The Rising Cost of AML Compliance in Australia: Can Smarter Tools Reduce the Burden?
Anti-Money Laundering (AML) compliance in Australia has never been more critical — or more expensive.
As regulatory scrutiny increases and financial crime becomes more complex, financial institutions are under pressure to spend more time, money, and resources just to keep up.
But is this sustainable? And is there a smarter way to stay compliant without letting costs spiral out of control?
Let’s take a closer look at why compliance costs are rising, what’s at stake for banks and fintechs in Australia, and how modern AML solutions, powered by AI and collaboration, are helping institutions future-proof their compliance programmes.

Why Are AML Compliance Costs Rising in Australia?
Over the past few years, Australia has seen a surge in regulatory activity around financial crime. From high-profile casino investigations to AUSTRAC’s growing enforcement role, the message is clear: AML compliance is non-negotiable.
Here’s what’s driving the rising cost:
1. Tighter Regulatory Expectations
AUSTRAC expects more than just basic transaction monitoring. Institutions must demonstrate proactive risk assessments, tailored customer due diligence (CDD), and robust ongoing monitoring — all supported by detailed documentation and audit trails.
2. More Complex Financial Crime
Criminals are getting smarter. Whether it’s mule networks exploiting instant payments or layering funds across crypto and traditional channels, detecting illicit activity now requires more sophisticated tools and deeper data insights.
3. Manual Workflows and Legacy Systems
Many institutions still rely on outdated systems and siloed processes, which increase the burden on compliance teams and inflate operational costs. Manually reviewing false positives or investigating fragmented alerts takes time — and people.
4. Reputational Risk and Fines
In recent years, enforcement actions have brought AML failures into public view — from Crown and Star casinos to financial institutions under investigation. The reputational damage, legal risk, and remediation costs far outweigh the cost of modernising compliance infrastructure.

What Do Rising AML Costs Look Like on the Ground?
According to industry estimates, large Australian banks are spending hundreds of millions annually on compliance-related activities. Mid-sized banks and fintechs may not face the same scale, but they often carry a disproportionate burden due to leaner teams and tighter budgets.
Here’s where the costs add up:
- Hiring and retaining skilled AML staff
- Managing alert fatigue from legacy monitoring systems
- Frequent audits and remediation exercises
- Technology upgrades and consultant fees
- Delays in customer onboarding due to manual CDD reviews
These costs aren’t just financial — they also affect speed, agility, and customer experience.
Can Smarter Tools Reduce the Burden?
The short answer: yes — but only if they’re the right tools.
Smarter AML compliance doesn't mean more tools. It means better tools that are purpose-built for modern financial crime risks. Here's what that looks like:
What Smarter AML Compliance Looks Like
1. Behavioural Transaction Monitoring
Modern systems go beyond rule-based monitoring to detect suspicious patterns based on behaviour. This reduces false positives and increases detection accuracy — freeing up analysts to focus on what matters.
2. Federated Learning and Shared Intelligence
Collaborative platforms enable institutions to share insights and typologies without sharing sensitive data. This reduces blind spots and helps detect new risks earlier — especially in cross-border and real-time payments.
3. Automation and AI Assistants
AI-powered investigation assistants can summarise alerts, prioritise high-risk cases, and auto-generate audit trails — helping compliance teams do more with less.
4. Dynamic Risk Scoring
Instead of static scoring, smarter systems update customer risk profiles in real-time based on behaviour, location, transaction type, and other dynamic inputs.
5. Plug-and-Play Integration
Modern AML solutions should integrate easily with core banking systems, customer onboarding tools, and case management platforms — reducing overhead and ensuring a seamless compliance workflow.
How Tookitaki’s FinCense Is Helping Australian Institutions Stay Ahead
At Tookitaki, we’ve designed FinCense to deliver smarter compliance — not just cheaper, but better.
Built on a modular, federated AI framework, FinCense empowers banks, fintechs, and payment platforms to stay ahead of financial crime risks without overburdening teams or budgets.
With FinCense, institutions get:
- Up to 72% reduction in false positives
- 3.5x faster case resolutions
- Real-time, scenario-based monitoring tailored to local risks
- Federated typology sharing via the AFC Ecosystem
- Smart Disposition engine for audit-ready alert summaries
Whether you're dealing with domestic mule activity, complex layering, or regulatory audits — FinCense helps you detect, investigate, and respond with speed, accuracy, and confidence.
The Stakes Are Higher Than Ever
Financial crime is evolving rapidly, and so is the regulatory bar. But throwing more people, more tools, and more money at the problem isn’t the answer.
The future of AML compliance in Australia lies in smarter systems, collaborative intelligence, and scalable solutions that adapt as the threat landscape changes.
