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How FinTech is advancing AML Controls in the UAE?

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Jerin Mathew
14 December 2022
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10 min

With the advent of new technology, the way we conduct financial transactions has changed dramatically. We have gone from a world where cash was king to one where digital transactions are the norm. This shift has been especially pronounced in the Middle East, where a region traditionally dominated by physical currency is now embracing digitization and taking measures to increase innovation.

Compared with Europe’s annual growth of 4-5 percent, consumer digital payment transactions in the UAE grew at a rate of over 9 percent between 2014 and 2019. In 2022, digital payment volumes from SMEs grew by 44%, according to a report by McKinsey and Co.

Along with new opportunities, the growing cashless society in the Middle East has presented the need for new onboarding and ongoing due diligence mechanisms within fintech companies, with an increasing reliance on technology to fight financial crime. As more and more businesses move online, it's no surprise that financial crime is following suit.

The move to a cashless society in the Middle East presents both challenges and opportunities for anti-financial crime professionals. Traditional methods of due diligence and onboarding are no longer sufficient in a digital world. In order to explore some of the critical things that financial institutions need to know to ensure financial crime compliance in line with growing digitalization, Tookitaki conducted a webinar on December 13 as part of our Compliant Conversations webinar series.

Moderated by Gloria Chraim, Tookitaki’s Regional Head of Sales (MEA), we were fortunate to have on board Meyya EL Amine, Chief Compliance Officer at Yap Payment Services, and Gurminder Kaur, Head of Compliance at Al Rostamani International Exchange, as our key speakers in the webinar. The speakers covered topics such as addressing the shift from traditional banking to digital banking, how new trends and technologies are shaping up the anti-financial crime efforts in the Middle East and how the regulatory landscape is changing to support the continued adoption of technology.  The speakers also shared tips for fintech companies to stay proactive and ensure compliance with holistic visibility and better insights into customer behaviour and identifying suspicious activities at large.

The Rising Popularity of Digital Banking in the UAE

In the UAE, digital banking started with individuals, however, the sector has now grown to incorporate small and medium enterprises (SMEs) and even bigger companies. In digital banking, automation, multimedia and telecom came together to give customers a seamless banking experience. Compared to traditional banking, it is faster, more convenient, customer friendly and smart.

During the pandemic, the existing digital infrastructure in the UAE came to people’s rescue and they happily embraced digital banking and digital financial services. The emergence of digital banking positively impacted the way how financial institutions do their regulatory filing that too have gone digital to a large extent. The UAE government and the regulatory authorities were well prepared for the change as they have already laid down measures supported by a great infrastructure.

The Opportunities and Challenges of a Cashless Economy

The transition to a cashless economy has the potential to bring many benefits, such as increased convenience and speed of transactions, reduced costs for businesses and financial institutions, and improved financial inclusion for underserved populations.

However, the transition to a cashless economy also presents some challenges that the UAE must carefully address in order to ensure a smooth and successful transition. Some of the key opportunities and challenges of a cashless economy in the UAE are discussed below.

Opportunities:

Increased convenience and speed of transactions: Digital payment methods are typically faster and more convenient than using cash, allowing for more efficient transactions and reducing the time and effort required for both consumers and businesses.

Reduced costs for businesses and financial institutions: A cashless economy can help reduce the costs associated with handling and transporting physical money, such as security and transportation expenses. This can be particularly beneficial for small businesses and financial institutions.

Improved financial inclusion: A cashless economy can help improve access to financial services for underserved populations, such as migrant workers or rural communities. This can help promote economic growth and reduce inequality.

Challenges:

Access to technology and financial services: In order for a cashless economy to be successful, everyone must have access to the necessary technology and financial services. This can be a challenge in the UAE, where there is a large population of migrant workers who may not have access to bank accounts or the means to use digital payment methods.

Impact on small businesses and traditional industries: The transition to a cashless economy may be difficult for small businesses and traditional industries that do not have the infrastructure or resources to support digital payment methods. These businesses may struggle to compete with larger, more technologically advanced companies if they are unable to accept digital payments.

Money Laundering/Terrorist Financing Risks: A cashless economy can make it easier for criminals to conduct financial transactions without leaving a paper trail, making it more difficult for law enforcement agencies to detect and prevent money laundering and terrorist financing.

Cybersecurity risks: As more transactions are conducted digitally, there is an increased risk of sensitive financial information being compromised. The UAE must take steps to ensure the security of digital payment systems in order to protect against fraud and hacking.

Overall, while the transition to a cashless economy in the UAE has the potential to bring many benefits, it is important for the government and other stakeholders to carefully address these challenges in order to ensure a smooth and successful transition.

The Gaps of Traditional Approaches to Fighting Financial Crime

With financial channels going online, the bad actors have more chances for their illicit activities, taking advantage of possible gaps in the digital financial system. Regulatory scrutiny over financial institutions has continued to increase and fines have been rising too. It might be because of a disconnect between what we have been practicing and what needs to be done given the changing scenarios.

