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Crypto Exchanges Facing Enforcement Action and How to Stay Compliant

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Tookitaki
03 August 2022
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6 min

Some of the biggest cryptocurrency exchanges in the world are under federal investigation for allegedly breaking American sanctions by enabling users to buy and sell digital tokens in Iran and other countries.

Kraken, a San Francisco-based cryptocurrency exchange, has reportedly been subject to a Treasury Department investigation since 2019.

Federal authorities are reportedly looking into cryptocurrency exchange Kraken for allegedly enabling users in Iran to trade digital assets defying US sanctions.

According to the New York Times (NYT), which cited five sources familiar with the situation, the exchange has been the subject of an investigation by the Office of Foreign Assets Control (OFAC) of the Treasury Department since 2019 and may be fined. Kraken would be the largest US. Crypto firm to face enforcement action from OFAC. Regulatory measures have already been taken against Kraken. The CFTC fined the company $1.25 million last year for providing an illegal trading service.

For more than three decades, US policy has frequently included sanctions against Iran. After pulling out of the Iran nuclear agreement in 2018, former president Donald Trump reinstated sanctions. In his view, the deal did not do enough to rein in Iran's missile development. Due to these restrictions, US companies having trade ties to Iran had to cease operations.

Kraken's chief legal officer, Marco Santori, stated that the San Francisco-based cryptocurrency exchange does not comment on particular conversations with regulators and is growing its compliance staff to keep up with the expansion of its business. Separately, due to Russia's conflict with Ukraine, the US has placed sanctions on several Russian individuals. However, no statutory restriction prevents crypto providers from barring access to accounts. According to Kraken CEO Jesse Powell, total bans would be unfair to Russians, calling such a move a "pretty extreme measure."

Other Companies Facing Charges for Servicing Sanctioned Nations

As the market for digital currencies has expanded, the federal government has aggressively cracked down on crypto businesses, which are only loosely regulated. In July, the Justice Department filed insider trading charges against an ex-employee of Coinbase, one of the biggest US crypto exchanges. Tether, a stablecoin startup, was fined by the Commodity Futures Trading Commission for false representations of its reserves last year.

A macroeconomic environment that is unpredictable, a decline in risk appetite following the collapse of TerraUSD (UST), and the ripple effects on cryptocurrency lenders like Celsius and Voyager are some of the contributing factors. Industry analysts anticipate that the regulatory environment for cryptocurrencies will rapidly change. This month, according to a report from Reuters, Binance broke US restrictions by letting users from Iran to trade on its platform. However, according to Chagri Poyraz, Binance's global head of sanctions (VPNs), users may have been able to get around restrictions via Virtual Private Networks.

Although not for disobeying US sanctions, Kraken has already faced enforcement actions and was apparently seeking a valuation exceeding $10 billion earlier this year. The Commodity Futures Trading Commission fined the exchange $1.25 million in September 2021 for allegedly making an improper offering.

BitGo, a provider of digital wallet services located in Palo Alto, California, was fined more than $98,000 by the OFAC in 2020 for 183 alleged sanctions violations. For 2,102 alleged infractions, it penalised BitPay, an Atlanta-based cryptocurrency payment processor, more than $500,000 last year. Coinbase also disclosed in a 2021 financial filing that it had sent notices to OFAC flagging transactions that may have violated sanctions, though the agency hasn't taken any enforcement action.

Learn More: Latest AML Fine Figures

How to Remain Compliant According to OFAC 

According to Hailey Lennon, an attorney at Anderson Kill who specialises in regulatory concerns in the cryptocurrency industry, "the fact that crypto can move without a bank or middleman means that exchanges are accountable for some sorts of financial regulatory compliance."

In a guide published by OFAC, they list their expectations for internal controls from any virtual currency firms. 

OFAC states that an effective sanctions compliance programme will include policies and procedures designed to address the risks identified in a company's risk assessment. These may include controls to identify, interdict, escalate, report (as appropriate), and maintain records for transactions or activities prohibited by OFAC-administered sanctions. An effective sanctions compliance programme will enable a company to conduct sufficient due diligence on customers, business partners, and transactions and identify "red flags." 