Final Thought
Rising AML compliance costs don’t have to mean rising pain.
With the right technology, institutions in Australia can reduce risk, improve efficiency, and build lasting trust with regulators and customers alike.
If you're ready to reduce the cost and complexity of compliance, without compromising on quality — Tookitaki is here to help.
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The CEO Wasn’t Real: Inside Singapore’s $499K Deepfake Video Scam
In March 2025, a finance director at a multinational firm in Singapore authorised a US$499,000 payment during what appeared to be a Zoom call with the company’s senior leadership. There was just one problem: none of the people on the call were real.
What seemed like a routine virtual meeting turned out to be a highly orchestrated deepfake scam, where cybercriminals used artificial intelligence to impersonate the company’s Chief Financial Officer and other top executives. The finance director, believing the request was genuine, wired nearly half a million dollars to a fraudulent account.
The incident has sent shockwaves across the financial and corporate world, underscoring the fast-evolving threat of deepfake technology.
Background of the Scam
According to Singapore police reports, the finance executive received a message from someone posing as the company’s UK-based CFO. The message requested an urgent fund transfer to facilitate a confidential acquisition. To build credibility, the fraudster set up a Zoom call — featuring multiple senior executives, all appearing and sounding authentic.
But the entire video call was fabricated using deepfake technology.
These weren’t just stolen profile photos; they were AI-generated likenesses with synced facial movements and realistic voices, mimicking actual executives. The finance director, seeing what seemed like familiar faces and hearing familiar voices, followed through with the transfer.
Only later did the company realise that the actual executives had never been on the call.
What the Case Revealed
This wasn’t just another phishing email or spoofed WhatsApp message. This was next-level digital deception. Here’s what made it chillingly effective:
- Multi-party deepfake execution – The fraud involved several synthetic identities, all rendered convincingly in real-time to simulate a legitimate boardroom environment.
- High-level impersonation – Senior figures like the CFO were cloned with accurate visual and vocal characteristics, heightening the illusion of authority and urgency.
- Deeply contextual manipulation – The scam leveraged business context (e.g. M&A activity, board-level communications) that suggested insider knowledge.
Singapore’s police reported this as one of the most convincing cases of AI-powered impersonation seen to date — and issued a national warning to corporations and finance professionals.
Impact on Financial Institutions and Corporates
While the fraud targeted one company, its implications ripple across the entire financial system:
Deepfake Fatigue and Trust Erosion
When even video calls are no longer trustworthy, confidence in digital communication takes a hit. This undermines both internal decision-making and external client relationships.
CFOs and Finance Teams in the Crosshairs
Finance and treasury teams are prime targets for scams like this. These professionals are expected to act fast, handle large sums, and follow instructions from the top — making them vulnerable to high-pressure frauds.
Breakdown of Traditional Verification
Emails, video calls, and even voice confirmations can be falsified. Without secondary verification protocols, companies remain dangerously exposed.

Lessons Learned from the Scam
The Singapore deepfake case isn’t an outlier — it’s a glimpse into the future of financial crime. Key takeaways:
- Always Verify High-Value Requests
Especially those involving new accounts or cross-border transfers. A secondary channel of verification — via phone or an encrypted app — is now a must. - Educate Senior Leadership
Executives need to be aware that their digital identities can be hijacked. Regular briefings on impersonation risks are essential. - Adopt Real-Time Behavioural Monitoring
Advanced analytics can flag abnormal transaction patterns — even when the request appears “approved” by an authority figure. - Invest in Deepfake Detection Tools
There are now software solutions that scan video content for artefacts, inconsistencies, or signs of AI manipulation. - Strengthen Internal Protocols
Critical payment workflows should always require multi-party authorisation, escalation logic, and documented rationale.
The Role of Technology in Prevention
Scams like this are designed to outsmart conventional defences. A new kind of defence is required — one that adapts in real-time and learns from emerging threats.
This is where Tookitaki’s compliance platform, FinCense, plays a vital role.
Powered by the AFC Ecosystem and Agentic AI:
- Typology-Driven Detection: FinCense continuously updates its detection logic based on real-world scam scenarios contributed by financial crime experts worldwide.
- AI-Powered Simulation: Institutions can simulate deepfake-driven fraud scenarios to test and refine their internal controls.
- Federated Learning: Risk signals and red flags from across institutions are shared securely without compromising sensitive data.
- Smart Case Disposition: Agentic AI reviews and narrates alerts, allowing compliance officers to respond faster and with greater clarity — even in complex scams like this.

Moving Forward: Facing the Synthetic Threat Landscape
Deepfake technology has moved from the realm of novelty to real-world risk. The Singapore incident is a wake-up call for companies across ASEAN and beyond.
