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Striking Balance in Growth and AML Compliance: MAS's Recent Directive

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Tookitaki
10 August 2023
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8 min

The Monetary Authority of Singapore (MAS) has a longstanding commitment to ensuring the financial integrity of Singapore's thriving financial center. In its continuous efforts to mitigate risks associated with money laundering and terrorism financing (AML/TF), MAS regularly issues directives and guidance to financial institutions operating within the country. 

One such important directive, recently issued by the MAS, is specifically aimed at the wealth management sector - an area that has an inherently higher exposure to AML/TF risks due to factors such as client attributes, the size and complexity of transactions, and the very nature of the services provided.

This directive, codified as Circular No.: AMLD 02/2023 and released in March 2023, underscores the crucial role of financial institutions as gatekeepers in ensuring that wealth management fund flows into Singapore are legitimate. It also sets out the expectation for these institutions to remain vigilant to the evolving ML/TF risks, particularly in the context of high growth areas.

This blog post aims to delve deeper into the implications of this directive, the potential challenges that financial institutions may face, and how they can strike a successful balance between growth and compliance. Furthermore, it explores the role of technology in mitigating AML risks and how advanced Regtech solutions, such as those offered by Tookitaki, can assist in navigating this complex landscape.

The Dual Challenge of Growth and Compliance

Inherent ML/TF Risks in Wealth Management

The wealth management sector is characterised by high-value transactions, complex financial structures, and clientele that often includes high-net-worth individuals. All of these factors create an inherently higher exposure to money laundering and terrorism financing (ML/TF) risks. The sheer scale and intricacy of transactions can be exploited for illegal purposes.

Additionally, high-net-worth individuals might use complex structures or offshore entities for wealth management, which could obscure the true source of funds or beneficial ownership, thereby elevating the risk of illicit activities.

Balancing Growth and Regulatory Compliance: A Tough Act

While striving for growth, financial institutions face the daunting task of staying in line with the evolving regulatory landscape. Rapid expansion in services and clientele, especially in high growth areas, can potentially exacerbate the ML/TF risks if existing controls are not concurrently scaled and adapted. The MAS directive makes it clear that financial institutions should remain alert and actively enhance their risk controls in line with their growth trajectory.

However, this is easier said than done. As they broaden their wealth management offerings, institutions are challenged to monitor and mitigate a larger number of complex transactions without impeding the speed and efficiency of service. Further, they must remain vigilant towards higher-risk customers and transactions and constantly update and educate their Board and Senior Management about these risks.

Building a strong, robust compliance program that can handle high volume and complexity without compromising on growth ambitions is a challenge. Yet, failing to strike the right balance could lead to severe reputational damage, financial penalties, and potentially jeopardize the financial institution's license to operate.

 

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Understanding the MAS Directive

The Monetary Authority of Singapore (MAS) has made it clear in its recent directive (AMLD 02/2023) that financial institutions need to fortify their risk controls in parallel with the growth of their wealth management business. Let's delve into the directive's key points:

Strengthening Board and Senior Management (BSM) Oversight

At the helm of every financial institution, the Board and Senior Management (BSM) play a crucial role in setting the institution's tone and direction when it comes to risk management and compliance. The MAS directive emphasises the need to bolster BSM oversight, particularly for high-growth areas.

  1. The BSM should stay informed about potential ML/TF risks stemming from these areas and create a clear action plan to deal with them. It is essential for the BSM to send a strong message on the importance of risk management and maintaining a strong internal control environment.
  2. Quality assurance reviews and testing should be carried out regularly to validate the effectiveness of the institution's Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) controls. The BSM should stay updated with the results of these tests.
  3. The risk and control functions within the institution need to be adequately resourced and should have a firm grasp on changes in business strategies or customer segments. These teams are responsible for monitoring the ML/TF risk profiles of identified high-growth areas.

Enhancing Risk and Control Functions

The directive further stresses the need to enhance risk and control functions to remain abreast with the evolving risk landscape.

  1. An added review and quality assurance testing of existing Customer Due Diligence (CDD) practices in high-growth areas is encouraged to ensure that the frontline and control functions are operating effectively.
  2. If the CDD controls are found to be lacking in dealing with the risk characteristics of high-growth areas, FIs are urged to enhance their CDD practices promptly. This includes identifying higher-risk customers and corroborating the source of wealth (SOW) and source of funds (SOF) of customers.
  3. FIs are expected to stay vigilant towards higher-risk customers and transactions. This includes being aware of the additional ML/TF risks when dealing with complex legal structures used for wealth management. Due diligence is needed to understand the purpose of such structures and to identify and verify the ultimate beneficial owners (UBO).

