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AML and RegTech: Key learnings from 2021 and in Upcoming 2022

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Tookitaki
31 Jan 2022
9 min
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Featuring insights from risk and compliance leaders at Tookitaki, ACAMS, FATF and others.

From NFTs and the Metaverse to new legislation, the finance and compliance space is rapidly changing, requiring financial institutions to be even more prepared. They will be expected to implement sophisticated compliance frameworks capable of meeting ever-changing AML compliance requirements.

Looking back on 2021, the growing reach of regulatory sanctions has had an impact on enterprises all around the world. Most firms were concerned about the use of financial institutions for money laundering and terrorism funding. In response, global regulatory bodies have emerged with more rigid Anti-Money Laundering (AML) compliance to identify and eliminate the risk of such criminal activities. This year was a watershed moment in AML compliance.

In 2021, we spoke to our customers about their previous AML strategies and experiences as well as how they intended to scale their fraud prevention in the coming years.

We asked them about what was important to them in a compliance programme. As part of these discussions, a few themes kept coming up that we’ve chosen to share the learnings from.

We’ve also used data from industry experts to make predictions about what the AML and RegTech space might look like in the next 12 months.

Looking back: Key learnings from 2021

 

1. Reforms have been key to regulators

AML reforms

2. Financial crimes have become increasingly prevalent online

While financial services are going increasingly digital, especially during the pandemic, so are financial crimes. Criminals have been adapting their strategies well to fit into the digital avenues. The use of new payment methods and crypto assets for money laundering has been increasing albeit on a smaller scale.

Illicit crypto transaction activity reached an all-time high in 2021, with illicit addresses receiving $14 billion during the year, up from $7.8 billion in 2020, according to blockchain analytics firm ChainAnalysis. While regulators brought companies dealing with cryptocurrencies under their AML rules, these companies are failing to comply with them.

The Financial Conduct Authority in the UK announced in June that an “unprecedented number” of crypto companies had withdrawn applications from a temporary permit scheme in the country. According to media reports, up to 50 companies dealing in cryptocurrencies may be forced to close after failing to meet the UK’s AML rules.

While criminals are quick to adapt to technological advancement with financial transactions such as cryptocurrencies, financial institutions and regulators need to be more proactive to counter the misuse. Regulators around the world should devote attention to developing effective crypto-related legislation and promoting the use of technology to identify crime. Meanwhile, financial institutions should look at technological opportunities to prevent money laundering with these new-age transaction methods.

3. Financial institutions have expressed a desire for more comprehensive AML risk coverage

Rules and thresholds have been less effective for financial institutions as they tried to build compliance programmes in line with increased regulatory requirements and changing customer behaviour. Financial institutions we engaged with have been voicing concerns over operational bottlenecks, rising costs of maintenance and lacklustre effectiveness of their existing solutions for customer due diligence, transaction monitoring and screening.

For example, the US is making moves to slash the suspicious transaction threshold from $3,000 to $250. That means a heavy workload for compliance professionals as any transaction above $250 will need to be investigated.

To address this, financial institutions wanted AML solutions that follow a risk-based approach and are more dynamic and comprehensive in addressing their pressing concerns. With risk factors continuously increasing, rule-based approaches may not be sustainable in the long run. Meanwhile, risk-based approaches that dynamically add context to each and every case can make their compliance programmes future-proof.

4. Regulators continue to encourage the adoption of tech in AML compliance

Regulators across the world have been unanimous in their voice that proper implementation of technology can significantly alleviate the current AML compliance pains of financial institutions. In 2021, we’ve seen more of these encouraging statements from regulators. In January 2021, the Hong Kong Monetary Authority (HKMA) published case studies that highlighted the benefits of adopting RegTech solutions for AML compliance.

Separately, the Financial Action Task Force (FATF), in its June 2021 report titled Opportunities and Challenges of New Technologies for AML/CFT, said “new technologies can improve the speed, quality and efficiency of measures to combat money laundering and terrorist financing.” It added that these technologies can enable secure payments and transactions, enhanced due diligence on high-risk entities, and ongoing transaction monitoring.