When identity can be faked in real-time, and fraudsters learn faster than regulators, the only defence is to stay ahead — with intelligence, collaboration, and next-generation tech.
Because next time, the CEO might not be real, but the money lost will be.
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The AI Governance Crisis: How Compliance-First Thinking Undermines Both Innovation and Compliance
The financial services industry stands at a crossroads. Despite investing over $180 billion annually in financial crime compliance globally, financial institutions are failing spectacularly at their primary mission: preventing financial crime. Money launderers successfully process between $2-5 trillion annually representing up to 5% of global GDP, while authorities intercept less than 1-2% of these illicit flows. Meanwhile, traditional compliance systems generate false positive rates exceeding 90%, overwhelming investigators with irrelevant alerts while real threats slip through undetected.
This paradox reveals a fundamental crisis in how the industry approaches AI governance. Rather than enabling better crime detection, current compliance-heavy frameworks are creating bureaucratic bottlenecks that simultaneously stifle innovation and undermine security. The result is a vicious cycle where institutions spend more on compliance while becoming less effective at preventing actual crimes.
The Compliance Industrial Complex in APAC
Financial institutions across Asia-Pacific have built what amounts to a compliance industrial complex; one that checks every regulatory box, but often misses the mark on actual financial crime deterrence.
Spending is rising sharply. AML compliance costs in APAC have grown by 9–10% over the past two years, particularly in markets like Singapore, Malaysia, Indonesia, and the Philippines. Midsize to large firms in the region now spend between US $12–14 million annually, while smaller institutions are still allocating US $1–2 million each year, a substantial burden relative to their size.
Yet these escalating costs haven’t translated into better outcomes. Detection rates remain low. Analyst burnout is on the rise, but hiring lags behind, especially as firms struggle to find compliance professionals with both regulatory expertise and technical fluency. The result? A growing volume of alerts, an overstretched workforce, and mounting operational risk.
This misalignment between cost and capability has created a vicious loop: more money, more tools, more alerts - but no meaningful reduction in actual financial crime.

The Alert Avalanche in APAC
Nowhere is the dysfunction more evident than in APAC’s transaction monitoring systems. Alert volumes have surged by 800% in recent years, yet over 90% of these alerts are false positives, according to the AML Tech Barometer. This means investigators spend the bulk of their time chasing noise instead of identifying true threats.
The consequences are more than operational, they’re systemic. According to the Nasdaq Global Financial Crime Report 2024, APAC recorded the highest global fraud losses, totalling US $221.4 billion, with US $190 billion attributed to payments fraud alone.
These figures reflect a deeper issue: compliance teams are drowning in alerts that fail to distinguish genuine threats from benign anomalies. While real criminal behaviour evolves, traditional detection systems lag — overwhelmed by volume, underpowered in intelligence, and increasingly ineffective at stopping sophisticated financial crime.
Innovation Paralysis Through Regulatory Complexity
The compliance-first approach has created a regulatory environment that actively discourages innovation. Traditional vendors promote complex 12-point compliance frameworks that promise "audit readiness" through extensive documentation and multi-layered governance structures. While these frameworks appear comprehensive, they suffer from critical weaknesses that paradoxically increase both compliance risk and innovation costs.
Bureaucratic Bottlenecks
Heavy regulatory frameworks create bureaucratic bottlenecks that slow innovation. Financial institutions now spend 40% of their compliance budget on documentation and audit preparation rather than actual crime detection capabilities. This misallocation of resources means that institutions are investing heavily in appearing compliant rather than being effective.
The regulatory landscape has become a maze of conflicting requirements. Over 40 countries have initiated or enacted national AI policies, with more than a dozen introducing sector-specific financial services guidance. However, instead of harmonisation, regulatory divergence is accelerating, creating what experts call "regulatory fragmentation" that leaves multinational banks caught in crossfire between inconsistent standards.
{{cta-first}}
The Innovation-Compliance False Dichotomy
Current approaches perpetuate a false dichotomy between innovation and compliance, suggesting these goals are fundamentally incompatible. This thinking has led to what researchers call the "innovative trilemma"e perceived impossibility of simultaneously maintaining market integrity, providing clear guidance, and fostering innovation.
The European Union's AI Act exemplifies this challenge. While intended to create harmonized standards, financial services firms report that the heavy burden of documentation, mandatory transparency, and strict compliance checks can slow innovation considerably. Banks and insurers have requested reductions in real-time monitoring requirements, arguing that these can be "disproportionate and discourage innovation."
Real-World Consequences in APAC
Security Failures at Scale
- APAC lost US $221.4 billion to fraud in 2024, the highest globally even as AML compliance spending soared.
- Traditional, reactive detection systems continue to let sophisticated scams slip through.