The Need for Vigilance

The directive calls for financial institutions to maintain a high level of vigilance, especially when dealing with higher-risk customers and transactions. Institutions should be alert to unusual patterns of transactions, such as unexpected fund flows or spikes in transactions, especially those involving higher-risk jurisdictions. The MAS strongly encourages the use of data analytics to identify unusual transaction patterns and customer networks of concern.

In the subsequent section, we will discuss how technology and regtech solutions such as those offered by Tookitaki can aid financial institutions in implementing and adhering to the guidelines set out in the MAS directive.

Impact of the Directive on Financial Institutions

The directive issued by MAS brings to light certain shifts that financial institutions must make to their operations and practices. The impacts on the industry, particularly in high-growth areas and customer due diligence, are substantial.

Operations in High Growth Areas

  • Enhanced Oversight: The directive makes it clear that areas experiencing high growth should be under enhanced supervision. Financial institutions are expected to identify these areas and ensure that risk management protocols evolve in tandem with growth. This calls for a holistic review of current practices and possibly an investment in new resources to manage increased risk.
  • Increased Resources: The need for well-resourced risk and control functions as emphasized by the directive might lead to increased personnel or technology investments in these areas. Institutions may need to hire new staff or provide additional training to existing personnel. Alternatively, they may choose to invest in advanced technologies that enable more efficient risk monitoring and management.
  • Business Strategy Adjustments: The directive's focus on staying updated with changes in business strategy and target customer segments may require institutions to implement more rigorous review processes. This includes staying updated on business developments and being agile enough to respond to changes in risk profiles associated with strategic shifts.

Impact on Customer Due Diligence Practices

  • Deeper Scrutiny of Customers: As part of the enhanced Customer Due Diligence (CDD) practices, financial institutions will need to delve deeper into identifying higher risk customers. This may require more thorough checks into a customer's background, transaction history, and relationship with the institution.
  • Understanding Complex Structures: When dealing with wealth management structures such as trusts, family offices, and insurance wrappers, the institutions will need to undertake more comprehensive investigations. They will need to understand the purpose of these structures, assess the associated ML/TF risks, and identify the ultimate beneficial owners (UBO). This might require developing more comprehensive knowledge bases and may increase the time taken to onboard clients with such structures.
  • Increased Transaction Monitoring: The directive necessitates vigilance over higher-risk transactions. This includes watching out for unexpected fund flows, transaction spikes, and transactions involving higher-risk jurisdictions. This will mean enhanced transaction monitoring protocols and possibly the use of advanced data analytics to identify suspicious transaction patterns.

The Role of Technology in Mitigating AML Risks

As financial institutions navigate through the heightened demands of the new MAS directive, technology presents itself as a vital ally. The use of advanced tools and systems can make the difference between reactive compliance and proactive risk management.

Aiding Compliance and Risk Management

  • Automated Systems: Technology can automate much of the necessary compliance and risk management activities. From conducting robust customer due diligence to monitoring high-risk transactions, automated systems can significantly reduce manual workload while improving accuracy and efficiency.
  • AI and Machine Learning: The use of artificial intelligence and machine learning algorithms can enhance the detection of suspicious patterns in transactions and identify hidden risk factors. By learning from historical data and evolving in real time, these tools can provide an edge in managing complex ML/TF risks.
  • Integration and Scalability: Technological solutions allow for integration with existing systems and scalability to adapt to changes in business strategy, growth areas, and customer segments. This ensures that compliance efforts remain effective even as institutions evolve and grow.

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How Tookitaki Can Help

Tookitaki's Regtech solutions are tailor-made to address the challenges of managing ML/TF risks while complying with regulatory directives. By employing machine learning and data analytics, Tookitaki provides the necessary tools to strengthen compliance and risk management practices.

Advanced Machine Learning Capabilities

Tookitaki’s Anti-Money Laundering Suite (AML Suite) utilises machine learning to develop an in-depth understanding of each institution's unique risk landscape. By learning from historical data and adjusting to new information in real time, the software can accurately identify potential ML/TF risks and alert relevant parties.

  • Proactive Risk Management: Machine learning enables proactive risk management by identifying potential risks based on complex patterns that might be missed by manual checks. This helps in strengthening risk and control functions and ensuring that they keep pace with the growth of the wealth management business.
  • Enhanced Monitoring: AML Suite continually monitors for unusual transaction patterns and unexpected fund flows, providing an extra layer of security for financial institutions. Machine learning enhances the detection of anomalous spikes and third-party flows, assisting institutions in fulfilling the MAS directive's requirements for vigilant monitoring.