Looking ahead: Key predictions for 2022

 

1. Stricter Crypto Regulations, awareness of NFTs and the Metaverse

Both regulators and businesses have their eyes on cryptocurrency around the world.

According to research from data company Chainalysis, cryptocurrency-based crime reached a new all-time high in 2021, with roughly $14 billion in transactions – up from $7.8 billion in 2020.

According to the research, global cryptocurrency transaction volume surged by 567% to $15.8 trillion in 2021. The 567% rise in transaction volume proves that cryptocurrencies have entered the mainstream.

“As more investors seek financial rewards from this rising asset class, criminals will continue to search for opportunities to exploit, and we predict that crypto-related crime will increase in 2022.” says Abhishek Chatterjee, CEO and founder of Tookitaki.

As a result, improving virtual asset regulation has emerged as a recurring subject. Many regulatory authorities such as FinCEN, SEC, FATF, and other watchdogs have taken an interest in cryptocurrency regulation in the past year. This will continue through 2022.

According to Gou Wenjun, director of the People’s Bank of China’s (PBoC) Anti-Money Laundering (AML) unit, China’s crackdown on cryptocurrencies may extend to NFTs and the metaverse, as both currencies pose several risks, and thus regulatory authorities must maintain “consistent high-level vigilance” on the evolution of digital currencies.

Aside from that, several other governments have taken steps to regulate and mainstream cryptocurrencies, with some, such as China, preparing to create its own digital Yuan. However, by 2022, cryptocurrency exchanges will be required to do AML screening on every customer, a process that will certainly expand to every country in the world in the near future.

2. Beyond the Big Banks: Information Sharing

The Financial Action Task Force (FATF) has urged governments and businesses to collaborate in the fight against money laundering and terrorism funding. Both entities are dealing with the same difficulties, particularly when it comes to information: its reliability, volume, openness, and capacity to be handled effectively.

The FATF says that “data sharing is critical to fight money laundering and the financing of terrorism and proliferation”.

While the trend toward information sharing may take time to catch on, we have already seen the first steps, such as the FinCEN Exchange in the United States, which aims to improve public-private information sharing. However, it is expected to see more similar initiatives in 2022.

In its recent (2021) report titled Stocktake on data pooling, collaborative analytics and data protection, the international agency, which provides the FATF recommendations, notes that with technological advances, financial institutions can analyse large amounts of structured and unstructured data and identify patterns and trends more effectively. The report also lists available and emerging technologies that facilitate advanced AML/CFT analytics and allow collaborative analytics between financial institutions while respecting national and international data privacy requirements.

3. Increased use of Artificial Intelligence and Machine Learning

The importance of continuous improvement of an organisation’s financial transaction monitoring and name screening effectiveness has never been more critical in the digital age and it's predicted that more institutions will adopt AI and ML into their AML programmes.

A study by SAS, KPMG and the Association of Certified Anti-Money Laundering Specialists (ACAMS), surveyed more than 850 ACAMS members worldwide about their use of technology to detect money laundering. 57% of respondents claimed they had already implemented AI or machine learning in their anti-money laundering compliance procedures or are piloting solutions that will be implemented in the next 12-18 months.

According to the study, a third of financial institutions are accelerating their AI and ML adoption for AML purposes. When asked about their AML regulator’s position on the implementation of AI/ML, 66% of respondents said their regulator promotes and encourages these technology innovations.

“As regulators across the world increasingly judge financial institutions’ compliance efforts based on the effectiveness of the intelligence they provide to law enforcement, it’s no surprise 66 per cent of respondents believe regulators want their institutions to leverage AI and machine learning,” said Kieran Beer, chief analyst at ACAMS.

“The pressure on banks to improve their money laundering efforts while addressing Covid-19-related difficulties is expected to be the driving force for the increased usage of AI and ML. Because of the pandemic’s dramatic shift in consumer behaviour, many financial institutions have realised that static, rules-based systems are just not as accurate or flexible as systems that monitor and use criminal behaviour patterns to detect true positives,” said founder and CEO of Tookitaki, Abhishek Chatterjee.

