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Money Laundering via Cryptocurrencies: All You Need to Know

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Tookitaki
04 November 2020
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8 min

Money laundering via cryptocurrency has been going on for a while now. We’ve all heard of Bitcoin, Ethereum and Dogecoin. Crypto is used by financial criminals globally but how are they getting away with it? It’s time we lifted the lid on this crime and decoded what often sounds complicated but doesn’t have to be.

This is everything you need to know. 

What is cryptocurrency?

Simply put, Cryptocurrency is a digital or virtual currency that is protected by encryption, making counterfeiting and double-spending practically impossible. Many cryptocurrencies are built on blockchain technology, which is a distributed ledger enforced by a distributed network of computers. Cryptocurrencies are distinguished by the fact that they are not issued by any central authority, making them potentially resistant to government intervention or manipulation.

The biggest criticism Cryptocurrencies face is their use for illegal activities.

Technological advancements have given criminals faster and safer options to wash their ill-gotten money. There is no doubt that cryptocurrencies are a very useful technological innovation that helps individuals and institutions access financial products and services in a faster and cost-effective manner. However, their rise as alternative value transfer and investment tools raises money laundering concerns as well.

Banned in some countries

Cryptocurrencies are rapidly gaining popularity, but not everyone is on board, as many governments have outlawed dealing and trading in these digital tokens. While there are apparently over 5,000 known cryptocurrencies in the world today, analysts and experts are still anticipating a rapid rise in the value of Bitcoin, the world’s oldest and most valuable cryptocurrency, with only a few months left in 2021. However, while some nations, like India, are rapidly expanding their crypto markets, others, such as Russia, Morocco, Egypt and Bangladesh, are tightening down. Recently, China’s central bank has announced that all transactions of cryptocurrencies are illegal in the country.

Money laundering via crypto

While they may not be a competitor to the currency in terms of laundering volume at present, the ever-increasing use of cryptocurrency and their unregulated or less-regulated nature in many jurisdictions mean that the financial world has a lot to worry about. The same is echoed in the 2019 meeting of the G20 Finance Ministers and Central Bank Governors in Japan. “While crypto-assets do not pose a threat to global financial stability at this point, we remain vigilant to risks, including those related to consumer and investor protection, anti-money laundering and countering the financing of terrorism,” says a note from the meeting.

Crypto advisors often claim that laundering money with cryptocurrencies is highly complex and risky, making it an ineffective strategy compared to conventional techniques. They also argue that transactions in digital currencies are more transparent and accountable compared to fiat currencies. Another argument is: money laundering using cryptocurrencies is comparatively very small in terms of volume and mainstream media is focusing more on criminal activities related to digital currencies rather than technology and innovation. Albeit on a small scale, there is no doubt that cryptocurrencies are being used to facilitate money laundering.

Cryptocurrencies are slowly changing their stature as a mainstream medium of value exchange in the digital era. Many large companies now accept the digital currency for payments of products and services, and many banks consider the adoption of blockchain technology. This being said, cryptocurrency really has the potential to replace their paper and plastic variants. Therefore, it is important to analyse the loopholes enabling these currencies to be used for money laundering and to develop adequate counter technologies to combat the crime.

Some Noteworthy Numbers and Cases

According to the United Nations, between US$800 billion and US$2 trillion are being laundered every year across the globe, representing 2-5% of the global gross domestic product. Out of this, more than 90% goes undetected. The exact volume of crypto laundering is yet to be established. However, we found some indicative statistics on the Internet.

  • A report says that crypto thefts, hacks, and frauds totaled US$1.36 billion in the first five months of 2020, compared to 2019’s US$4.5 billion.
  • According to another report, criminals laundered US$2.8 billion in 2019 using crypto exchanges, compared to US$1 billion in 2018.
  • As of 2019, total bitcoin spending on the dark web was US$829 million, representing 0.5% of all bitcoin transactions.
  • A separate study, analysing more than 800 market maker exchanges, found that 56% of all crypto exchanges worldwide have weak KYC identification protocols — with exchanges in Europe, the US and the UK among the worst offenders.
  • The study noted that 60% of European Virtual Asset Service Providers have deficient KYC practices.

In October 2020, Europol announced that an unprecedented international law enforcement operation involving 16 countries had resulted in the arrest of 20 individuals who attempted to launder tens of millions of euros since 2016 on behalf of the world’s foremost cybercriminals. Operated by the notorious QQAAZZ network, the scheme involved the conversion of stolen funds into cryptocurrency using tumbling services that help hide the source of funds. In yet another incident, a man from New Zealand was arrested on money laundering, worth thousands of dollars, involving cryptocurrency.