Robust Customer Due Diligence

Tookitaki’s solutions facilitate rigorous customer due diligence, aiding in the identification of high-risk customers, including those posing tax evasion and corruption-related risks.

  • Customer Screening: AML Suite's Smart Screening module detects potential matches against sanctions lists, PEPs, and other watchlists. It includes 50+ name-matching techniques and supports multiple attributes such as name, address, gender, date of birth, and date of incorporation.
  • Customer Risk Scoring: Tookitaki's Customer Risk Scoring solution is a flexible and scalable customer risk ranking program that adapts to changing customer behaviour and compliance requirements. This module creates a dynamic, 360-degree risk profile of customers.
  • Continuous Assessment: The software enables continuous assessment of customers and their activities, keeping an eye out for changes in risk profiles and providing actionable insights. This continuous monitoring is essential in the high-growth areas identified by the directive.

Through its advanced solutions, Tookitaki assists financial institutions in striking a balance between robust growth and regulatory compliance. As the MAS directive underscores the importance of vigilance in the wealth management sector, Tookitaki's Regtech solutions ensure that institutions are well-equipped to manage and mitigate potential risks.

Final Thoughts

The Monetary Authority of Singapore's directive for financial institutions to mitigate money laundering and terrorism financing (ML/TF) risks in the wealth management sector reflects the crucial balance between financial growth and regulatory compliance. Financial institutions are challenged to meet regulatory obligations while managing complex, high-value transactions typical of the wealth management industry.

Tookitaki's Regtech solutions, with advanced machine learning capabilities and robust customer due diligence features, provide the necessary support to financial institutions. They offer an effective means to manage ML/TF risks, strengthen compliance practices, and ensure that institutions can successfully balance the dual imperatives of growth and compliance. 

Understanding the regulatory landscape and the sophisticated strategies required to navigate it can be complex. That's where Tookitaki comes in. To learn more about how our machine learning-enabled AML solutions can help your institution maintain compliance while fostering growth, we encourage you to explore further.

Whether you're interested in a demo or want more information about our services, our team is available to guide you. Contact us today and discover how Tookitaki can equip you with the tools to successfully navigate your financial institutions' regulatory challenges and growth opportunities. 

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Blogs
13 Oct 2025
6 min
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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.

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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
Blogs
13 Oct 2025
6 min
read

How Collective Intelligence Can Transform AML Collaboration Across ASEAN

Financial crime in ASEAN doesn’t recognise borders — yet many of the region’s financial institutions still defend against it as if it does.

Across Southeast Asia, a wave of interconnected fraud, mule, and laundering operations is exploiting the cracks between countries, institutions, and regulatory systems. These crimes are increasingly digital, fast-moving, and transnational, moving illicit funds through a web of banks, payment apps, and remittance providers.

No single institution can see the full picture anymore. But what if they could — collectively?

That’s the promise of collective intelligence: a new model of anti-financial crime collaboration that helps banks and fintechs move from isolated detection to shared insight, from reactive controls to proactive defence.

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The Fragmented Fight Against Financial Crime

For decades, financial institutions in ASEAN have built compliance systems in silos — each operating within its own data, its own alerts, and its own definitions of risk.
Yet today’s criminals don’t operate that way.

They leverage networks. They use the same mule accounts to move money across different platforms. They exploit delays in cross-border data visibility. And they design schemes that appear harmless when viewed within one institution’s walls — but reveal clear criminal intent when seen across the ecosystem.

The result is an uneven playing field:

  • Fragmented visibility: Each bank sees only part of the customer journey.
  • Duplicated effort: Hundreds of institutions investigate similar alerts separately.
  • Delayed response: Without early warning signals from peers, detection lags behind crime.

Even with strong internal controls, compliance teams are chasing symptoms, not patterns. The fight is asymmetric — and criminals know it.

Scenario 1: The Cross-Border Money Mule Network

In 2024, regulators in Malaysia, Singapore, and the Philippines jointly uncovered a sophisticated mule network linked to online job scams.
Victims were recruited through social media posts promising part-time work, asked to “process transactions,” and unknowingly became money mules.

Funds were deposited into personal accounts in the Philippines, layered through remittance corridors into Malaysia, and cashed out via ATMs in Singapore — all within 48 hours.