Red flags are indications that illicit activity or compliance breakdowns may be occurring that prompt a company to investigate and take appropriate action. Policies and procedures should be enforced, and weaknesses should be identified and remediated to prevent activity that might violate sanctions. In the virtual currency industry, the internal controls a company implements will depend on the products and services the company offers, where the company operates, the locations of its users, and what sanctions-specific risks the company identifies during its risk assessment process. Internal controls often involve the use of industry-specific tools, such as screening, investigation, and transaction monitoring. 

OFAC also states that the virtual currency industry may use software as these can be helpful tools for an effective sanctions compliance programme. 

Risk Indicators or Red Flags According to OFAC

In their guide, OFAC states that in addition to screening transactions and other KYC identifying information, virtual currency companies should also consider monitoring transactions and users for risk indicators or "red flags" that may indicate a sanctions nexus. Examples of risk indicators may be individuals or entities who: 

  • Provide inaccurate or incomplete customer identification or KYC information when attempting to open an account 
  • Attempt to access a virtual currency exchange from an IP address or VPN connected to a sanctioned jurisdiction 
  • Are non-responsive or refuse to provide updated customer identification or KYC information 
  • Are non-responsive or refuse to provide additional transaction information in response to a virtual currency company's request 
  • Attempt to transact with a virtual currency address associated with a blocked person or sanctioned jurisdiction 

Additionally, as appropriate, "red flags" indicative of money laundering or other illicit financial activity may also be indicative of potential sanctions evasion.

The Need For a Sanctions Screening Tool

As a corporation, you have the difficulty of finding a way to thoroughly and cost-effectively review the numerous sanctions lists without disturbing your daily operations. Manual checks would be complex and time-consuming due to a large number of sanctions lists to be verified and can also easily lead to human error. Finding an automated system to complete these mandatory tests makes sense and is the simplest way to reach the compliance standards that regulators like OFAC require.

Speak to a team member to get more information about our screening tool today.

 

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Blogs
28 Oct 2025
5 min
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Trapped on Camera: Inside Australia’s Chilling Live-Stream Extortion Scam

Introduction: A Crime That Played Out in Real Time

It began like a scene from a psychological thriller — a phone call, a voice claiming to be law enforcement, and an accusation that turned an ordinary life upside down.

In mid-2025, an Australian nurse found herself ensnared in a chilling scam that spanned months and borders. Fraudsters posing as Chinese police convinced her she was implicated in a criminal investigation and demanded proof of innocence.

What followed was a nightmare: she was monitored through live-stream video calls, coerced into isolation, and ultimately forced to transfer over AU$320,000 through multiple accounts.

This was no ordinary scam. It was psychological imprisonment, engineered through fear, surveillance, and cross-border financial manipulation.

The “live-stream extortion scam,” as investigators later called it, revealed how far organised networks have evolved — blending digital coercion, impersonation, and complex laundering pipelines that exploit modern payment systems.

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The Anatomy of the Scam

According to reports from Australian authorities and news.com.au, the scam followed a terrifyingly systematic pattern — part emotional manipulation, part logistical precision.

  1. Initial Contact – The victim received a call from individuals claiming to be from the Chinese Embassy in Canberra. They alleged that her identity had been used in a major crime.
  2. Transfer to ‘Police’ – The call was escalated to supposed Chinese police officers. These fraudsters used uniforms and badges in video calls, making the impersonation feel authentic.
  3. Psychological Entrapment – The victim was told she was under investigation and must cooperate to avoid arrest. She was ordered to isolate herself, communicate only via encrypted apps, and follow their “procedures.”
  4. The Live-Stream Surveillance – For weeks, scammers demanded she keep her webcam on for long hours daily so they could “monitor her compliance.” This tactic ensured she remained isolated, fearful, and completely controlled.
  5. The Transfers Begin – Under threat of criminal charges, she was instructed to transfer her savings into “safe accounts” for verification. Over AU$320,000 was moved in multiple transactions to mule accounts across the region.

By the time she realised the deception, the money had vanished through layers of transfers and withdrawals — routed across several countries within hours.

Why Victims Fall for It: The Psychology of Control

This scam wasn’t built on greed. It was built on fear and authority — two of the most powerful levers in human behaviour.