As a result, we predict companies will move away from traditional models.

4. UBO Laws to Have More Transparency

Globally there has been an increasing focus on the need for transparency in business. Many governments have translated the call for openness into formal reporting of beneficial ownership, increasing the need for companies to assess their structure and ensure they meet varying local disclosure requirements.

A key example of this is the Anti-Money Laundering Act of 2020 (AMLA 2020) in the US. Among others, the Act requires certain types of corporate entities that are registered in the country to disclose information regarding UBO, set out by the Corporate Transparency Act (CTA).  This is a significant change in terms of transparency as to corporate ownership and will help curb the abuse of company incorporation laws to hide illicit business dealings and money laundering.

We predict banks will implement improved Customer Due Diligence (CDD) measures to reduce financial crimes as transparency increases.

Some countries have embraced these laws. However, because certain countries, such as Switzerland, do not intend to embrace UBO legislation, criminals in these countries will have easy access to shell companies next year. It is expected that money laundering and other financial crimes would skyrocket in these countries.

5. A seamless online customer onboarding experience will become key

Research carried out by Finextra with the AITE Group in 2018 found that 13 billion data records were stolen or lost in the US since 2013, which in turn is driving increased application fraud that’s set to cost banks in the US $2.7 billion in credit card and DDA loses in 2020, up from £2.2 billion in 2018. This is a global problem, with the UK fraud prevention organisation Cifas stating that during the previous several years, its members have reported around 175,000 incidents of identity theft every year.

As the cost of financial crime rises, so does the demand on banks to reduce friction when communicating with clients. This is due to the fact that, in the digital age, customer expectations are influenced by their interactions with digital behemoths such as Apple and Amazon. This increases the pressure on those in financial services to provide equally frictionless online experiences, with the importance of simplicity of use beginning with onboarding.

Therefore, it was perhaps not surprising when Finextra asked about key business case drivers for new account risk assessment tools, top of the list for fraud executives at banks, at 88%, were those that improve the customer onboarding experience, according to their research.

Therefore, client onboarding that is frictionless and doesn’t compromise on AML requirements is no longer an alternative; it is a need.

Final Thoughts

Money launderers and cybercriminals will continually devise new ways to exploit the financial industry in order to carry out illegal operations. The most challenging component, however, is discovering illicit activity in time while including a comprehensive AML framework to trace, detect, and eradicate the possible danger of money laundering, terrorism financing, and other financial crimes. Understanding criminal behaviour patterns at the root is key.

Do you want to learn more about AML compliance services for your company? Reach out to us.

 

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Blogs
19 Jun 2025
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Australia on Alert: Why Financial Crime Prevention Needs a Smarter Playbook

From traditional banks to rising fintechs, Australia's financial sector is under siege—not from market volatility, but from the surging tide of financial crime. In recent years, the country has become a hotspot for tech-enabled fraud and cross-border money laundering.

A surge in scams, evolving typologies, and increasingly sophisticated actors are pressuring institutions to confront a hard truth: the current playbook is outdated. With fraudsters exploiting digital platforms and faster payments, financial institutions must now pivot from reactive defences to real-time, intelligence-led prevention strategies.

The Australian government has stepped up through initiatives like the National Anti-Scam Centre and legislative reforms—but the real battleground lies inside financial institutions. Their ability to adapt fast, collaborate widely, and think smarter will define who stays ahead.

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The Evolving Threat Landscape

Australia’s shift to instant payments via the New Payments Platform (NPP) has revolutionised financial convenience. However, it's also reduced the window for detecting fraud to mere seconds—exposing institutions to high-velocity, low-footprint crime.

In 2024, Australians lost over AUD 2 billion to scams, according to the ACCC’s Scamwatch report:

  • Investment scams accounted for the largest losses at AUD 945 million
  • Remote access scams followed with AUD 106 million
  • Other high-loss categories included payment redirection and phishing scams

Behind many of these frauds are organised crime groups that exploit vulnerabilities in onboarding systems, mule account networks, and compliance delays. These syndicates operate internationally, often laundering funds through unsuspecting victims or digital assets.

