This disclaimer governs the use of the structured compliance workflows provided within the Duely platform. This Regulatory Disclaimer is an information document. It does not form part of the Master Subscription Agreement (MSA) (MSA clause 8.6), and it should be read with the MSA, whose clauses 2 and 2A set out Duely's role and liability.

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, criminal watchlist and adverse-media screening). Duely can check an Australian identity document's details with the issuing agency through the Australian Government Document Verification Service (DVS), where the Firm has it switched on. The Platform shows Duely's identity opinion, not the agency's answer. Foreign documents are captured and checked for tampering, but not against an issuing-country database.
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 Evaluations

Under section 26F(4)(f) of the AML/CTF Act and section 5-10 of the AML/CTF Rules 2025, a reporting entity's AML/CTF program must be independently evaluated at least once every three years.

Duely supports these independent evaluations by providing Evidence Packs.
Duely is a tool. The independent evaluation 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 evaluator.

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 Queensland, Australia.

6. Version History

2.3 (19 October 2026): sections 2 and 3 updated; this disclaimer is an information document and no longer part of the MSA (MSA clause 8.6); governed by Queensland law instead of New South Wales law.
2.2 (15 October 2026): the previous version.