirements (such as verifying a customer's identity against reliable and independent electronic data sources alongside a biometric liveness and face-match check). duely does not use the Document Verification Service (DVS).
  • Using a "safe harbour" verification path within duely does not automatically confer safe harbour protection on the Firm.
  • The Firm's AMLCO must independently ensure that all qualitative conditions for safe harbour under the prevailing AML/CTF Rules are met for each specific customer, 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.