Recent alerts from AUSTRAC and ASIC also highlighted the misuse of cryptocurrency exchanges, online gaming wallets, and e-commerce platforms in money laundering schemes. The message is clear: financial crime is mutating faster than most defences can adapt.

Australia FC

Why Traditional Defences Are Falling Short

Despite growing threats, many financial institutions still rely on legacy systems that were designed for a static risk environment. These tools:

  • Depend on manual rule updates, which can take weeks or months to deploy
  • Trigger false positives at scale, overwhelming compliance teams
  • Operate in silos, with no shared visibility across institutions

For instance, a suspicious pattern flagged at one bank may go entirely undetected at another—simply because they don’t share learnings. This fragmented model gives criminals a huge advantage, allowing them to exploit gaps in coverage and coordination.

The consequences aren’t just operational—they’re strategic. As financial criminals embrace automation, phishing kits, and AI-generated deepfakes, institutions using static tools are increasingly being outpaced.

The Cost of Inaction

The financial and reputational fallout from poor detection systems can be severe.

1. Consumer Trust Erosion

Australians are increasingly vocal about scam experiences. Victims often turn to social media or regulators after being defrauded—especially if they feel the bank was slow to react or dismissive of their case.

2. Regulatory Enforcement

AUSTRAC has made headlines with its tough stance on non-compliance. High-profile penalties against Crown Resorts, Star Entertainment, and non-bank remittance services show that even giants are not immune to scrutiny.

3. Market Reputation Risk

Investors and partners view AML and fraud management as core risk factors. A single failure can trigger media attention, customer churn, and long-term brand damage.

The bottom line? Institutions can no longer afford to treat compliance as a cost centre. It’s a driver of brand trust and operational resilience.

Rethinking AML and Fraud Prevention in Australia

As criminal innovation continues to escalate, the defence strategy must be proactive, intelligent, and collaborative. The foundations of this smarter approach include:

✅ AI-Powered Detection Systems

These systems move beyond rule-based alerts to analyse behavioural patterns in real-time. By learning from past frauds and adapting dynamically, AI models can flag suspicious activity before it becomes systemic.

For example:

  • Unusual login behaviour combined with high-value NPP transfers
  • Layered payments through multiple prepaid cards and wallets
  • Transactions just under the reporting threshold from new accounts

These patterns may look innocuous in isolation, but form high-risk signals when viewed in context.

✅ Federated Intelligence Sharing

Australia’s siloed infrastructure has long limited inter-institutional learning. A federated model enables institutions to share insights without exposing sensitive data—helping detect emerging scams faster.

Shared typologies, red flags, and network patterns allow compliance teams to benefit from collective intelligence rather than fighting crime alone.

✅ Human-in-the-Loop Collaboration

Technology is only part of the answer. AI tools must be designed to empower investigators, not replace them. When AI surfaces the right alerts, compliance professionals can:

  • Reduce time-to-investigation
  • Make informed, contextual decisions
  • Focus on complex cases with real impact

This fusion of human judgement and machine precision is key to staying agile and accurate.

A Smarter Playbook in Action: How Tookitaki Helps

At Tookitaki, we’ve built an ecosystem that reflects this smarter, modern approach.

FinCense is an AI-native platform designed for real-time detection across fraud and AML. It automates threshold tuning, uses network analytics to detect mule activity, and continuously evolves with new typologies.

The AFC Ecosystem is our collaborative network of compliance professionals and institutions who contribute real-world risk scenarios and emerging fraud patterns. These scenarios are curated, validated, and available out-of-the-box for immediate deployment in FinCense.

Some examples already relevant to Australian institutions include:

  • QR code-enabled scams using fake invoice payments
  • Micro-laundering via e-wallet top-ups and fast NPP withdrawals
  • Cross-border layering involving crypto exchanges and shell businesses

Together, FinCense and the AFC Ecosystem enable institutions to:

Building a Future-Ready Framework

The question is no longer if financial crime will strike—it’s how well prepared your institution is when it does.