Operational Inefficiencies
- Siloed systems and poor data quality create compliance gaps.
- Analysts spend excessive time on false positives, detracting from detecting real threats.
A Growing Talent Crisis
- Many APAC compliance teams are understaffed, despite high workloads and pressure to adopt advanced tech.
- Talent now needs both regulatory know-how and technological fluency, a rare costly combination.
The Path Forward: From Compliance to Governance
The evidence is overwhelming: compliance-first AI approaches are failing on their own terms while simultaneously stifling the innovation needed to address evolving threats. Financial institutions cannot continue down this path of escalating complexity and decreasing effectiveness.
The solution lies not in abandoning compliance but in reframing the entire approach around governance rather than checkbox mentality. Governance-first AI focuses on building systems that are inherently trustworthy, transparent, and effective - qualities that naturally satisfy regulatory requirements while enabling innovation.
This represents a fundamental shift from reactive compliance to proactive governance, from fragmented systems to integrated platforms, and from bureaucratic overhead to operational effectiveness. The institutions that embrace this transition will not only achieve superior compliance outcomes but will also gain competitive advantages through more effective crime detection and lower operational costs.
Conclusion
The AI governance crisis in financial services is not a technical problem, it is a strategic challenge that requires fundamental rethinking of how institutions balance innovation with risk management. The current compliance-first paradigm has demonstrated its limitations through massive costs, operational inefficiencies, and security failures.
The time has come to move beyond the false dichotomy of innovation versus compliance toward a governance-first approach that treats trustworthy AI as a competitive advantage rather than a regulatory burden. The institutions that make this transition first will not only achieve better compliance outcomes but will also position themselves to lead the next generation of financial crime prevention.
What’s Next in This Blog Series
In our next blog, we'll explore how initiatives like Singapore's AI-Verify program are pioneering the governance-first approach and setting new standards for responsible AI deployment in financial services.
Stay tuned.

Australia’s AML Overhaul: What AUSTRAC’s New Rules Mean for Compliance Teams
AUSTRAC’s latest draft rules signal a defining moment for AML compliance in Australia.
With growing pressure to address regulatory gaps and align with global standards, AUSTRAC has released a second exposure draft of AML/CTF rules that could reshape how financial institutions approach compliance. These proposed updates are more than routine tweaks, they are part of a strategic pivot aimed at strengthening Australia’s financial crime defences following international scrutiny and domestic lapses.
Background: Why AUSTRAC Is Updating the Rules
AUSTRAC’s policy overhaul comes at a critical time for the Australian financial sector. After years of industry feedback, regulatory incidents, and repeated warnings from the Financial Action Task Force (FATF), Australia has faced growing pressure to modernise its AML/CTF framework. This pressure intensified after the Royal Commission findings and the high-profile Crown Resorts case, which exposed systemic failures in detecting and reporting suspicious transactions.
The second exposure draft released in July 2025 reflects AUSTRAC’s intent to close key compliance loopholes and bring the current system in line with global best practices. It expands on the earlier draft by incorporating industry consultation and focuses on more granular obligations for customer due diligence, ongoing monitoring, and sanctions screening. These changes aim to strengthen Australia’s position in the face of a rapidly evolving threat landscape driven by digital finance, cross-border transactions, and sophisticated laundering techniques.
What’s Changing: Key Highlights from the Exposure Draft Rules
The second exposure draft introduces several new requirements that directly impact how reporting entities manage risk and monitor customers:
1. Clarified PEP Obligations
The draft now defines a broader set of politically exposed persons (PEPs), including foreign and domestic roles, and mandates enhanced due diligence regardless of source of funds.
2. Expanded Ongoing Monitoring
Entities must now monitor customers continuously, not just at onboarding, using both transaction and behavioural data. This shift pushes compliance teams to move from static checks to dynamic, risk-based reviews.
3. Third-Party Reliance Rules
The draft clarifies when and how financial institutions can rely on third parties for KYC processes. This includes more specific provisions for responsibility and liability in case of failure.
4. Sanctions Screening Expectations
AUSTRAC has proposed more stringent guidelines for sanctions screening, especially around name-matching and periodic list updates. There is also an increased focus on ultimate beneficial ownership.
5. Obligations for Fintechs and Digital Wallet Providers
The draft recognises the role of digital services and imposes tighter onboarding and monitoring standards for high-risk products and cross-border offerings.

Comparing ED2 with Tranche 2 Reforms
While Tranche 2 reforms remain on the horizon with a broader mandate to include lawyers, accountants, and real estate agents under the AML/CTF regime, the second exposure draft zeroes in on tightening the compliance expectations for existing reporting entities.