Four manipulation techniques stood out:

  • Authority Bias – The impersonation of police officials leveraged fear of government power. Victims were too intimidated to question legitimacy.
  • Isolation – By cutting victims off from family and friends, scammers removed all sources of doubt.
  • Surveillance and Shame – Continuous live-stream monitoring reinforced compliance, making victims believe they were truly under investigation.
  • Incremental Compliance – The fraudsters didn’t demand the full amount upfront. Small “verification transfers” escalated gradually, conditioning obedience.

What made this case disturbing wasn’t just the financial loss — but how it weaponised digital presence to achieve psychological captivity.

ChatGPT Image Oct 28, 2025, 06_41_51 PM

The Laundering Playbook: From Fear to Finance

Behind the emotional manipulation lay a highly organised laundering operation. The scammers moved funds with near-institutional precision.

  1. Placement – Victims deposited funds into local accounts controlled by money mules — individuals recruited under false pretences through job ads or online chats.
  2. Layering – Within hours, the funds were fragmented and channelled:
    • Through fintech payment apps and remittance platforms with fast settlement speeds.
    • Into business accounts of shell entities posing as logistics or consulting firms.
    • Partially converted into cryptocurrency to obscure traceability.
  3. Integration – Once the trail cooled, the money re-entered legitimate financial channels through overseas investments and asset purchases.

This progression from coercion to laundering highlights why scams like this aren’t merely consumer fraud — they’re full-fledged financial crime pipelines that demand a compliance response.

A Broader Pattern Across the Region

The live-stream extortion scam is part of a growing web of cross-jurisdictional deception sweeping Asia-Pacific:

  • Taiwan: Victims have been forced to record “confession videos” as supposed proof of innocence.
  • Malaysia and the Philippines: Scam centres dismantled in 2025 revealed money-mule networks used to channel proceeds into offshore accounts.
  • Australia: The Australian Federal Police continues to warn about rising “safe account” scams where victims are tricked into transferring funds to supposed law enforcement agencies.

The convergence of social engineering and real-time payments has created a fraud ecosystem where emotional manipulation and transaction velocity fuel each other.

Red Flags for Banks and Fintechs

Financial institutions sit at the frontline of disruption.
Here are critical red flags across transaction, customer, and behavioural levels:

1. Transaction-Level Indicators

  • Multiple mid-value transfers to new recipients within short intervals.
  • Descriptions referencing “case,” “verification,” or “safe account.”
  • Rapid withdrawals or inter-account transfers following large credits.
  • Sudden surges in international transfers from previously dormant accounts.

2. KYC/CDD Risk Indicators

  • Recently opened accounts with minimal transaction history receiving large inflows.
  • Personal accounts funnelling funds through multiple unrelated third parties.
  • Connections to high-risk jurisdictions or crypto exchanges.

3. Customer Behaviour Red Flags

  • Customers reporting that police or embassy officials instructed them to move funds.
  • Individuals appearing fearful, rushed, or evasive when explaining transfer reasons.
  • Seniors or migrants suddenly sending large sums overseas without clear purpose.

When combined, these signals form the behavioural typologies that transaction-monitoring systems must be trained to identify in real time.

Regulatory and Industry Response

Authorities across Australia have intensified efforts to disrupt the networks enabling such scams:

  • Australian Federal Police (AFP): Launched dedicated taskforces to trace mule accounts and intercept funds mid-transfer.
  • Australian Competition and Consumer Commission (ACCC): Through Scamwatch, continues to warn consumers about escalating impersonation scams.
  • Financial Institutions: Major banks are now introducing confirmation-of-payee systems and inbound-payment monitoring to flag suspicious deposits before funds are moved onward.
  • Cross-Border Coordination: Collaboration with ASEAN financial-crime units has strengthened typology sharing and asset-recovery efforts for transnational cases.

Despite progress, the challenge remains scale — scams evolve faster than traditional manual detection methods. The solution lies in shared intelligence and adaptive technology.

How Tookitaki Strengthens Defences

Tookitaki’s ecosystem of AI-driven compliance tools directly addresses these evolving, multi-channel threats.

1. AFC Ecosystem: Shared Typologies for Faster Detection

The AFC Ecosystem aggregates real-world scenarios contributed by compliance professionals worldwide.
Typologies covering impersonation, coercion, and extortion scams help financial institutions across Australia and Asia detect similar behavioural patterns early.