We still create customer risk profiles n silos. Within compliance, customer screening, transaction monitoring and customer risk scoring processes do not speak to each other, thereby failing to provide a holistic view of the customer. This is one of the reasons why the traditional rule-based or scenario-based approaches are failing today. With a huge customer base, where the data fields are static and are not regularly updated, the actual customer risk remains not captured. Compliance analysts are often burdened with a large number of alerts, leading to the possibility of many high-risk customers remaining unaffected.

The Need for New Onboarding and Ongoing Due Diligence Mechanisms

Rule-based customer risk assessment is no longer an option. This needs to be done in a dynamic fashion and on an ongoing basis. If our data on customer is obsolete or not up to the mark, then definitely we will feel the pinch as those data is the basis of all our customer risk assessment, transaction monitoring and name screening processes. Despite the possibilities of fraud, digital know your customer or KYC has actually come as a boon as it helps in remediating your data issues to a large extent. However, digital KYC alone is not going to help us; we need to feed the digital KYC systems properly.

We need to first understand our data and segment our customers. There cannot be a one-size-fits-all approach. Customers need to be segmented based on geographies, nationalities, occupation, industries, etc., depending on the business model, and proper risk values or scores need to be determined for each customer. Based on perceived risk, the nature of questions at the time of onboarding can be simplified or made tougher.

Technologies like Optical Character Recognition (OCR) and facial recognitioncan also help to a great extent. OCR can take old data, validate it and populate it into a more readable, more accurate form. With facial recognition, we can have liveliness check, biometrics assessment and validate the customer with a central database. Ongoing due diligence is also required to feed the customer risk rating models. This will help rescore customer risk dynamically at regular intervals or if there are any changes in the original customer profile.

The Impact of New Trends and Technologies on Compliance

The UAE in particular and the GCC or MENA region in general are embracing the risk-based approach (RBA) to fighting financial crime. Today, the compliance trend is to have easily verifiable and real-time channels for customer identification documents and commercial registries. Technology is helping us a lot in compliance, and the regulatory requirements are also boosting technology to be more innovative, smarter and quicker. All of us, the customers, the businesses and regulators, are benefiting from it. Businesses are even using it for understanding the consumer better and customise their product and service offerings.

This is all coming to the surface of the final consumer and the business. Even though it is compliance related and a part of regulatory requirements, it is serving us immensely and it's growing exponentially.

The Role of Technology in Fighting Financial Crime

Technology plays a crucial role in the fight against financial crime by providing tools and systems that can help detect and prevent illegal activities.

  • Machine learning is a type of artificial intelligence that involves training algorithms on large amounts of data to enable them to make predictions or take actions based on that data. This technology can be used in the fight against financial crime by providing algorithms with data on past financial crimes, such as money laundering or fraud. The algorithms can then learn to identify patterns and anomalies in financial data that may indicate illegal activity.
  • One potential application of machine learning in the fight against financial crime is in the detection of money laundering. By analyzing transaction data, algorithms can learn to identify the characteristics of money laundering transactions, such as the use of multiple bank accounts or the movement of money through different countries. This can help law enforcement agencies and financial institutions detect potential money laundering activities and take action to prevent them.
  • Another potential application of machine learning in the fight against financial crime is in the detection of fraud. Algorithms can be trained on data from past fraud cases to learn the patterns and characteristics of fraudulent transactions.
  • Overall, machine learning has the potential to play a significant role in the fight against financial crime by providing algorithms with the ability to identify patterns and anomalies in financial data that may indicate illegal activity.
  • Another way that technology is used in the fight against financial crime is through the development of secure payment systems. These systems use encryption and other security measures to protect financial transactions and prevent fraud. This can help protect consumers and businesses from becoming victims of financial crimes.
  • Additionally, technology is also used to improve communication and collaboration among law enforcement agencies, regulatory bodies, and financial institutions. This can help these organizations share information and collaborate effectively to combat financial crime.

The Importance of Collective Intelligence

Collective intelligence can play an important role in fighting financial crime by allowing organisations and individuals to share information and resources, coordinate efforts, and work together towards a common goal. For example, financial institutions can use collective intelligence to share information about suspicious transactions and patterns of behaviour that may indicate financial crimes such as money laundering or fraud. This can help identify potential threats and enable law enforcement and other agencies to take action.

In addition, collective intelligence can be used to develop and improve algorithms and other technologies for detecting and preventing financial crimes. By pooling their expertise and resources, organisations and individuals can work together to create more effective solutions for detecting and preventing financial crime.

The Change in Regulatory Landscape to Support Tech Adoption

The regulatory acceptance to new technology has come at a very fast pace. The regulators are not just interested in that you have a system, rather they are interested in knowing why do you have that system. They're interested in understanding that whether you have the know-how of your technology, customer base and typologies, and whether that has been correctly embodied them in your customer risk assessment model.