Unlike Tranche 2, which aims to expand the scope of regulated professions, the exposure draft rules focus on strengthening operational practices such as ongoing monitoring, customer segmentation, and enhanced due diligence for existing covered sectors. The rules also go deeper into technological expectations, such as maintaining audit trails and validating third-party service providers.
In short, ED2 is more about modernising the how of AML compliance, whereas Tranche 2 will eventually reshape the who of the regulated ecosystem.
Why It Matters for Financial Institutions
For compliance officers and risk managers, these proposed changes translate to increased scrutiny, more granular documentation, and an urgent need to improve monitoring practices. Institutions will be expected to maintain stronger evidence trails, adopt real-time monitoring tools, and improve their ability to detect behavioural anomalies across customer life cycles.
Moreover, the clear emphasis on risk-based ongoing due diligence means firms can no longer rely on periodic checks alone. Dynamic updates to risk profiles, responsive escalation triggers, and cross-channel data analysis will become critical components of future-ready compliance programs.
{{cta-first}}
Tookitaki’s Perspective and Solution Fit
At Tookitaki, we believe AUSTRAC’s second exposure draft offers an opportunity for Australian institutions to build more resilient, intelligence-driven compliance programs.
Our flagship platform, FinCense, is built to adapt to evolving AML obligations through its scenario-driven detection engine, AI-led transaction monitoring, and federated learning capabilities. Financial institutions can seamlessly adopt continuous risk monitoring, generate audit-ready investigation trails, and integrate sanctions screening workflows, all while maintaining high levels of precision.
Importantly, Tookitaki’s federated intelligence model draws from a community of AML experts to anticipate emerging threats and codify new typologies. This ensures institutions stay ahead of bad actors who are constantly evolving their methods.
What’s Next: Preparing for the New Rules
AUSTRAC is expected to finalise the rules following this round of industry consultation, with phased implementation timelines to be announced. Financial institutions should begin by assessing gaps in their existing AML controls, especially around ongoing monitoring, PEP screening, and documentation processes.
This is also a good time to evaluate technology infrastructure. Solutions that enable scalable monitoring, natural language audit logs, and flexible rule design will give institutions a distinct advantage in meeting the new compliance bar.
Conclusion
AUSTRAC’s second exposure draft marks a pivotal shift from checkbox compliance to intelligent, risk-driven AML practices. For financial institutions, the future of compliance lies in adopting flexible, technology-powered solutions that can evolve with the regulatory landscape.
The message is clear, compliance is no longer a static requirement. It is a dynamic, strategic pillar that demands agility, insight, and collaboration.

The CEO Wasn’t Real: Inside Singapore’s $499K Deepfake Video Scam
In March 2025, a finance director at a multinational firm in Singapore authorised a US$499,000 payment during what appeared to be a Zoom call with the company’s senior leadership. There was just one problem: none of the people on the call were real.
What seemed like a routine virtual meeting turned out to be a highly orchestrated deepfake scam, where cybercriminals used artificial intelligence to impersonate the company’s Chief Financial Officer and other top executives. The finance director, believing the request was genuine, wired nearly half a million dollars to a fraudulent account.
The incident has sent shockwaves across the financial and corporate world, underscoring the fast-evolving threat of deepfake technology.
Background of the Scam
According to Singapore police reports, the finance executive received a message from someone posing as the company’s UK-based CFO. The message requested an urgent fund transfer to facilitate a confidential acquisition. To build credibility, the fraudster set up a Zoom call — featuring multiple senior executives, all appearing and sounding authentic.
But the entire video call was fabricated using deepfake technology.
These weren’t just stolen profile photos; they were AI-generated likenesses with synced facial movements and realistic voices, mimicking actual executives. The finance director, seeing what seemed like familiar faces and hearing familiar voices, followed through with the transfer.
Only later did the company realise that the actual executives had never been on the call.
What the Case Revealed
This wasn’t just another phishing email or spoofed WhatsApp message. This was next-level digital deception. Here’s what made it chillingly effective:
- Multi-party deepfake execution – The fraud involved several synthetic identities, all rendered convincingly in real-time to simulate a legitimate boardroom environment.
- High-level impersonation – Senior figures like the CFO were cloned with accurate visual and vocal characteristics, heightening the illusion of authority and urgency.
- Deeply contextual manipulation – The scam leveraged business context (e.g. M&A activity, board-level communications) that suggested insider knowledge.
Singapore’s police reported this as one of the most convincing cases of AI-powered impersonation seen to date — and issued a national warning to corporations and finance professionals.
Impact on Financial Institutions and Corporates
While the fraud targeted one company, its implications ripple across the entire financial system:
Deepfake Fatigue and Trust Erosion
When even video calls are no longer trustworthy, confidence in digital communication takes a hit. This undermines both internal decision-making and external client relationships.