To be future-ready, institutions must:

  • Break silos through collaborative platforms
  • Invest in continuous learning systems that evolve with threats
  • Equip teams with intelligent tools, not more manual work

Those who act now will not only improve operational resilience, but also lead in restoring public trust.

As the financial landscape transforms, so too must the compliance infrastructure. Tomorrow’s threats demand a shared response, built on intelligence, speed, and community-led innovation.

Strengthening AML Compliance Through Technology and Collaboration

Conclusion: Trust Is the New Currency

Australia is at a turning point. The cost of reactive, siloed compliance is too high—and criminals are already exploiting the lag.

It’s time to adopt a smarter playbook. One where technology, collaboration, and shared intelligence replace outdated controls.

At Tookitaki, we’re proud to build the Trust Layer for Financial Services—empowering banks and fintechs to:

  • Stop fraud before it escalates
  • Reduce false positives and compliance fatigue
  • Strengthen transparency and accountability

Through FinCense and the AFC Ecosystem, our mission is simple: enable smarter decisions, faster actions, and safer financial systems.

Australia on Alert: Why Financial Crime Prevention Needs a Smarter Playbook
Blogs
23 Jun 2025
5 min
read

Behind the Compliance Curtain: The Future of AML in Australia

Australia’s sunny financial reputation has come under scrutiny—and this time, the spotlight is global.

From casino scandals to multi-billion-dollar remittance breaches, the country’s anti-money laundering (AML) framework is facing a pivotal moment. What was once seen as a gold standard in regional governance is now under pressure to catch up—and compliance officers across banks, fintechs, and regulatory bodies are watching closely.

So what lies behind the curtain of AML in Australia today—and what must the financial community do next?

Talk to an Expert

The AML Landscape in Australia: Where Things Stand

Australia’s AML/CFT regime has long been led by AUSTRAC, the nation’s financial intelligence unit and regulator. Over the past few years, AUSTRAC has made headlines with major enforcement actions:

  • Westpac (2020): A $1.3 billion penalty over 23 million breaches of AML laws.
  • Crown Resorts (2022): Systemic failure to monitor high-risk transactions, especially tied to junket operators and casinos.
  • Star Entertainment Group (2022): Similar failings in AML controls and customer due diligence.

These cases revealed a troubling pattern: AML risks were known, red flags existed, but institutions lacked either the technology, urgency, or capability to respond in real time.

More worryingly, Australia’s AML legal framework—particularly its coverage of non-financial sectors like lawyers, accountants, real estate agents, and high-value dealers—remains incomplete. This gap in regulatory coverage continues to raise red flags with global watchdogs, especially the Financial Action Task Force (FATF).

The Tranche 2 Reforms: Closing the Gaps or Buying Time?

For nearly two decades, Australia has delayed implementing the so-called Tranche 2 reforms, which would bring designated non-financial businesses and professions (DNFBPs) into the AML regulatory net.

What Tranche 2 Proposes:

  • AML obligations for real estate professionals, lawyers, accountants, and company service providers.
  • Stronger beneficial ownership transparency.
  • Enhanced customer due diligence and reporting mechanisms across non-financial channels.

Yet, while successive governments have pledged action, progress has been sluggish. Industry bodies have raised concerns about cost, feasibility, and regulatory overreach. But international momentum is building, and patience is wearing thin.

In its 2023 follow-up review, FATF explicitly called out Australia’s delayed reforms. Without Tranche 2, the country faces increased scrutiny—and potential reputational damage that could affect correspondent banking relationships and investor trust.

AUS blog

The Tech Factor: How Modern AML Looks in 2025

Even where regulations exist, legacy compliance systems are struggling to keep up with today’s threats. Financial crime has evolved. So must the tools to fight it.

What’s Changed:

  • Speed: Real-time payments and digital wallets mean funds can be layered, split, and moved across jurisdictions in seconds.
  • Complexity: Fraudsters are using mules, shell companies, and social engineering to blend illicit flows with legitimate ones.
  • Volume: Transaction volumes are rising, making manual reviews and static rules increasingly unviable.