2. FinCense: Scenario-Driven Monitoring

FinCense operationalises these typologies into live detection rules. It can flag:

  • Victim-to-mule account flows linked to extortion scams.
  • Rapid outbound transfers inconsistent with customer behaviour.
  • Multi-channel layering patterns across bank and fintech rails.

Its federated-learning architecture allows institutions to learn collectively from global patterns without exposing customer data — turning local insight into regional strength.

3. FinMate: AI Copilot for Investigations

FinMate, Tookitaki’s investigation copilot, connects entities across multiple transactions, surfaces hidden relationships, and auto-summarises alert context.
This empowers compliance teams to act before funds disappear, drastically reducing investigation time and false positives.

4. The Trust Layer

Together, Tookitaki’s systems form The Trust Layer — an integrated framework of intelligence, AI, and collaboration that protects the integrity of financial systems and restores confidence in every transaction.

Conclusion: From Fear to Trust

The live-stream extortion scam in Australia exposes how digital manipulation has entered a new frontier — one where fraudsters don’t just deceive victims, they control them.

For individuals, the impact is devastating. For financial institutions, it’s a wake-up call to detect emotional-behavioural anomalies before they translate into cross-border fund flows.

Prevention now depends on collaboration: between banks, regulators, fintechs, and technology partners who can turn intelligence into action.

With platforms like FinCense and the AFC Ecosystem, Tookitaki helps transform fragmented detection into coordinated defence — ensuring trust remains stronger than fear.

Because when fraud thrives on control, the answer lies in intelligence that empowers.

Trapped on Camera: Inside Australia’s Chilling Live-Stream Extortion Scam
Blogs
27 Oct 2025
6 min
read

Eliminating AI Hallucinations in Financial Crime Detection: A Governance-First Approach

Introduction: When AI Makes It Up — The High Stakes of “Hallucinations” in AML

This is the third instalment in our series, Governance-First AI Strategy: The Future of Financial Crime Detection.

  • In Part 1, we explored the governance crisis created by compliance-heavy frameworks.

  • In Part 2, we highlighted how Singapore’s AI Verify program is pioneering independent validation as the new standard.

In this post, we turn to one of the most urgent challenges in AI-driven compliance: AI hallucinations.

Imagine an AML analyst starting their day, greeted by a queue of urgent alerts. One, flagged as “high risk,” is generated by the newest AI tool. But as the analyst investigates, it becomes clear that some transactions cited by the AI never actually happened. The explanation, while plausible, is fabricated: a textbook case of AI hallucination.

Time is wasted. Trust in the AI system is shaken. And worse, while chasing a phantom, a genuine criminal scheme may slip through.

As artificial intelligence becomes the core engine for financial crime detection, the problem of hallucinations, outputs not grounded in real data or facts, poses a serious threat to compliance, regulatory trust, and operational efficiency.

What Are AI Hallucinations and Why Are They So Risky in Finance?

AI hallucinations occur when a model produces statements or explanations that sound correct but are not grounded in real data.

In financial crime compliance, this can lead to:

  • Wild goose chases: Analysts waste valuable time chasing non-existent threats.

  • Regulatory risk: Fabricated outputs increase the chance of audit failures or penalties.

  • Customer harm: Legitimate clients may be incorrectly flagged, damaging trust and relationships.

Generative AI systems are especially vulnerable. Designed to create coherent responses, they can unintentionally invent entire scenarios. In finance, where every “fact” matters to reputations, livelihoods, and regulatory standing, there is no room for guesswork.

ChatGPT Image Oct 27, 2025, 01_15_25 PM

Why Do AI Hallucinations Happen?

The drivers are well understood:

  1. Gaps or bias in training data: Incomplete or outdated records force models to “fill in the blanks” with speculation.

  2. Overly creative design: Generative models excel at narrative-building but can fabricate plausible-sounding explanations without constraints.

  3. Ambiguous prompts or unchecked logic: Vague inputs encourage speculation, diverting the model from factual data.

Real-World Misfire: A Costly False Alarm

At a large bank, an AI-powered monitoring tool flagged accounts for “suspicious round-dollar transactions,” producing a detailed narrative about potential laundering.