Regulators can play an active role in bringing standardization in compliance technology adoption also. The federal registry, the IP validations for retail customer database and the public registry for the beneficial ownership are proactive measures from the regulators to ensure that the financial industry is upgrading itself with newer systems.

One example of a change in the regulatory landscape to support tech adoption is the growth of regulatory sandboxes. These are controlled environments in which companies can test new technologies and business models without being subject to all of the usual regulations. This can help companies innovate and bring new products and services to market more quickly, while also ensuring that these products and services are safe and comply with relevant regulations.

How can Fintechs Ensure Compliance?

Fintechs can ensure compliance by optimizing on their systems, by optimizing and investing in their human capital and by looking up to the best practices around the world and applying that. Even if the regulators are not asking to do it, do it now. Furthermore, we need to share knowledge across the organization. We need to make every line of defense understand what is the risk that is associated to our organization, and how we are best at mitigating it.

Improving Compliance with Tookitaki

Headquartered in Singapore, Tookitaki is a regulatory technology company offering financial crime detection and prevention to some of the world's leading banks and fintechs to help them stay vigilant and compliant.

The anti-money laundering (AML) compliance departments of today’s financial institutions are inundated with voluminous false positives and case backlogs that add to costs and prevent them from filtering out high quality alerts.

Tookitaki’s Anti-Money Laundering Suite (AMLS) helps protect your customers throughout the entire onboarding, and ongoing proceses through two modules customised to suit your needs- Intelligent Alert Detection (IAD) for detection and prevention and Smart Alert Management (SAM) for management. Designed on three C-principles – comprehensive, convenient and compliant, the AMLS uses transaction monitoring, smart screening and customer risk scoring solutions. The alerts from all solutions are unified in an interactive, modern-age Case Manager that offers speedy alert disposition and easy regulatory report filing.


Stay empowered with increased risk coverage and mitigate risks seamlessly in the ever-evolving world of regulatory compliance.
Request a demo today to learn more.

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Blogs
02 Dec 2025
6 min
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Inside Australia’s $200 Million Psychic Scam: How a Mother–Daughter Syndicate Manipulated Victims and Laundered Millions

1. Introduction of the Scam

In one of Australia’s most astonishing financial crime cases, police arrested a mother and daughter in November 2025 for allegedly running a two hundred million dollar fraud and money laundering syndicate. Their cover was neither a shell company nor a darknet marketplace. They presented themselves as psychics who claimed the ability to foresee danger, heal emotional wounds, and remove spiritual threats that supposedly plagued their clients.

The case captured national attention because it combined two worlds that rarely collide at this scale. Deep emotional manipulation and sophisticated financial laundering. What seemed like harmless spiritual readings turned into a highly profitable criminal enterprise that operated quietly for years.

The scam is a stark reminder that fraud is evolving beyond impersonation calls and fake investment pitches. Criminals are finding new ways to step into the most vulnerable parts of people’s lives. Understanding this case helps financial institutions identify similar behavioural and transactional signals before they escalate into million dollar losses.

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2. Anatomy of the Scam

Behind the illusion of psychic counselling was a methodical, multi layered fraud structure designed to extract wealth while maintaining unquestioned authority over victims.

A. Establishing Irresistible Authority

The syndicate created an aura of mystique. They styled themselves as spiritual guides with special insight into personal tragedies, relationship breakdowns, and looming dangers. This emotional framing created an asymmetric relationship. The victims were the ones seeking answers. The scammers were the ones providing them.

B. Cultivating Dependence Over Time

Victims did not transfer large sums immediately. The scammers first built trust through frequent sessions, emotional reinforcement, and manufactured “predictions” that aligned with the victims’ fears or desires. Once trust solidified, dependence followed. Victims began to rely on the scammers’ counsel for major life decisions.

C. Escalating Financial Requests Under Emotional Pressure

As dependence grew, payments escalated. Victims were told that removing a curse or healing an emotional blockage required progressively higher financial sacrifices. Some were convinced that failing to comply would bring harm to themselves or loved ones. Fear became the payment accelerator.

D. Operating as a Structured Syndicate

Although the mother and daughter fronted the scheme, police uncovered several associates who helped receive funds, manage assets, and distance the organisers from the flow of money. This structure mirrored the operational models of organised fraud groups.

E. Exploiting the Legitimacy of “Services”

The payments appeared as consulting or spiritual services, which are common and often unregulated. This gave the syndicate a major advantage. Bank transfers looked legitimate. Transaction descriptions were valid. And the activity closely resembled the profiles of other small service providers.

This blending of emotional exploitation and professional disguise is what made the scam extraordinarily effective.

3. Why Victims Fell for It: The Psychology at Play

People often believe financial crime succeeds because victims are careless. This case shows the opposite. The victims were targeted precisely because they were thoughtful, concerned, and searching for help.

A. Authority and Expertise Bias

When someone is positioned as an expert, whether a doctor, advisor, or psychic, their guidance feels credible. Victims trusted the scammers’ “diagnosis” because it appeared grounded in unique insight.

