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AMLDirectory Australia · Tranche 2

duely vs FreeAML

These are not the same kind of product

duely is an end-to-end hosted platform. FreeAML is a verification layer you plug into your own process. Comparing them on monthly cost will mislead you: they are bought to do different jobs, and the cheaper figure below does not mean the better buy. Read the capability rows, not the prices.

duely

ILIXIR TECHNOLOGIES PTY LTD · ABN 11 680 039 392

Platform

SMR export

AUSTRAC XML

Screening

Ongoing

Audit log

Append-only

From

$64.90

inc GST, per month
$59.00 as published, ex GST

Capabilities29 verified 2 absent 0 not established
  • Program
    • AML/CTF program build: Yes
    • Risk assessment: Yes
    • Program maintenance and review: Yes
    • Independent evaluation support (s84): Yes
    • Staff training: Yes
    5/5
  • Customer
    • Customer due diligence: Yes
    • Know your business (entity checks): Yes
    • Beneficial ownership and control: Yes
    • Enhanced due diligence: Yes
    • Reliance arrangements: Yes
    5/5
  • Identity
    • Electronic identity verification: Yes
    • Biometric liveness and face match: Yes
    • Document Verification Service access: Yes
    3/3
  • Screening
    • PEP and sanctions screening: Yes
    • Adverse media screening: Yes
    • Ongoing customer monitoring: Yes
    • Automated transaction monitoring (bank-style rules): No
    3/4
  • Tranche 2 operations
    • Risk assessed per designated service: Yes
    • Ongoing monitoring triggered by designated service and risk: Yes
    • Program obligations calendar (reviews, effectiveness, AMLCO reports, independent evaluation): Yes
    • Versioned AML program and CDD records: Yes
    • Escalation to AMLCO or manager with outcome recorded: Yes
    • Expired document alerts: Yes
    • Reliance CDD requests sent and received: Yes
    7/7
  • Reporting
    • Suspicious matter report workflow: Yes
    • AUSTRAC SMR XML export: Yes
    • Tipping-off controls (s123): Yes
    • Threshold transaction reporting: Yes
    4/4
  • Record
    • Evidence pack export: Yes
    • Immutable audit log: Yes
    • API access: No
    2/3
What these 31 mean

Program

AML/CTF program build
Yes
Risk assessment
Yes
Program maintenance and review
Yes
Independent evaluation support (s84)
Yes
Staff training
Yes

Customer

Customer due diligence
Yes
Know your business (entity checks)
Yes
Beneficial ownership and control
Yes
Enhanced due diligence
Yes
Reliance arrangements
Yes

Identity

Electronic identity verification
Yes
Biometric liveness and face match
Yes
Document Verification Service access
Yes

Screening

PEP and sanctions screening
Yes
Adverse media screening
Yes
Ongoing customer monitoring
Yes
Automated transaction monitoring (bank-style rules)
No

Tranche 2 operations

Risk assessed per designated service
Yes
Ongoing monitoring triggered by designated service and risk
Yes
Program obligations calendar (reviews, effectiveness, AMLCO reports, independent evaluation)
Yes
Versioned AML program and CDD records
Yes
Escalation to AMLCO or manager with outcome recorded
Yes
Expired document alerts
Yes
Reliance CDD requests sent and received
Yes

Reporting

Suspicious matter report workflow
Yes
AUSTRAC SMR XML export
Yes
Tipping-off controls (s123)
Yes
Threshold transaction reporting
Yes

Record

Evidence pack export
Yes
Immutable audit log
Yes
API access
No

Checked 8 Oct 2026

View board for duely

FreeAML

The Trustee for Vaz Capital Trust · ABN 28 247 067 155

Verification

SMR export

AUSTRAC XML

Screening

Point in time

Audit log

Not established

From

$22.00

inc GST, per check
$20.00 as published, ex GST

Capabilities14 verified 3 partial 0 absent 14 not established
  • Program
    • AML/CTF program build: Yes
    • Risk assessment: Yes
    • Program maintenance and review: Not established
    • Independent evaluation support (s84): Not established
    • Staff training: Yes
    3/5
  • Customer
    • Customer due diligence: Yes
    • Know your business (entity checks): Yes
    • Beneficial ownership and control: Yes
    • Enhanced due diligence: Not established
    • Reliance arrangements: Not established
    3/5
  • Identity
    • Electronic identity verification: Yes
    • Biometric liveness and face match: Yes
    • Document Verification Service access: Yes
    3/3
  • Screening
    • PEP and sanctions screening: Yes
    • Adverse media screening: Yes
    • Ongoing customer monitoring: Yes
    • Automated transaction monitoring (bank-style rules): Not established
    3/4
  • Tranche 2 operations
    • Risk assessed per designated service: Partial
    • Ongoing monitoring triggered by designated service and risk: Partial
    • Program obligations calendar (reviews, effectiveness, AMLCO reports, independent evaluation): Not established
    • Versioned AML program and CDD records: Partial
    • Escalation to AMLCO or manager with outcome recorded: Not established
    • Expired document alerts: Not established
    • Reliance CDD requests sent and received: Not established
    0/7
  • Reporting
    • Suspicious matter report workflow: Not established
    • AUSTRAC SMR XML export: Yes
    • Tipping-off controls (s123): Not established
    • Threshold transaction reporting: Not established
    1/4
  • Record
    • Evidence pack export: Yes
    • Immutable audit log: Not established
    • API access: Not established
    1/3
What these 31 mean