CFOs and Finance Teams in the Crosshairs
Finance and treasury teams are prime targets for scams like this. These professionals are expected to act fast, handle large sums, and follow instructions from the top — making them vulnerable to high-pressure frauds.
Breakdown of Traditional Verification
Emails, video calls, and even voice confirmations can be falsified. Without secondary verification protocols, companies remain dangerously exposed.

Lessons Learned from the Scam
The Singapore deepfake case isn’t an outlier — it’s a glimpse into the future of financial crime. Key takeaways:
- Always Verify High-Value Requests
Especially those involving new accounts or cross-border transfers. A secondary channel of verification — via phone or an encrypted app — is now a must. - Educate Senior Leadership
Executives need to be aware that their digital identities can be hijacked. Regular briefings on impersonation risks are essential. - Adopt Real-Time Behavioural Monitoring
Advanced analytics can flag abnormal transaction patterns — even when the request appears “approved” by an authority figure. - Invest in Deepfake Detection Tools
There are now software solutions that scan video content for artefacts, inconsistencies, or signs of AI manipulation. - Strengthen Internal Protocols
Critical payment workflows should always require multi-party authorisation, escalation logic, and documented rationale.
The Role of Technology in Prevention
Scams like this are designed to outsmart conventional defences. A new kind of defence is required — one that adapts in real-time and learns from emerging threats.
This is where Tookitaki’s compliance platform, FinCense, plays a vital role.
Powered by the AFC Ecosystem and Agentic AI:
- Typology-Driven Detection: FinCense continuously updates its detection logic based on real-world scam scenarios contributed by financial crime experts worldwide.
- AI-Powered Simulation: Institutions can simulate deepfake-driven fraud scenarios to test and refine their internal controls.
- Federated Learning: Risk signals and red flags from across institutions are shared securely without compromising sensitive data.
- Smart Case Disposition: Agentic AI reviews and narrates alerts, allowing compliance officers to respond faster and with greater clarity — even in complex scams like this.

Moving Forward: Facing the Synthetic Threat Landscape
Deepfake technology has moved from the realm of novelty to real-world risk. The Singapore incident is a wake-up call for companies across ASEAN and beyond.
When identity can be faked in real-time, and fraudsters learn faster than regulators, the only defence is to stay ahead — with intelligence, collaboration, and next-generation tech.
Because next time, the CEO might not be real, but the money lost will be.
.png)
Australia’s AML Overhaul: What AUSTRAC’s New Rules Mean for Compliance Teams
AUSTRAC’s latest draft rules signal a defining moment for AML compliance in Australia.
With growing pressure to address regulatory gaps and align with global standards, AUSTRAC has released a second exposure draft of AML/CTF rules that could reshape how financial institutions approach compliance. These proposed updates are more than routine tweaks, they are part of a strategic pivot aimed at strengthening Australia’s financial crime defences following international scrutiny and domestic lapses.
Background: Why AUSTRAC Is Updating the Rules
AUSTRAC’s policy overhaul comes at a critical time for the Australian financial sector. After years of industry feedback, regulatory incidents, and repeated warnings from the Financial Action Task Force (FATF), Australia has faced growing pressure to modernise its AML/CTF framework. This pressure intensified after the Royal Commission findings and the high-profile Crown Resorts case, which exposed systemic failures in detecting and reporting suspicious transactions.
The second exposure draft released in July 2025 reflects AUSTRAC’s intent to close key compliance loopholes and bring the current system in line with global best practices. It expands on the earlier draft by incorporating industry consultation and focuses on more granular obligations for customer due diligence, ongoing monitoring, and sanctions screening. These changes aim to strengthen Australia’s position in the face of a rapidly evolving threat landscape driven by digital finance, cross-border transactions, and sophisticated laundering techniques.
What’s Changing: Key Highlights from the Exposure Draft Rules
The second exposure draft introduces several new requirements that directly impact how reporting entities manage risk and monitor customers:
1. Clarified PEP Obligations
The draft now defines a broader set of politically exposed persons (PEPs), including foreign and domestic roles, and mandates enhanced due diligence regardless of source of funds.
2. Expanded Ongoing Monitoring
Entities must now monitor customers continuously, not just at onboarding, using both transaction and behavioural data. This shift pushes compliance teams to move from static checks to dynamic, risk-based reviews.
3. Third-Party Reliance Rules
The draft clarifies when and how financial institutions can rely on third parties for KYC processes. This includes more specific provisions for responsibility and liability in case of failure.
4. Sanctions Screening Expectations
AUSTRAC has proposed more stringent guidelines for sanctions screening, especially around name-matching and periodic list updates. There is also an increased focus on ultimate beneficial ownership.