B. Emotional Vulnerability

Many victims were dealing with grief, loneliness, uncertainty, or family conflict. These emotional states are fertile ground for manipulation. Scammers do not need access to bank accounts when they already have access to the human heart.

C. The Illusion of Personal Connection

Fraudsters used personalised predictions and tailored spiritual advice. This created a bond that felt intimate and unique. When a victim feels “understood,” their defences lower.

D. Fear Based Decision Making

Warnings like “your family is at risk unless you act now” are extremely powerful. Under fear, rationality is overshadowed by urgency.

E. The Sunk Cost Trap

Once a victim has invested a significant amount, they continue paying to “finish the process” rather than admit the entire relationship was fraudulent.

Understanding these psychological drivers is essential. They are increasingly common across romance scams, deepfake impersonations, sham consultant schemes, and spiritual frauds across APAC.

4. The Laundering Playbook Behind the Scam

Once the scammers extracted money, the operation transitioned into a textbook laundering scheme designed to conceal the origin of illicit funds and distance the perpetrators from the victims.

A. Multi Layered Account Structures

Money flowed through personal accounts, associates’ accounts, and small businesses that provided cover for irregular inflows. This layering reduced traceability.

B. Conversion Into High Value Assets

Luxury goods, vehicles, property, and jewellery were used to convert liquid funds into stable, movable wealth. These assets can be held long term or liquidated in smaller increments to avoid detection.

C. Cross Jurisdiction Fund Movement

Authorities suspect that portions of the money were transferred offshore. Cross border movements complicate the investigative trail and exploit discrepancies between regulatory frameworks.

D. Cash Based Structuring

Victims were sometimes encouraged to withdraw cash, buy gold, or convert savings into prepaid instruments. These activities create gaps in the financial record that help obscure illicit origins.

E. Service Based Laundering Through Fake Invoices

The scammers reportedly issued or referenced “healing services,” “spiritual cleansing,” and similar descriptions. Because these services are intangible, verifying their legitimacy is difficult.

The laundering strategy was not unusual. What made it hard to detect was its intimate connection to a long term emotional scam.

5. Red Flags for FIs

Financial institutions can detect the early signals of scams like this through behavioural and transactional monitoring.

Key Transaction Red Flags

  1. Repeated high value transfers to individuals claiming to provide advisory or spiritual services.
  2. Elderly or vulnerable customers making sudden, unexplained payments to unfamiliar parties.
  3. Transfers that increase in value and frequency over weeks or months.
  4. Sudden depletion of retirement accounts or long held savings.
  5. Immediate onward transfers from the recipient to offshore banks.
  6. Significant cash withdrawals following online advisory sessions.
  7. Purchases of gold, jewellery, or luxury goods inconsistent with customer profiles.

Key Behavioural Red Flags

  1. Customers showing visible distress or referencing “urgent help” required by an adviser.
  2. Hesitation or refusal to explain the purpose of a transaction.
  3. Uncharacteristic secrecy regarding financial decisions.
  4. Statements referencing curses, spiritual threats, or emotional manipulation.

KYC and Profile Level Red Flags

  1. Service providers with no registered business presence.
  2. Mismatch between declared income and transaction activity.
  3. Shared addresses or accounts among individuals connected to the same adviser.

Financial institutions that identify these early signals can prevent significant losses and support customers before the harm intensifies.

ChatGPT Image Dec 2, 2025, 11_24_39 AM

6. How Tookitaki Strengthens Defences

Modern financial crime is increasingly psychological, personalised, and disguised behind legitimate looking service payments. Tookitaki equips institutions with the intelligence and technology to identify these patterns early.

A. Behavioural Analytics Trained on Real World Scenarios

FinCense analyses changes in spending, emotional distress indicators, unusual advisory payments, and deviations from customer norms. These subtle behavioural cues often precede standard red flags.

B. Collective Intelligence Through the AFC Ecosystem

Compliance experts across Asia Pacific contribute emerging fraud scenarios, including social engineering, spiritual scams, and coercion based typologies. Financial institutions benefit from insights grounded in real world criminal activity, not static rules.

C. Dynamic Detection Models for Service Based Laundering

FinCense distinguishes between ordinary professional service payments and laundering masked as consulting or spiritual fees. This is essential for cases where invoice based laundering is the primary disguise.

D. Automated Threshold Optimisation and Simulation

Institutions can simulate how new scam scenarios would trigger alerts and generate thresholds that adapt to the bank’s customer base. This reduces false positives while improving sensitivity.

E. Early Intervention for Vulnerable Customers

FinCense helps identify elderly or high risk individuals who show sudden behavioural changes. Banks can trigger outreach before the customer falls deeper into manipulation.

F. Investigator Support Through FinMate

With FinMate, compliance teams receive contextual insights, pattern explanations, and recommended investigative paths. This accelerates understanding and action on complex scam patterns.

Together, these capabilities form a proactive defence system that protects victims and reinforces institutional trust.