The problem? Those transactions never occurred.

The AI had hallucinated the explanation, stitching together fragments of unrelated historical data. The result: a week-long audit, wasted resources, and an urgent reminder of the need for stronger governance over AI outputs.

A Governance-First Playbook to Stop Hallucinations

Forward-looking compliance teams are embedding anti-hallucination measures into their AI governance frameworks. Key practices include:

1. Rigorous, Real-World Model Training
AI models must be trained on thousands of verified AML cases, including edge cases and emerging typologies. Exposure to operational complexity reduces speculative outputs.At Tookitaki, scenario-driven drills such as deepfake scam simulations and laundering typologies continuously stress-test the system to identify risks before they reach investigators or regulators.

2. Evidence-Based Outputs, Not Vague Alerts
Traditional systems often produce alerts like: “Possible layering activity detected in account X.” Analysts are left to guess at the reasoning.Governance-first systems enforce data-anchored outputs:“Layering risk detected: five transactions on 20/06/25 match FATF typology #3. See attached evidence.”
This creates traceable, auditable insights, building efficiency and trust.

3. Human-in-the-Loop (HITL) Validation
Even advanced models require human oversight. High-stakes outputs, such as risk narratives or new typology detections, must pass through expert validation.At Tookitaki, HITL ensures:

  • Analytical transparency
  • Reduced false positives
  • No unexplained “black box” reasoning

4. Prompt Engineering and Retrieval-Augmented Generation (RAG)Ambiguity invites hallucinations. Precision prompts, combined with RAG techniques, ensure outputs are tied to verified databases and transaction logs, making fabrication nearly impossible.

Spotlight: Tookitaki’s Precision-First AI Philosophy

Tookitaki’s compliance platform is built on a governance-first architecture that treats hallucination prevention as a measurable objective.

  • Scenario-Driven Simulations: Rare typologies and evolving crime patterns are continuously tested to surface potential weaknesses before deployment.

  • Community-Powered Validation: Detection logic is refined in real time through feedback from a global network of financial crime experts.

  • Mandatory Fact Citations: Every AI-generated narrative is backed by case data and audit references, accelerating compliance reviews and strengthening regulatory confidence.

At Tookitaki, we recognise that no AI system can be infallible. As leading research highlights, some real-world questions are inherently unanswerable. That is why our goal is not absolute perfection, but precision-driven AI that makes hallucinations statistically negligible and fully traceable — delivering factual integrity at scale.

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Conclusion: Factual Integrity Is the Foundation of Trust

Eliminating hallucinations is not just a technical safeguard. It is a governance imperative. Compliance teams that embed evidence-based outputs, rigorous training, human-in-the-loop validation, and retrieval-anchored design will not only reduce wasted effort but also strengthen regulatory confidence and market reputation.

Key Takeaways from Part 3:

  1. AI hallucinations erode trust, waste resources, and expose firms to regulatory risk.

  2. Governance-first frameworks prevent hallucinations by enforcing evidence-backed, auditable outputs.

  3. Zero-hallucination AI is not optional. It is the foundation of responsible financial crime detection.

Are you asking your AI to show its data?
If not, you may be chasing ghosts.

In the next blog, we will explore how building an integrated, agentic AI strategy, linking model creation to real-time risk detection, can shift compliance from reactive to resilient.

Eliminating AI Hallucinations in Financial Crime Detection: A Governance-First Approach
Blogs
13 Oct 2025
6 min
read

When MAS Calls and It’s Not MAS: Inside Singapore’s Latest Impersonation Scam

A phone rings in Singapore.
The caller ID flashes the name of a trusted brand, M1 Limited.
A stern voice claims to be from the Monetary Authority of Singapore (MAS).

“There’s been suspicious activity linked to your identity. To protect your money, we’ll need you to transfer your funds to a safe account immediately.”

For at least 13 Singaporeans since September 2025, this chilling scenario wasn’t fiction. It was the start of an impersonation scam that cost victims more than S$360,000 in a matter of weeks.

Fraudsters had merged two of Singapore’s most trusted institutions, M1 and MAS, into one seamless illusion. And it worked.