Modern AML compliance now demands real-time monitoring, behavioural analysis, and AI-driven detection engines that adapt to new patterns as they emerge. This is where advanced platforms like Tookitaki’s FinCense come in—offering scenario-driven intelligence and federated learning capabilities tailored for high-risk markets like Australia.

Case Insight: Where Detection Failed—and Where Tech Could Have Helped

Consider the AUSTRAC case against Crown Resorts. Red flags—such as large, unexplained cash deposits, transactions linked to politically exposed persons (PEPs), and high-risk jurisdictions—were not acted upon for months, sometimes years.

The problem wasn’t a lack of data. It was a failure to connect the dots in real time.

With an adaptive AML system like FinCense in place, the scenario might have looked different:

  • Suspicious transaction patterns would have triggered real-time alerts.
  • Beneficiary risk scoring could have flagged high-risk links earlier.
  • AI-based learning could have surfaced anomalous activity invisible to static rule sets.

The outcome? Faster intervention, reduced institutional risk, and regulatory confidence.

Building the Future: Tookitaki’s Role in Strengthening Australia’s AML Defences

Tookitaki’s FinCense platform is designed for the complexity of modern financial ecosystems—especially those navigating regulatory reform and reputational pressure, like Australia.

Key Features That Matter:

  • Federated Learning Engine: Enables institutions to learn from emerging typologies across the region—without sharing sensitive data.
  • Real-Time Transaction Monitoring: Uses AI to surface anomalous patterns and risk indicators at the speed of today’s financial crime.
  • Scenario-Based Approach: Combines regulatory intelligence with real-world cases to keep detection capabilities relevant and context-rich.
  • Audit-Ready Investigations: Helps compliance teams manage alerts, document findings, and demonstrate control effectiveness.

As Tranche 2 looms and regulatory expectations rise, FinCense can help banks and fintechs in Australia stay ahead of both criminal innovation and regulatory demand.

What Compliance Teams Must Do Now

✅ Prepare for Tranche 2 (Even If It’s Not Here Yet)

  • Map exposure to DNFBPs.
  • Engage with vendors and consultants to scope out necessary controls.

✅ Build for Agility and Resilience

  • Invest in dynamic risk-scoring engines and AI-powered analytics.
  • Integrate systems that can adapt, not just flag transactions.

✅ Collaborate and Learn

  • Participate in intelligence-sharing platforms like the AFC Ecosystem.
  • Use scenario libraries to anticipate typologies before they strike.

✅ Rethink ROI from an AML Lens

  • With regulators now tracking the effectiveness (not just existence) of AML systems, demonstrate real-time capability, reduced false positives, and improved investigation turnaround.
Strengthening AML Compliance Through Technology and Collaboration

Conclusion: The Curtain’s Up—What Will Australia Do Next?

Australia stands at a crossroads. Behind the curtain of its legacy AML system lies both risk and opportunity.

The risk is clear: continued global scrutiny, regulatory gaps, and potential grey listing if reforms stall.
But the opportunity is greater: to lead the region with tech-driven, intelligence-led compliance that’s faster, smarter, and more collaborative than ever.

As the regulatory environment evolves, so must the institutions within it. With the right partners, like Tookitaki, and a commitment to real-time defences, Australia can transform its AML posture from reactive to revolutionary.

Because in the fight against financial crime, detection is no longer enough. It’s time to defend.

Behind the Compliance Curtain: The Future of AML in Australia
Blogs
02 Jul 2025
4 min
read

Inside AUSTRAC: Navigating Australia’s AML/CTF Regulations in a High-Risk Era

As money laundering methods grow more sophisticated, the pressure on financial institutions to detect, report, and prevent financial crime is intensifying — and AUSTRAC is at the centre of it all.
In an era where financial ecosystems are rapidly digitising, AUSTRAC’s role in overseeing Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance has become mission-critical. For banks, fintechs, and other reporting entities, staying ahead of regulatory expectations is no longer just a compliance issue — it’s a matter of reputation, trust, and long-term viability.