7. Conclusion

The two hundred million dollar psychic scam is more than a headline. It is a lesson in how deeply fraud can infiltrate personal lives and how effectively criminals can disguise illicit flows behind emotional manipulation. It is also a warning that traditional monitoring systems, which rely on transactional patterns alone, may miss the early behavioural signals that reveal the true nature of emerging scams.

For financial institutions, two capabilities are becoming non negotiable.

  1. Understanding the human psychology behind financial crime.
  2. Using intelligent, adaptive systems that can detect the behavioural and transactional interplay.

Tookitaki helps institutions meet both challenges. Through FinCense and the AFC Ecosystem, institutions benefit from collective intelligence, adaptive detection, and technology designed to understand the complexity of modern fraud.

As scams continue to evolve, so must defences. Building stronger systems today protects customers, prevents loss, and strengthens trust across the financial ecosystem.

Inside Australia’s $200 Million Psychic Scam: How a Mother–Daughter Syndicate Manipulated Victims and Laundered Millions
Blogs
25 Nov 2025
6 min
read

Inside Singapore’s YouTrip Account Takeover Surge: How 21 Victims Lost Control in Seconds

1. Introduction to the Scam

In August 2025, Singapore confronted one of its most instructive fraud cases of the year — a fast, coordinated Account Takeover (ATO) campaign targeting YouTrip users. Within weeks, 21 customers lost access to their wallets after receiving what looked like genuine SMS alerts from YouTrip. More than S$16,000 vanished through unauthorised overseas transactions before most victims even realised their accounts had been compromised.

Unlike investment scams or fake job schemes, this wasn’t a long con.
This was precision fraud — rapid credential theft, instant account access, and a streamlined laundering pathway across borders.

The YouTrip case demonstrates an uncomfortable reality for the region:
ATO attacks are no longer exceptional; they are becoming a dominant fraud vector across Singapore’s instant-payment ecosystem.

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2. Anatomy of the Scam

Even with Singapore’s strong cybersecurity posture, the mechanics behind this attack were alarmingly simple — and that’s what makes it so dangerous.

Step 1: Fraudsters Spoofed YouTrip’s SMS Sender ID

Victims received messages inside the legitimate YouTrip SMS thread.
This erased suspicion instantly. Criminals used sender-ID spoofing to impersonate official alerts such as:

  • “Unusual login detected.”
  • “Your account has been temporarily locked.”
  • “Verify your identity to continue using the app.”

Step 2: Victims Clicked a Link That Looked Trustworthy

The URLs included familiar cues — “youtrip”, “secure”, “sg” — and closely mirrored the brand’s identity.
Phishing sites were mobile-optimised, giving them a legitimate look and feel.

Step 3: Credentials and OTPs Were Harvested in Real Time

The fake page requested the same details as the real app:

  • login email
  • password
  • one-time password

As soon as victims entered the OTP, scammers intercepted it and logged into the real YouTrip account instantly.

Step 4: Takeover Was Completed in Under a Minute

Upon successful login, fraudsters performed high-risk actions:

  • Changed recovery email
  • Added their own device
  • Modified account security settings
  • Removed access for the legitimate user

This locked victims out before they could intervene.

Step 5: Funds Were Drained Through Overseas Transactions

Within minutes, transactions were executed via channels selected for:

  • high transaction throughput
  • low scrutiny
  • regional cash-out networks

By the time victims called YouTrip or the bank, the money was already layered through multiple nodes.

3. Why Victims Fell for It: The Psychology at Play

Contrary to popular belief, victims were not careless — they were outplayed by criminals who understand behavioural sequencing and cognitive biases better than most.

1. Authority Bias

Messages delivered inside an official SMS thread trigger the same psychological authority as a bank officer calling from a registered number.

2. Urgency Override

Terms like “account suspension” or “unauthorised transaction detected” induce panic, shutting down analytical thinking.

3. The Familiarity Heuristic

Humans trust interfaces they recognise.
The cloned YouTrip page exploited this instinct to put victims into autopilot mode.

4. Digital Fatigue

Singaporean users receive dozens of OTPs, login requests, and verification alerts daily.
Criminals exploited this conditioning — when everything looks like routine security, nothing seems suspicious.

5. Multi-Step Confirmation

Phishing sites that request multiple fields (email + password + OTP) feel more legitimate because users equate complexity with authenticity.

ATO scams succeed not because users are uninformed, but because the attacker understands their mental shortcuts.

ChatGPT Image Nov 25, 2025, 12_18_16 PM

4. The Laundering Playbook Behind the Scam

What happened after the account takeover was not random — it followed a familiar cross-border laundering blueprint observed in multiple ASEAN cases this year.

1. Rapid Conversion Through High-Risk Overseas Merchants

Instead of direct wallet-to-wallet transfers, funds were routed through:

  • offshore digital service providers
  • unregulated e-commerce gateways
  • grey-market merchant accounts

This first hop breaks the link between victim and beneficiary.