The episode underscores a deeper truth: as digital trust grows, it also becomes a weapon. Scammers no longer just mimic banks or brands. They now borrow institutional credibility itself.

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The Anatomy of the Scam

According to police advisories, this new impersonation fraud unfolds in a deceptively simple series of steps:

  1. The Setup – A Trusted Name on Caller ID
    Victims receive calls from numbers spoofed to appear as M1’s customer service line. The scammers claim that the victim’s account or personal data has been compromised and is being used for illegal activity.
  2. The Transfer – The MAS Connection
    Mid-call, the victim is redirected to another “officer” who introduces themselves as an investigator from the Monetary Authority of Singapore. The tone shifts to urgency and authority.
  3. The Hook – The ‘Safe Account’ Illusion
    The supposed MAS officer instructs the victim to move money into a “temporary safety account” for protection while an “investigation” is ongoing. Every interaction sounds professional, from background call-centre noise to scripted verification questions.
  4. The Extraction – Clean Sweep
    Once the transfer is made, communication stops. Victims soon realise that their funds, sometimes their life savings, have been drained into mule accounts and dispersed across digital payment channels.

The brilliance of this scam lies in its institutional layering. By impersonating both a telecom company and the national regulator, the fraudsters created a perfect loop of credibility. Each brand reinforced the other, leaving victims little reason to doubt.

Why Victims Fell for It: The Psychology of Authority

Fraudsters have long understood that fear and trust are two sides of the same coin. This scam exploited both with precision.

1. Authority Bias
When a call appears to come from MAS, Singapore’s financial regulator, victims instinctively comply. MAS is synonymous with legitimacy. Questioning its authority feels almost unthinkable.

2. Urgency and Fear
The narrative of “criminal misuse of your identity” triggers panic. Victims are told their accounts are under investigation, pushing them to act immediately before they “lose everything.”

3. Technical Authenticity
Spoofed numbers, legitimate-sounding scripts, and even hold music similar to M1’s call centre lend realism. The environment feels procedural, not predatory.

4. Empathy and Rapport
Scammers often sound calm and helpful. They “guide” victims through the process, framing transfers as protective, not suspicious.

These psychological levers bypass logic. Even well-educated professionals have fallen victim, proving that awareness alone is not enough when deception feels official.

The Laundering Playbook Behind the Scam

Once the funds leave the victim’s account, they enter a machinery that’s disturbingly efficient: the mule network.

1. Placement
Funds first land in personal accounts controlled by local money mules, individuals who allow access to their bank accounts in exchange for commissions. Many are recruited via Telegram or social media ads promising “easy income.”

2. Layering
Within hours, funds are split and moved:

  • To multiple domestic mule accounts under different names.
  • Through remittance platforms and e-wallets to obscure trails.
  • Occasionally into crypto exchanges for rapid conversion and cross-border transfer.

3. Integration
Once the money has been sufficiently layered, it’s reintroduced into the economy through:

  • Purchases of high-value goods such as luxury items or watches.
  • Peer-to-peer transfers masked as legitimate business payments.
  • Real-estate or vehicle purchases under third-party names.

Each stage widens the distance between the victim’s account and the fraudster’s wallet, making recovery almost impossible.

What begins as a phone scam ends as money laundering in motion, linking consumer fraud directly to compliance risk.

A Surge in Sophisticated Scams

This impersonation scheme is part of a larger wave reshaping Singapore’s fraud landscape:

  • Government Agency Impersonations:
    Earlier in 2025, scammers posed as the Ministry of Health and SingPost, tricking victims into paying fake fees for “medical” or “parcel-related” issues.
  • Deepfake CEO and Romance Scams:
    In March 2025, a Singapore finance director nearly lost US$499,000 after a deepfake video impersonated her CEO during a virtual meeting.
  • Job and Mule Recruitment Scams:
    Thousands of locals have been drawn into acting as unwitting money mules through fake job ads offering “commission-based transfers.”

The lines between fraud, identity theft, and laundering are blurring, powered by social engineering and emerging AI tools.

Singapore’s Response: Technology Meets Policy

In an unprecedented move, Singapore’s banks are introducing a new anti-scam safeguard beginning 15 October 2025.

Accounts with balances above S$50,000 will face a 24-hour hold or review when withdrawals exceed 50% of their total funds in a single day.