In this blog, we explore:

  • AUSTRAC’s mandate and structure
  • Key AML/CTF obligations under Australian law
  • Landmark enforcement cases
  • Upcoming reforms, including Tranche 2
  • FATF scrutiny and global compliance pressures
  • How tech-forward compliance strategies are reshaping the future
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What is AUSTRAC and Why Does It Matter?

AUSTRAC — the Australian Transaction Reports and Analysis Centre — is the government body responsible for detecting and disrupting criminal abuse of Australia’s financial system.

AUSTRAC has a dual mandate:

  • Regulator: Supervises compliance with AML/CTF obligations.
  • Financial Intelligence Unit (FIU): Collects and analyses data to support law enforcement, national security, and international counterparts.

It works with over 17,000 reporting entities, ranging from traditional banks to digital wallets, remittance providers, gaming platforms, and more. As both a data collector and enforcer, AUSTRAC is uniquely positioned to uncover illicit financial activity at scale.

A Brief History of AML/CTF Regulation in Australia

Australia’s journey in strengthening its anti-money laundering and counter-terrorism financing framework began in earnest with the passage of the AML/CTF Act in 2006. This legislation introduced foundational obligations such as KYC procedures, transaction monitoring, and reporting requirements for a wide range of financial institutions and service providers.

Over time, the regime has evolved significantly. In 2014, AUSTRAC formalised the risk-based approach, requiring entities to tailor their AML programs based on their specific exposure to financial crime risks.

The period between 2018 and 2020 marked a turning point in enforcement, with AUSTRAC taking decisive action against some of Australia’s largest institutions — including Tabcorp, the Commonwealth Bank, and Westpac — for major compliance failures.

In the years that followed, Tranche 2 reforms were proposed to expand AML/CTF obligations to include professions such as lawyers, accountants, and real estate agents, which are known to be exploited for laundering illicit funds.

As of 2024, these reforms remain under active discussion, with the Australian government under growing pressure from international bodies such as the FATF to close regulatory gaps. The expected passage of Tranche 2 in 2025 would significantly broaden AUSTRAC’s regulatory reach and bring Australia closer in line with global AML standards.

AUSTRAC


Understanding Your AML/CTF Obligations

If your institution provides “designated services” under the AML/CTF Act, here’s what you’re required to do:

🔹 AML/CTF Program (Part A and Part B)

  • Part A: Institutional risk assessments, governance, reporting, and training
  • Part B: Customer identification and verification procedures (KYC)

🔹 Reporting Requirements

  • Suspicious Matter Reports (SMRs)
    Must be submitted when the activity raises suspicion, regardless of the amount.
  • Threshold Transaction Reports (TTRs)
    For cash transactions of AUD 10,000 or more.
  • International Funds Transfer Instructions (IFTIs)
    Mandatory for cross-border fund movements.

🔹 Customer Due Diligence (CDD)

  • Verify customer identity at onboarding
  • Apply Enhanced Due Diligence (EDD) for high-risk customers or transactions
  • Conduct ongoing monitoring

🔹 Record Keeping

  • Maintain transaction and identity verification records for at least 7 years.

AUSTRAC’s Enforcement Power: Learning from Past Failures

AUSTRAC is not just a passive regulator. When institutions fall short, the consequences are severe and public.

The Crown Resorts Case

In 2022, Crown Melbourne and Crown Perth were found guilty of systemic AML/CTF program failures. AUSTRAC investigations revealed:

  • Inadequate risk assessments of high-risk customers and junket operators
  • Poor transaction monitoring
  • Weak governance and oversight

Penalty: AUD 450 million settlement
Impact: Major reputational damage and licence scrutiny

The Westpac Case

Arguably, the most consequential case in Australia’s AML history. In 2020, Westpac was fined AUD 1.3 billion — the largest civil penalty in Australian corporate history — for:

  • Failing to report over 23 million IFTIs
  • Inadequate transaction monitoring
  • Enabling transactions linked to child exploitation networks

These cases underscore the high expectations placed on financial institutions — not just to comply, but to detect, investigate, and prevent abuse of their services.