5. Obligations for Fintechs and Digital Wallet Providers
The draft recognises the role of digital services and imposes tighter onboarding and monitoring standards for high-risk products and cross-border offerings.

Comparing ED2 with Tranche 2 Reforms
While Tranche 2 reforms remain on the horizon with a broader mandate to include lawyers, accountants, and real estate agents under the AML/CTF regime, the second exposure draft zeroes in on tightening the compliance expectations for existing reporting entities.
Unlike Tranche 2, which aims to expand the scope of regulated professions, the exposure draft rules focus on strengthening operational practices such as ongoing monitoring, customer segmentation, and enhanced due diligence for existing covered sectors. The rules also go deeper into technological expectations, such as maintaining audit trails and validating third-party service providers.
In short, ED2 is more about modernising the how of AML compliance, whereas Tranche 2 will eventually reshape the who of the regulated ecosystem.
Why It Matters for Financial Institutions
For compliance officers and risk managers, these proposed changes translate to increased scrutiny, more granular documentation, and an urgent need to improve monitoring practices. Institutions will be expected to maintain stronger evidence trails, adopt real-time monitoring tools, and improve their ability to detect behavioural anomalies across customer life cycles.
Moreover, the clear emphasis on risk-based ongoing due diligence means firms can no longer rely on periodic checks alone. Dynamic updates to risk profiles, responsive escalation triggers, and cross-channel data analysis will become critical components of future-ready compliance programs.
{{cta-first}}
Tookitaki’s Perspective and Solution Fit
At Tookitaki, we believe AUSTRAC’s second exposure draft offers an opportunity for Australian institutions to build more resilient, intelligence-driven compliance programs.
Our flagship platform, FinCense, is built to adapt to evolving AML obligations through its scenario-driven detection engine, AI-led transaction monitoring, and federated learning capabilities. Financial institutions can seamlessly adopt continuous risk monitoring, generate audit-ready investigation trails, and integrate sanctions screening workflows, all while maintaining high levels of precision.
Importantly, Tookitaki’s federated intelligence model draws from a community of AML experts to anticipate emerging threats and codify new typologies. This ensures institutions stay ahead of bad actors who are constantly evolving their methods.
What’s Next: Preparing for the New Rules
AUSTRAC is expected to finalise the rules following this round of industry consultation, with phased implementation timelines to be announced. Financial institutions should begin by assessing gaps in their existing AML controls, especially around ongoing monitoring, PEP screening, and documentation processes.
This is also a good time to evaluate technology infrastructure. Solutions that enable scalable monitoring, natural language audit logs, and flexible rule design will give institutions a distinct advantage in meeting the new compliance bar.
Conclusion
AUSTRAC’s second exposure draft marks a pivotal shift from checkbox compliance to intelligent, risk-driven AML practices. For financial institutions, the future of compliance lies in adopting flexible, technology-powered solutions that can evolve with the regulatory landscape.
The message is clear, compliance is no longer a static requirement. It is a dynamic, strategic pillar that demands agility, insight, and collaboration.

The AI Governance Crisis: How Compliance-First Thinking Undermines Both Innovation and Compliance
The financial services industry stands at a crossroads. Despite investing over $180 billion annually in financial crime compliance globally, financial institutions are failing spectacularly at their primary mission: preventing financial crime. Money launderers successfully process between $2-5 trillion annually representing up to 5% of global GDP, while authorities intercept less than 1-2% of these illicit flows. Meanwhile, traditional compliance systems generate false positive rates exceeding 90%, overwhelming investigators with irrelevant alerts while real threats slip through undetected.
This paradox reveals a fundamental crisis in how the industry approaches AI governance. Rather than enabling better crime detection, current compliance-heavy frameworks are creating bureaucratic bottlenecks that simultaneously stifle innovation and undermine security. The result is a vicious cycle where institutions spend more on compliance while becoming less effective at preventing actual crimes.
The Compliance Industrial Complex in APAC
Financial institutions across Asia-Pacific have built what amounts to a compliance industrial complex; one that checks every regulatory box, but often misses the mark on actual financial crime deterrence.
Spending is rising sharply. AML compliance costs in APAC have grown by 9–10% over the past two years, particularly in markets like Singapore, Malaysia, Indonesia, and the Philippines. Midsize to large firms in the region now spend between US $12–14 million annually, while smaller institutions are still allocating US $1–2 million each year, a substantial burden relative to their size.
Yet these escalating costs haven’t translated into better outcomes. Detection rates remain low. Analyst burnout is on the rise, but hiring lags behind, especially as firms struggle to find compliance professionals with both regulatory expertise and technical fluency. The result? A growing volume of alerts, an overstretched workforce, and mounting operational risk.