The goal is to give banks and customers time to verify large or unusual transfers, especially those made under pressure.

This measure complements other initiatives:

  • Anti-Scam Command (ASC): A joint force between the Singapore Police Force, MAS, and IMDA that coordinates intelligence across sectors.
  • Digital Platform Code of Practice: Requiring telcos and platforms to share threat information faster.
  • Money Mule Crackdowns: Banks and police continue to identify and freeze mule accounts, often through real-time data exchange.

It’s an ecosystem-wide effort that recognises what scammers already exploit: financial crime doesn’t operate in silos.

ChatGPT Image Oct 13, 2025, 01_55_40 PM

Red Flags for Banks and Fintechs

To prevent similar losses, financial institutions must detect the digital fingerprints of impersonation scams long before victims report them.

1. Transaction-Level Indicators

  • Sudden high-value transfers from retail accounts to new or unrelated beneficiaries.
  • Full-balance withdrawals or transfers shortly after a suspicious inbound call pattern (if linked data exists).
  • Transfers labelled “safe account,” “temporary holding,” or other unusual memo descriptors.
  • Rapid pass-through transactions to accounts showing no consistent economic activity.

2. KYC/CDD Risk Indicators

  • Accounts receiving multiple inbound transfers from unrelated individuals, indicating mule behaviour.
  • Beneficiaries with no professional link to the victim or stated purpose.
  • Customers with recently opened accounts showing immediate high-velocity fund movements.
  • Repeated links to shared devices, IPs, or contact numbers across “unrelated” customers.

3. Behavioural Red Flags

  • Elderly or mid-income customers attempting large same-day transfers after phone interactions.
  • Requests from customers to “verify” MAS or bank staff, a potential sign of ongoing social engineering.
  • Multiple failed transfer attempts followed by a successful large payment to a new payee.

For compliance and fraud teams, these clues form the basis of scenario-driven detection, revealing intent even before loss occurs.

Why Fragmented Defences Keep Failing

Even with advanced fraud controls, isolated detection still struggles against networked crime.

Each bank sees only what happens within its own perimeter.
Each fintech monitors its own platform.
But scammers move across them all, exploiting the blind spots in between.

That’s the paradox: stronger individual controls, yet weaker collaborative defence.

To close this gap, financial institutions need collaborative intelligence, a way to connect insights across banks, payment platforms, and regulators without breaching data privacy.

How Collaborative Intelligence Changes the Game

That’s precisely where Tookitaki’s AFC Ecosystem comes in.

1. Shared Scenarios, Shared Defence

The AFC Ecosystem brings together compliance experts from across ASEAN and ANZ to contribute and analyse real-world scenarios, including impersonation scams, mule networks, and AI-enabled frauds.
When one member flags a new scam pattern, others gain immediate visibility, turning isolated awareness into collaborative defence.

2. FinCense: Scenario-Driven Detection

Tookitaki’s FinCense platform converts these typologies into actionable detection models.
If a bank in Singapore identifies a “safe account” transfer typology, that logic can instantly be adapted to other institutions through federated learning, without sharing customer data.
It’s collaboration powered by AI, built for privacy.

3. AI Agents for Faster Investigations

FinMate, Tookitaki’s AI copilot, assists investigators by summarising cases, linking entities, and surfacing relationships between mule accounts.
Meanwhile, Smart Disposition automatically narrates alerts, helping analysts focus on risk rather than paperwork.

Together, they accelerate how financial institutions identify, understand, and stop impersonation scams before they scale.

Conclusion: Trust as the New Battleground

Singapore’s latest impersonation scam proves that fraud has evolved. It no longer just exploits systems but the very trust those systems represent.

When fraudsters can sound like regulators and mimic entire call-centre environments, detection must move beyond static rules. It must anticipate scenarios, adapt dynamically, and learn collaboratively.

For banks, fintechs, and regulators, the mission is not just to block transactions. It is to protect trust itself.
Because in the digital economy, trust is the currency everything else depends on.

With collaborative intelligence, real-time detection, and the right technology backbone, that trust can be defended, not just restored after losses but safeguarded before they occur.

When MAS Calls and It’s Not MAS: Inside Singapore’s Latest Impersonation Scam