2. Layering Through Micro-Transactions

Stolen balances are split into multiple small payments to evade:

  • velocity controls
  • threshold triggers
  • AML rule-based alerts

These micro-purchases accumulate into large aggregated totals further downstream.

3. Cash-Out Via Mule Networks

Money ends up with low-tier money mules in:

  • Malaysia
  • Thailand
  • Indonesia
  • or the Philippines

These cash-out operatives withdraw, convert to crypto, or re-route to additional accounts.

4. Final Integration

Funds reappear as:

  • crypto assets
  • overseas remittance credits
  • merchant settlement payouts
  • or legitimate-looking business revenues

Within hours, the fraud becomes laundered value — almost unrecoverable.

The YouTrip case is not an isolated attack, but a reflection of a well-oiled fraud-laundering pipeline.

5. Red Flags for Banks and E-Money Issuers

ATO fraud leaves behind detectable signals — but institutions must be equipped to see them in real time.

A. Pre-Login Red Flags

  • Sudden device fingerprint mismatch
  • Login attempts from high-risk IP addresses
  • Abnormal login timing patterns (late night/early morning bursts)

B. Login Red Flags

  • Multiple failed login attempts followed by a quick success
  • New browser or device immediately accessing sensitive settings
  • Unexpected change to recovery information within minutes of login

C. Transaction Red Flags

  • Rapid overseas transactions after login
  • Micro-transactions in quick succession
  • Transfers to merchants with known risk scores
  • New beneficiary added and transacted with instantly

D. Network-Level Red Flags

  • Funds routed to known mule clusters
  • Transaction patterns matching previously detected laundering typologies
  • Repeated use of the same foreign merchant across multiple victims

These signals often appear long before the account is emptied — if institutions have the intelligence to interpret them.

6. How Tookitaki Strengthens Defences

This case illustrates exactly why Tookitaki is building the Trust Layer for financial institutions across ASEAN and beyond.

1. Community-Powered Intelligence (AFC Ecosystem)

ATO and mule typologies contributed by experts across 20+ markets help institutions recognise patterns before they are exploited locally.

Signals from similar scams in Malaysia, Thailand, and the Philippines immediately enrich Singapore’s detection capabilities.

2. FinCense Real-Time Behavioural Analytics

FinCense continuously evaluates:

  • login patterns
  • device changes
  • location mismatches
  • velocity anomalies
  • transaction behaviour

This means ATO attempts can be flagged even before a fraudulent transfer is executed.

3. Federated Learning for Cross-Border Fraud Signals

Tookitaki’s federated approach enables institutions to detect emerging patterns from shared intelligence without exchanging personal data.

This is critical for attacks like YouTrip ATO, where laundering nodes sit outside Singapore.

4. FinMate — AI Copilot for Investigations

FinMate accelerates analyst action by providing:

  • instant summaries
  • source-of-funds context
  • anomaly explanations
  • recommended next steps

ATO investigations that once took hours can now be handled in minutes.

5. Unified Trust Layer

By integrating AML, fraud detection, and mule network intelligence into one adaptive engine, Tookitaki gives institutions a holistic shield against fast-moving, cross-border ATO attacks.

7. Conclusion

The YouTrip account takeover surge is a timely reminder that even well-secured digital wallets can be compromised through simple techniques that exploit human behaviour and real-time payment pathways.

This was not a sophisticated cyberattack.
It was a coordinated exploitation of urgency, routine behaviour, and gaps in behavioural monitoring.

As instant payments continue to dominate Singapore’s financial landscape, ATO attacks will only grow in frequency and complexity.
Institutions that rely solely on rule-based controls or siloed fraud engines will remain vulnerable.

But those that adopt a community-driven, intelligence-rich, and AI-powered fraud defence — the Trust Layer — will move faster than the criminals, protect their customers more effectively, and uphold trust in the digital financial ecosystem.

Inside Singapore’s YouTrip Account Takeover Surge: How 21 Victims Lost Control in Seconds
Blogs
19 Nov 2025
6 min
read

BSP Proposes Tougher Penalties for Reporting Lapses: What Payment Operators Need to Know

The payments landscape in the Philippines has transformed rapidly in recent years. Digital payments now account for more than half of all retail transactions in the country, and uptake continues to grow as consumers and businesses turn to mobile wallets, online transfers, QR payments, and instant fund movements.

This shift has also brought new expectations from regulators. As digital transactions scale, the integrity of data, the accuracy of reporting, and the ability of payment system operators to maintain strong compliance controls have become non negotiable. The Bangko Sentral ng Pilipinas (BSP) has repeatedly emphasised that a safe and reliable digital payments ecosystem requires timely and accurate regulatory submissions.

This is the backdrop of the BSP’s newly proposed penalty framework for reporting lapses among payment system operators. It is a significant development. The proposal introduces daily monetary penalties for inaccurate or late submissions, along with potential non monetary sanctions for responsible officers. While the circular is still open for industry comments, its message is clear. Reporting lapses are no longer administrative oversights. They are operational weaknesses that can create systemic risk.