Each financial institution saw only a fragment:

  • A remittance provider noticed repeated small transfers.
  • A bank saw ATM withdrawals.
  • A payment platform flagged a sudden spike in deposits.

Individually, none of these signals triggered escalation.
But collectively, they painted a clear picture of laundering activity.

This is where collective intelligence could have made the difference — if these institutions shared typologies, device fingerprints, or transaction patterns, the scheme could have been detected far earlier.

Scenario 2: The Regional Scam Syndicate

In 2025, Thai authorities dismantled a syndicate that defrauded victims across ASEAN through fake investment platforms.
Funds collected in Thailand were sent to shell firms in Cambodia and the Philippines, then layered through e-wallets linked to unlicensed payment agents in Vietnam.

Despite multiple suspicious activity reports (SARs) being filed, no single institution could connect the dots fast enough.
Each SAR told a piece of the story, but without shared context — names, merchant IDs, or recurring payment routes — the underlying network remained invisible for months.

By the time the link was established, millions had already vanished.

This case reflects a growing truth: isolation is the weakest point in financial crime defence.

Why Traditional AML Systems Fall Short

Most AML and fraud systems across ASEAN were designed for a slower era — when payments were batch-processed, customer bases were domestic, and typologies evolved over years, not weeks.

Today, they struggle against the scale and speed of digital crime. The challenges echo what community banks face elsewhere:

  • Siloed tools: Transaction monitoring, screening, and onboarding often run on separate platforms.
  • Inconsistent entity view: Fraud and AML systems assess the same customer differently.
  • Fragmented data: No single source of truth for risk or identity.
  • Reactive detection: Alerts are investigated in isolation, without the benefit of peer insights.

The result? High false positives, slow investigations, and missed cross-institutional patterns.

Criminals exploit these blind spots — shifting tactics across borders and platforms faster than detection rules can adapt.

ChatGPT Image Oct 13, 2025, 12_54_11 PM

The Case for Collective Intelligence

Collective intelligence offers a new way forward.

It’s the idea that by pooling anonymised insights, institutions can collectively detect threats no single bank could uncover alone. Instead of sharing raw data, banks and fintechs share patterns, typologies, and red flags — learning from each other’s experiences without compromising confidentiality.

In practice, this looks like:

  • A payment institution sharing a new mule typology with regional peers.
  • A bank leveraging cross-institution risk indicators to validate an alert.
  • Multiple FIs aligning detection logic against a shared set of fraud scenarios.

This model turns what used to be isolated vigilance into a networked defence mechanism.
Each participant adds intelligence that strengthens the whole ecosystem.

How ASEAN Regulators Are Encouraging Collaboration

Collaboration isn’t just an innovation — it’s becoming a regulatory expectation.

  • Singapore: MAS has called for greater intelligence-sharing through public–private partnerships and cross-border AML/CFT collaboration.
  • Philippines: BSP has partnered with industry associations like Fintech Alliance PH to develop joint typology repositories and scenario-based reporting frameworks.
  • Malaysia: BNM’s National Risk Assessment and Financial Sector Blueprint both emphasise collective resilience and information exchange between institutions.

The direction is clear — regulators are recognising that fighting financial crime is a shared responsibility.

AFC Ecosystem: Turning Collaboration into Practice

The AFC Ecosystem brings this vision to life.

It is a community-driven platform where compliance professionals, regulators, and industry experts across ASEAN share real-world financial crime scenarios and red-flag indicators in a structured, secure way.

Each month, members contribute and analyse typologies — from mule recruitment through social media to layering through trade and crypto channels — and receive actionable insights they can operationalise in their own systems.

The result is a collective intelligence engine that grows with every contribution.
When one institution detects a new laundering technique, others gain the early warning before it spreads.

This isn’t about sharing customer data — it’s about sharing knowledge.

FinCense: Turning Shared Intelligence into Detection

While the AFC Ecosystem enables the sharing of typologies and patterns, Tookitaki’s FinCense makes those insights operational.

Through its federated learning model, FinCense can ingest new typologies contributed by the community, simulate them in sandbox environments, and automatically tune thresholds and detection models.

This ensures that once a new scenario is identified within the community, every participating institution can strengthen its defences almost instantly — without sharing sensitive data or compromising privacy.

It’s a practical manifestation of collective defence, where each institution benefits from the learnings of all.

Building the Trust Layer for ASEAN’s Financial System

Trust is the cornerstone of financial stability — and it’s under pressure.
Every scam, laundering scheme, or data breach erodes the confidence that customers, regulators, and institutions place in the system.