This misalignment between cost and capability has created a vicious loop: more money, more tools, more alerts - but no meaningful reduction in actual financial crime.

The Alert Avalanche in APAC
Nowhere is the dysfunction more evident than in APAC’s transaction monitoring systems. Alert volumes have surged by 800% in recent years, yet over 90% of these alerts are false positives, according to the AML Tech Barometer. This means investigators spend the bulk of their time chasing noise instead of identifying true threats.
The consequences are more than operational, they’re systemic. According to the Nasdaq Global Financial Crime Report 2024, APAC recorded the highest global fraud losses, totalling US $221.4 billion, with US $190 billion attributed to payments fraud alone.
These figures reflect a deeper issue: compliance teams are drowning in alerts that fail to distinguish genuine threats from benign anomalies. While real criminal behaviour evolves, traditional detection systems lag — overwhelmed by volume, underpowered in intelligence, and increasingly ineffective at stopping sophisticated financial crime.
Innovation Paralysis Through Regulatory Complexity
The compliance-first approach has created a regulatory environment that actively discourages innovation. Traditional vendors promote complex 12-point compliance frameworks that promise "audit readiness" through extensive documentation and multi-layered governance structures. While these frameworks appear comprehensive, they suffer from critical weaknesses that paradoxically increase both compliance risk and innovation costs.
Bureaucratic Bottlenecks
Heavy regulatory frameworks create bureaucratic bottlenecks that slow innovation. Financial institutions now spend 40% of their compliance budget on documentation and audit preparation rather than actual crime detection capabilities. This misallocation of resources means that institutions are investing heavily in appearing compliant rather than being effective.
The regulatory landscape has become a maze of conflicting requirements. Over 40 countries have initiated or enacted national AI policies, with more than a dozen introducing sector-specific financial services guidance. However, instead of harmonisation, regulatory divergence is accelerating, creating what experts call "regulatory fragmentation" that leaves multinational banks caught in crossfire between inconsistent standards.
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The Innovation-Compliance False Dichotomy
Current approaches perpetuate a false dichotomy between innovation and compliance, suggesting these goals are fundamentally incompatible. This thinking has led to what researchers call the "innovative trilemma"e perceived impossibility of simultaneously maintaining market integrity, providing clear guidance, and fostering innovation.
The European Union's AI Act exemplifies this challenge. While intended to create harmonized standards, financial services firms report that the heavy burden of documentation, mandatory transparency, and strict compliance checks can slow innovation considerably. Banks and insurers have requested reductions in real-time monitoring requirements, arguing that these can be "disproportionate and discourage innovation."
Real-World Consequences in APAC
Security Failures at Scale
- APAC lost US $221.4 billion to fraud in 2024, the highest globally even as AML compliance spending soared.
- Traditional, reactive detection systems continue to let sophisticated scams slip through.
Operational Inefficiencies
- Siloed systems and poor data quality create compliance gaps.
- Analysts spend excessive time on false positives, detracting from detecting real threats.
A Growing Talent Crisis
- Many APAC compliance teams are understaffed, despite high workloads and pressure to adopt advanced tech.
- Talent now needs both regulatory know-how and technological fluency, a rare costly combination.
The Path Forward: From Compliance to Governance
The evidence is overwhelming: compliance-first AI approaches are failing on their own terms while simultaneously stifling the innovation needed to address evolving threats. Financial institutions cannot continue down this path of escalating complexity and decreasing effectiveness.
The solution lies not in abandoning compliance but in reframing the entire approach around governance rather than checkbox mentality. Governance-first AI focuses on building systems that are inherently trustworthy, transparent, and effective - qualities that naturally satisfy regulatory requirements while enabling innovation.
This represents a fundamental shift from reactive compliance to proactive governance, from fragmented systems to integrated platforms, and from bureaucratic overhead to operational effectiveness. The institutions that embrace this transition will not only achieve superior compliance outcomes but will also gain competitive advantages through more effective crime detection and lower operational costs.
Conclusion
The AI governance crisis in financial services is not a technical problem, it is a strategic challenge that requires fundamental rethinking of how institutions balance innovation with risk management. The current compliance-first paradigm has demonstrated its limitations through massive costs, operational inefficiencies, and security failures.
The time has come to move beyond the false dichotomy of innovation versus compliance toward a governance-first approach that treats trustworthy AI as a competitive advantage rather than a regulatory burden. The institutions that make this transition first will not only achieve better compliance outcomes but will also position themselves to lead the next generation of financial crime prevention.
What’s Next in This Blog Series
In our next blog, we'll explore how initiatives like Singapore's AI-Verify program are pioneering the governance-first approach and setting new standards for responsible AI deployment in financial services.
Stay tuned.