Australia’s AML Pain Points and What Tranche 2 Means

Unregulated Professions: The Tranche 2 Gap

Australia’s AML/CTF regime currently does not cover “gatekeeper” professions — lawyers, accountants, real estate agents, and company service providers. This gap has drawn criticism from both the FATF and domestic watchdogs.

Tranche 2, expected to be legislated in 2025, will:

  • Extend AML obligations to these sectors
  • Close critical vulnerabilities exploited for shell companies, illicit property purchases, and tax evasion
  • Align Australia with global AML standards

For fintechs and financial institutions, this will mean greater scrutiny of third-party relationships and new customer categories.

FATF Evaluation: Australia Under the Global Lens

The Financial Action Task Force (FATF) — the global AML watchdog — is expected to conduct its next mutual evaluation of Australia soon. In its last review, Australia was flagged for:

  • Delays in enacting Tranche 2 reforms
  • Over-reliance on self-regulation in some sectors
  • Inconsistent enforcement levels

AUSTRAC and the government are now under pressure to demonstrate tangible improvements, including:

  • Broader coverage of at-risk sectors
  • Better risk-based supervision
  • More tech-led compliance outcomes

How Fintechs Can Stay Ahead

For fintechs, the AML/CTF journey can seem overwhelming, especially when scaling across regions. Here are five key steps to staying ahead:

  1. Invest Early in AML Infrastructure
    Don’t wait until licensing or audits to build compliance controls.
  2. Use Technology to Monitor in Real-Time
    Especially for high-velocity, small-value transactions common in wallets or P2P services.
  3. Customise Risk Scoring
    A high-risk customer in lending may not be the same as one in gaming or cross-border remittances.
  4. Build for Scalability
    Choose AML platforms that can grow with you, not patchwork solutions.
  5. Stay Informed on Regional Variations
    AUSTRAC’s expectations differ from MAS (Singapore) or BSP (Philippines); know your market.

Why AML Tech Is No Longer Optional

In today’s landscape, manual reviews and static rules don’t cut it. Criminals move faster — and so must compliance teams.

Key advantages of modern AML platforms:

  • Machine learning-based transaction monitoring
  • Dynamic threshold calibration to reduce false positives
  • Real-time alerting and case triage
  • Behavioural profiling and pattern recognition
  • Audit-ready investigation trails

How Tookitaki Helps You Stay Ahead

Tookitaki’s FinCense platform is purpose-built to tackle the real challenges banks and fintechs face in Australia and across APAC.

Key Modules:

🔹 Customer Onboarding Suite
Seamlessly integrates KYC, risk profiling, and watchlist screening

🔹 Transaction Monitoring
Scenario-based detection using patterns from the AFC Ecosystem

🔹 Smart Screening
Covers national ID, aliases, and local nuances — built to minimise false positives

🔹 FinMate (AI Copilot)
Assists investigators with summarised case narratives, red flags, and recommendations

Collaborative Advantage:

FinCense is powered by the AFC Ecosystem — a global community where financial institutions share typologies and red flags anonymously. This collective intelligence improves detection and reduces blind spots for all members.

For institutions facing rising risks from cross-border scams, shell company abuse, and real-time laundering, Tookitaki offers a smarter, community-driven alternative to traditional rule engines.

Strengthening AML Compliance Through Technology and Collaboration


Final Thoughts: A Smarter Future Starts Now

AUSTRAC’s expanding role and the upcoming Tranche 2 reforms signal a future where compliance will be more inclusive, tech-powered, and intelligence-driven.

For banks and fintechs, the opportunity lies not just in complying, but in leading. With the right tools, collaborative frameworks, and forward-thinking partners like Tookitaki, staying ahead of both regulation and risk is no longer an aspiration — it’s an expectation.

Inside AUSTRAC: Navigating Australia’s AML/CTF Regulations in a High-Risk Era