To rebuild and sustain that trust, ASEAN’s financial ecosystem needs a new foundation — a trust layer built on shared intelligence, advanced AI, and secure collaboration.

This is where Tookitaki’s approach stands out:

  • FinCense delivers real-time, AI-powered detection across AML and fraud.
  • The AFC Ecosystem unites institutions through shared typologies and collective learning.
  • Together, they form a network of defence that grows stronger with each participant.

The vision isn’t just to comply — it’s to outsmart.
To move from isolated controls to connected intelligence.
To make financial crime not just detectable, but preventable.

Conclusion: The Future of AML in ASEAN is Collective

Financial crime has evolved into a networked enterprise — agile, cross-border, and increasingly digital. The only effective response is a networked defence, built on shared knowledge, collaborative detection, and collective intelligence.

By combining the collaborative power of the AFC Ecosystem with the analytical strength of FinCense, Tookitaki is helping financial institutions across ASEAN stay one step ahead of criminals.

When banks, fintechs, and regulators work together — not just to report but to learn collectively — financial crime loses its greatest advantage: fragmentation.

How Collective Intelligence Can Transform AML Collaboration Across ASEAN
Blogs
08 Oct 2025
6 min
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Inside the $3.5 Million Email Scam That Fooled an Australian Government Agency

In August 2025, the Australian Federal Police (AFP) uncovered a sophisticated Business Email Compromise scheme that siphoned off 3.5 million Australian dollars from a federal government agency.

The incident has stunned the public sector, revealing how one forged email can pierce layers of bureaucratic control and financial safeguards. It also exposed how vulnerable even well-governed institutions have become to cyber-enabled fraud that blends deception, precision, and human error.

For investigators, this was a major victory. For governments and corporations, it was a wake-up call.

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Background of the Scam

The fraud began with a single deceptive message. Criminals posing as an existing corporate supplier emailed the finance department of a government agency with an apparently routine request: to update the vendor’s banking details.

Everything about the message looked legitimate. The logo, email signature, writing tone, and invoice references matched prior correspondence. Without suspicion, the staff processed several large payments to the new account provided.

That account belonged to the scammer.

By the time discrepancies appeared in reconciliation reports, 3.5 million dollars had already been transferred and partially dispersed through a network of mule accounts. The AFP launched an immediate investigation, working with banks to trace and freeze what funds remained.

Within weeks, a 38-year-old man from New South Wales was arrested and charged with multiple counts of fraud. The case, part of Operation HAWKER, highlighted a surge in email impersonation scams targeting both government and private entities across Australia.

What the Case Revealed

The AFP’s investigation showed that this was not a random phishing attempt but a calculated infiltration of trust. Several insights emerged.

1. Precision Social Engineering

The perpetrator had studied the agency’s procurement process, payment cadence, and vendor language patterns. The fake emails mirrored the tone and formatting of legitimate correspondence, leaving little reason to doubt their authenticity.

2. Human Trust as a Weak Point

Rather than exploiting software vulnerabilities, the fraudsters exploited confidence and routine. The email arrived at a busy time, used an authoritative tone, and demanded urgency. It was designed to bypass logic by appealing to habit.

3. Gaps in Verification

The change in banking details was approved through email alone. No secondary confirmation, such as a phone call or secure vendor portal check, was performed. In modern finance operations, this single step remains the most common point of failure.

4. Delayed Detection

Because the transaction appeared legitimate, no automated alert was triggered. Business Email Compromise schemes often leave no digital trail until funds are gone, making recovery exceptionally difficult.

This was a crime of psychology more than technology. The fraudster never hacked a system. He hacked human behaviour.

Impact on Government and Public Sector Entities

The financial and reputational fallout was immediate.

1. Loss of Public Funds

The stolen 3.5 million dollars represented taxpayer money intended for legitimate projects. While part of it was recovered, the incident forced a broader review of how government agencies manage vendor payments.

2. Operational Disruption

Following the breach, payment workflows across several departments were temporarily suspended for review. Staff were reassigned to audit teams, delaying genuine transactions and disrupting supplier relationships.

3. Reputational Scrutiny

In a climate of transparency, even a single lapse in safeguarding public money draws intense media and political attention. The agency involved faced questions from oversight bodies and the public about how a simple email could override millions in internal controls.

4. Sector-Wide Warning

The attack exposed how Business Email Compromise has evolved from a corporate nuisance into a national governance issue. With government agencies managing vast supplier ecosystems, they have become prime targets for impersonation and payment fraud.