This blog unpacks what the proposal means, why it matters, and how financial institutions can strengthen their compliance and reporting environment in preparation for a more stringent regulatory era.

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Why BSP Is Tightening Its Penalty Framework

The Philippines payments environment has seen rapid adoption of digital technologies, driven by financial inclusion goals and customer expectations for speed and convenience. With this acceleration comes a larger volume of data that financial institutions must capture, analyse, and report to regulators.

Several factors explain why BSP is moving towards stricter penalties:

1. Reporting is foundational to systemic stability

Regulators rely on accurate data to assess risks in the payment system. Gaps, inaccuracies, or delays can compromise oversight and create blind spots in areas such as liquidity flows, settlement patterns, operational disruptions, fraud, and unusual transaction activity.

2. Growth of non bank players

Many payment functions are now driven by fintechs, payment service providers, and other non bank operators. While this innovation expands access, it also requires a higher level of supervisory vigilance.

3. Increasing use of instant payments

With real real time payment channels becoming mainstream, reporting integrity becomes more critical. A single faulty dataset can affect risk assessments across multiple institutions.

4. Rise in financial crime and operational risk

Fraud, mule activity, phishing, account takeovers, and cross border scams have all increased. Accurate reporting helps regulators track patterns and intervene quickly.

5. Alignment with data governance expectations globally

Across ASEAN and beyond, regulators are raising standards for data quality, governance, and reporting. BSP’s proposal follows this global trend.

In short, accurate reporting is no longer just compliance housekeeping. It is central to maintaining trust and stability in a digital financial system.

What the BSP’s Proposed Penalty Framework Includes

The draft circular introduces several new enforcement mechanisms that significantly raise the stakes for reporting lapses.

1. Daily monetary penalties

Instead of one time fines, penalties may accrue daily until the issue is corrected. The amounts vary by institution type:

  • Large banks: up to PHP 3,000 per day
  • Digital banks: up to PHP 2,000 per day
  • Thrift banks: up to PHP 1,500 per day
  • Rural and cooperative banks: PHP 450 per day
  • Non bank payment system operators: up to PHP 1,000 per day

These penalties apply after the first resubmission window. If the revised report still fails to meet BSP’s standards, the daily penalty starts accumulating.

2. Potential non monetary sanctions

Beyond fines, responsible directors or officers may face:

  • Suspension
  • Disqualification
  • Other administrative measures

This signals that reporting lapses are now viewed as governance failures, not just operational issues.

3. Covers accuracy, completeness, and timeliness

Reporting lapses include:

  • Late submissions
  • Incorrect data
  • Missing fields
  • Inconsistent formatting
  • Incomplete reports

BSP is emphasising the importance of end to end data integrity.

4. Applies to all payment system operators

This includes banks and non bank entities engaged in:

  • E wallets
  • Remittance services
  • Payment gateways
  • Digital payment rails
  • Card networks
  • Clearing and settlement participants

The message is clear. Every participant in the payments ecosystem has a responsibility to ensure accurate reporting.

Why Reporting Lapses Are Becoming a Serious Compliance Risk

Reporting lapses may seem minor compared to fraud, AML breaches, or cybersecurity threats. However, in a digital financial system, they can trigger serious operational and reputational consequences.

1. Reporting inaccuracies can mask suspicious patterns

Poor quality data can hide indicators of financial crime, mule activity, unusual flows, or cross channel fraud.

2. Delays affect systemic risk monitoring

In real time payments, regulators need timely data to detect anomalies and protect end users.

3. Data discrepancies create regulatory red flags

Repeated corrections or inconsistencies may suggest weak controls, insufficient oversight, or internal process failures.

4. Poor reporting signals weak operational governance

BSP views reporting as a reflection of an institution’s internal controls, risk management capability, and overall compliance culture.

5. Reputational risk for institutions

Long term credibility with regulators is tied to consistent compliance performance.

In environments like the Philippines, where digital adoption is growing quickly, institutions that fall behind on reporting standards face increasing supervisory pressure.

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How Payment Operators Can Strengthen Their Reporting Framework

To operate confidently in this environment, organisations need strong internal processes, data governance frameworks, and technology that supports accurate, timely reporting.

Here are key steps financial institutions can take.

1. Strengthen internal governance for reporting

Institutions should formalise clear roles and ownership for reporting accuracy, including:

  • Defined reporting workflows
  • Documented data lineage
  • Internal sign offs before submission
  • Review and escalation protocols
  • Consistent internal audit coverage

Treating reporting as a governance function rather than a technical task helps reduce errors.

2. Improve data quality controls

Reporting issues often stem from weak data foundations. Institutions should invest in:

  • Data validation at source
  • Automated quality checks
  • Consistency rules across systems
  • Deduplication and formatting controls
  • Stronger reconciliation processes

Accurate reporting starts with clean, validated data.