Program

AML/CTF program build
Yes
Risk assessment
Yes
Program maintenance and review
Not established
Independent evaluation support (s84)
Not established
Staff training
Yes

Customer

Customer due diligence
Yes
Know your business (entity checks)
Yes
Beneficial ownership and control
Yes
Enhanced due diligence
Not established
Reliance arrangements
Not established

Identity

Electronic identity verification
Yes
Biometric liveness and face match
Yes
Document Verification Service access
Yes

Screening

PEP and sanctions screening
Yes
Adverse media screening
Yes
Ongoing customer monitoring
Yes
Automated transaction monitoring (bank-style rules)
Not established

Tranche 2 operations

Risk assessed per designated service
Partial
Ongoing monitoring triggered by designated service and risk
Partial
Program obligations calendar (reviews, effectiveness, AMLCO reports, independent evaluation)
Not established
Versioned AML program and CDD records
Partial
Escalation to AMLCO or manager with outcome recorded
Not established
Expired document alerts
Not established
Reliance CDD requests sent and received
Not established

Reporting

Suspicious matter report workflow
Not established
AUSTRAC SMR XML export
Yes
Tipping-off controls (s123)
Not established
Threshold transaction reporting
Not established

Record

Evidence pack export
Yes
Immutable audit log
Not established
API access
Not established

Checked 8 Oct 2026

View board for FreeAML

Where they differ

CapabilityduelyFreeAML
  • Risk assessed per designated serviceYesPartial
  • Ongoing monitoring triggered by designated service and riskYesPartial
  • Versioned AML program and CDD recordsYesPartial

14 further fields are unestablished for at least one of the two and are left out of the list above. A gap in our research is not a point against a product, and presenting it as one would score these two on our work rather than on theirs.

Every field, side by side

Reading a spec strip

  • Verifiedconfirmed on the provider’s own site
  • Partialpresent but limited or conditional
  • Absentthe product does not do it
  • Not establishedwe could not confirm either way

Each bar runs one segment per capability, in the same order on every board, so two providers compare by position. A hatched segment means the field is unfilled, not that the product lacks the capability — around half of all capability fields on this site are currently unestablished, and a blank would read as “no” and misrepresent a real business. Show all opens the full list in place.

ProgramduelyFreeAML
  • AML/CTF program build YesYes
  • Risk assessment YesYes
  • Program maintenance and review — differsYesNot established
  • Independent evaluation support (s84) — differsYesNot established
  • Staff training YesYes
CustomerduelyFreeAML
  • Customer due diligence YesYes
  • Know your business (entity checks) YesYes
  • Beneficial ownership and control YesYes
  • Enhanced due diligence — differsYesNot established
  • Reliance arrangements — differsYesNot established
IdentityduelyFreeAML
  • Electronic identity verification YesYes
  • Biometric liveness and face match YesYes
  • Document Verification Service access YesYes
ScreeningduelyFreeAML
  • PEP and sanctions screening YesYes
  • Adverse media screening YesYes
  • Ongoing customer monitoring YesYes
  • Automated transaction monitoring (bank-style rules) — differsNoNot established
Tranche 2 operationsduelyFreeAML
  • Risk assessed per designated service — differsYesPartial
  • Ongoing monitoring triggered by designated service and risk — differsYesPartial
  • Program obligations calendar (reviews, effectiveness, AMLCO reports, independent evaluation) — differsYesNot established
  • Versioned AML program and CDD records — differsYesPartial
  • Escalation to AMLCO or manager with outcome recorded — differsYesNot established
  • Expired document alerts — differsYesNot established
  • Reliance CDD requests sent and received — differsYesNot established
ReportingduelyFreeAML
  • Suspicious matter report workflow — differsYesNot established
  • AUSTRAC SMR XML export YesYes
  • Tipping-off controls (s123) — differsYesNot established
  • Threshold transaction reporting — differsYesNot established
RecordduelyFreeAML
  • Evidence pack export YesYes
  • Immutable audit log — differsYesNot established
  • API access — differsNoNot established

duely: 29/31 verified.FreeAML: 14/31 verified. A higher count means more that we could confirm, not necessarily more that the product does.

Stated limitations

Each board lists what that provider's own material says it does not do. We do not set those lists side by side: some providers publish their limits and others publish none, so a longer list often means a more candid provider rather than a weaker product. Where a limitation maps to a capability both providers have established, it appears in the comparison above.

duely: stated limitations FreeAML: stated limitations

Who you would be contracting with

On the Australian Business Register

Legal entity
ILIXIR TECHNOLOGIES PTY LTD
Registered from
11 November 2024

Recorded, not scored

Other business names
DUELY

On the Australian Business Register

Legal entity
The Trustee for Vaz Capital Trust
Registered from
2 April 2026

Recorded, not scored

Other business names
FreeAML
Full board: duelyFull board: FreeAML

duely checked 8 October 2026. FreeAML checked 8 October 2026. Pricing in this market goes stale within a quarter — verify current figures with the provider before you rely on them.