Lessons Learned from the Scam

The AFP’s findings offer lessons that extend far beyond this one case.

1. Verify Before You Pay

Every bank detail change should be independently verified through a trusted communication channel. A short phone call or video confirmation can prevent multi-million-dollar losses.

2. Email Is Not Identity

A familiar name or logo is no proof of authenticity. Fraudsters register look-alike domains or hijack legitimate accounts to deceive recipients.

3. Segregate Financial Duties

Dividing invoice approval and payment execution creates built-in checks. Dual approval for high-value transfers should be non-negotiable.

4. Train Continuously

Cybersecurity training must evolve with threat patterns. Staff should be familiar with red flags such as urgent tone, sudden banking changes, or secrecy clauses. Awareness converts employees from potential victims into active defenders.

5. Simulate Real Threats

Routine phishing drills and simulated payment redirection tests keep defences sharp. Detection improves dramatically when teams experience realistic scenarios.

The AFP noted that no malware or technical breach was involved. The scammer simply persuaded a person to trust the wrong email.

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The Role of Technology in Prevention

Traditional financial controls are built to detect anomalies in customer behaviour, not subtle manipulations in internal payments. Modern Business Email Compromise bypasses those defences by blending seamlessly into legitimate workflows.

To counter this new frontier of fraud, institutions need dynamic, intelligence-driven monitoring systems capable of connecting behavioural and transactional clues in real time. This is where Tookitaki’s FinCense and the AFC Ecosystem play a pivotal role.

Typology-Driven Detection

FinCense continuously evolves through typologies contributed by over 200 financial crime experts within the AFC Ecosystem. New scam patterns, including Business Email Compromise and invoice redirection, are incorporated quickly into its detection models. This ensures early identification of suspicious payment instructions before funds move out.

Agentic AI

At the heart of FinCense lies an Agentic AI framework. It analyses transactions, context, and historical data to identify unusual payment requests. Each finding is fully explainable, providing investigators with clear reasoning in natural language. This transparency reduces investigation time and builds regulator confidence.

Federated Learning

FinCense connects institutions through secure, privacy-preserving collaboration. When one organisation identifies a new fraud pattern, others benefit instantly. This shared intelligence enables industry-wide defence without compromising data security.

Smart Case Disposition

Once a suspicious event is flagged, FinCense generates automated case summaries and prioritises critical alerts for immediate human review. Investigators can act quickly on the most relevant threats, ensuring efficiency without sacrificing accuracy.

Together, these capabilities enable organisations to move from reactive investigation to proactive protection.

Moving Forward: Building a Smarter Defence

The $3.5 million case demonstrates that financial crime is no longer confined to the private sector. Public institutions, with complex payment ecosystems and high transaction volumes, are equally at risk.

The path forward requires collaboration between technology providers, regulators, and law enforcement.

1. Strengthen Human Vigilance

Human verification remains the strongest firewall. Agencies should reinforce protocols for vendor communication and empower staff to question irregular requests.

2. Embed Security by Design

Payment systems must integrate verification prompts, behavioural analytics, and anomaly detection directly into workflow software. Security should be part of process design, not an afterthought.

3. Invest in Real-Time Analytics

With payments now processed within seconds, detection must happen just as fast. Real-time transaction monitoring powered by AI can flag abnormal patterns before funds leave the account.

4. Foster Industry Collaboration

Initiatives like the AFP’s Operation HAWKER show how shared intelligence can accelerate disruption. Financial institutions, fintechs, and government bodies should exchange anonymised data to map and intercept fraud networks.

5. Rebuild Public Trust

Transparent communication about risks, response measures, and preventive steps strengthens public confidence. When agencies openly share what they have learned, others can avoid repeating the same mistakes.

Conclusion: A Lesson Written in Lost Funds

The $3.5 million scam was not an isolated lapse but a symptom of a broader challenge. In an era where every transaction is digital and every identity can be imitated, trust has become the new battleground.

A single forged email bypassed audits, cybersecurity systems, and years of institutional experience. It proved that financial crime today operates in plain sight, disguised as routine communication.

The AFP’s rapid response prevented further losses, but the lesson is larger than the recovery. Prevention must now be as intelligent and adaptive as the crime itself.

The fight against Business Email Compromise will be won not only through stronger technology but through stronger collaboration. By combining collective intelligence with AI-driven detection, the public sector can move from being a target to being a benchmark of resilience.

The scam was a costly mistake. The next one can be prevented.

Inside the $3.5 Million Email Scam That Fooled an Australian Government Agency