3. Reduce manual dependencies

Manual processing increases the risk of:

  • Typos
  • Formatting errors
  • Wrong values
  • Missing fields
  • Late submissions

Automation can significantly improve accuracy and speed.

4. Establish real time monitoring for data readiness

Real time payments require real time visibility. Institutions should build dashboards that track:

  • Submission deadlines
  • Pending validations
  • Data anomalies
  • Report generation status
  • Submission completeness

Proactive monitoring helps prevent last minute errors.

5. Build a reporting culture

Compliance culture is not limited to the AML or risk team. Reporting accuracy must be part of the organisation’s broader mindset.

This includes:

  • Leadership awareness
  • Cross functional coordination
  • Regular staff training
  • Internal awareness of BSP standards

A strong culture reduces repeat errors and supports sustainable compliance.

Where Technology Plays a Transformative Role

Payment operators in the Philippines face growing expectations from regulators, customers, and partners. Manual systems will struggle to keep pace with the increasing volume, speed, and complexity of payments and reporting requirements.

Advanced compliance technology offers significant advantages in this environment.

1. Automated data validation and enrichment

Technology can continuously clean, check, and normalise data, reducing errors at source.

2. Stronger reporting accuracy with AI powered checks

Modern systems detect anomalies and provide real time alerts before submission.

3. Integrated risk and reporting environment

Unified platforms reduce fragmentation, helping ensure data consistency across AML, payments, and reporting functions.

4. Faster submission cycles

Automated generation and submission reduce operational delays.

5. Lower compliance cost per transaction

Technology reduces manual dependency and improves investigator productivity.

This is where Tookitaki’s approach provides strong value to institutions in the Philippines.

How Tookitaki Helps Strengthen Reporting and Compliance in the Philippines

Tookitaki supports financial institutions through a combination of its Trust Layer, federated intelligence, and advanced compliance platform, FinCense. These capabilities help institutions reduce reporting lapses and elevate overall governance.

Importantly, several leading digital financial institutions in the Philippines already work with Tookitaki to strengthen their AML and compliance foundations. Customers like Maya and PayMongo use Tookitaki solutions to build cleaner data pipelines, enhance risk analysis, and maintain strong reporting resilience in a rapidly evolving regulatory environment.

1. FinCense improves data integrity and monitoring

FinCense provides automated data checks, risk analysis, and validation across AML, fraud, and compliance domains. This ensures that institutions operate with cleaner and more accurate datasets, which flow directly into reporting.

2. Agentic AI enhances investigation quality

Tookitaki’s AI powered investigation tools help identify inconsistencies, suspicious patterns, or data gaps early. This reduces the risk of incorrect reporting and strengthens audit readiness.

3. Better governance through the Trust Layer

Tookitaki’s Trust Layer enables consistency, transparency, and explainability across decisions and reporting. Institutions gain a clear record of how data is processed, how decisions are made, and how controls are applied.

4. Federated intelligence helps identify systemic risks

Through the AFC Ecosystem, member institutions benefit from shared insights on emerging typologies, reporting vulnerabilities, and financial crime risks. This community driven model enhances awareness and strengthens reporting standards.

5. Configurable reporting and audit tools

FinCense supports financial institutions with structured reporting exports, audit logs, and compliance dashboards that help generate accurate and complete reports aligned with regulatory expectations.

For organisations preparing for a tighter penalty regime, these capabilities help elevate reporting from reactive to proactive.

What This Regulatory Shift Means for the Future

The BSP’s proposed penalties are part of a larger trend shaping financial regulation:

1. Data governance is becoming a compliance priority

Institutions will need full visibility into where data comes from, how it is transformed, and who is responsible for each reporting field.

2. Expect more scrutiny on non banks

Fintechs and payment providers will face higher regulatory expectations as their role in the ecosystem grows.

3. Technology adoption will accelerate

Manual reporting processes will not scale. Institutions will need automation and advanced analytics to meet higher standards.

4. Reporting accuracy will influence regulatory trust

Organisations that demonstrate consistent accuracy will gain smoother interactions, fewer supervisory interventions, and more regulatory confidence.

5. Strong compliance will help drive competitive advantage

In the digital payments era, trust is a business asset. Institutions that demonstrate reliability and transparency will attract more customers and partners.

Conclusion

The BSP’s proposed penalty framework is more than a compliance update. It is a signal that the Philippines is strengthening its digital payments ecosystem and aligning financial regulation with global standards.

For payment system operators, the message is clear. Reporting lapses must be addressed through better governance, stronger data quality, and robust technology. Institutions that invest early will be better positioned to operate with confidence, reduce regulatory risk, and build long term trust with stakeholders.

Tookitaki remains committed to supporting financial institutions in the Philippines with advanced, trusted, and future ready compliance technology that strengthens reporting, reduces operational risk, and enhances governance across the payments ecosystem.

BSP Proposes Tougher Penalties for Reporting Lapses: What Payment Operators Need to Know