How Do Criminals Use Cryptocurrencies for Money Laundering?

To conceal the illegitimate origin of payments, criminals use a variety of strategies involving cryptocurrency. All of these approaches rely on one or more of cryptocurrency’s flaws, such as their intrinsic pseudonymity, ease of cross-border transactions, and decentralised peer-to-peer payments. Money laundering with cryptos follows the same three-stage process as cash-based money laundering.

1. Placement

In this stage, illicit funds are brought into the financial system through intermediaries such as financial institutions, exchanges, shops and casinos. One type of cryptocurrency can be bought with cash or other cryptocurrencies. It can be done through online cryptocurrency exchanges. Criminals often use exchanges with less levels of compliance with AML regulations for this purpose.

2. Layering

In this phase, criminals obscure the illegal source of funds through structured transactions. This makes the trail of illegal funds difficult to decode. Using crypto exchanges, criminals can convert one cryptocurrency into another or can take part in an Initial Coin Offering where payment for one type of digital currency is done with another type. Criminals can also move their crypto holdings to another country.

3. Integration

Here, illegal money is put back into the economy with a clean status. One of the most common techniques of criminals is the use of over the counter (OTC) brokers who act as intermediaries between buyers and sellers of cryptocurrencies. Many OTC brokers specialise in providing money-laundering services and they get very high commission rates for this.

Crypto Mixing

Mixing services, also known as tumblers, help cryptocurrency users to conduct transactions by mixing their cryptos with other users. A typical mixing service takes cryptos from a client, sends them through a series of various addresses and then recombines them, resulting in ‘clean’ cryptos.

Peer-to-peer Crypto networks

Criminals use these decentralised networks to transmit funds to a different location, frequently in another country where there are crypto exchanges with lax anti-money laundering legislation. These exchanges assist individuals in converting cryptocurrency into fiat currency in order to purchase high-end items.

Crypto ATMs

These ATMs allow people to purchase bitcoin via credit or debit cards and in some cases by depositing cash. Some ATMs offer the facility to trade cryptocurrencies for cash as well. In many countries, the KYC measures for the use of these machines are poorly enforced.

Online Gambling

Many gambling sites accept payments in cryptocurrencies. Criminals can purchase chips with cryptos and cash them out after a few transactions.

AML Regulations Related to Cryptocurrency

To combat the use of cryptocurrency in money laundering, regulators around the world have issued laws and advice for businesses trading in digital currencies.

While some regulators have included crypto exchanges and wallet businesses in their existing anti-money laundering legislation, others have established new ones.

  • In June 2019, global AML watchdog the Financial Action Task Force (FATF) published its guidance for virtual assets and virtual asset service providers (VASP). “The FATF strengthened its standards to clarify the application of anti-money laundering and counter-terrorist financing requirements on virtual assets and virtual asset service providers. According to the FATF, countries must now examine and minimise the risks associated with virtual asset financial operations and providers, as well as licence or register providers and subject them to supervision or monitoring by competent national authorities.
  • The Monetary Authority of Singapore (MAS)’s Payment Services Act mandated that crypto businesses operating in the country should obtain a license to comply with AML regulations. In July 2020, the MAS proposed another set of regulations to control the cryptocurrency industry in the country. The European Union (EU) has recently adopted the Fifth Anti-Money Laundering Directive (AMLD5) which require crypto exchanges and custodial service providers to register with their local regulator and be compliant with know-your-customer (KYC) and anti-money laundering AML procedures. In the US, the Financial Crimes Enforcement Network (FinCEN) regulates Money Services Businesses (MSBs) under the Bank Secrecy Act.
  • In 2013, FinCEN issued guidance that stated a virtual currency exchange and an administrator of a centralised repository of virtual currency with authority to issue and redeem the currency to be considered as MSBs.
  • Canada became the first country to approve regulation of cryptocurrency in the case of anti-money laundering in 2014, passed by the Parliament of Canada under Bill C-31. The bill aims to amend Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act to include Canadian cryptocurrency exchange. It has laid out the framework for regulating entities dealing in digital currencies, treating the currencies as money service businesses (MSBs).

 

How Can Crypto MSBs Ensure AML Compliance?

While regulators can issue guidance and norms, the onus is on MSBs to implement them. They need to have a well-designed AML compliance programme. This should be a well-balanced combination of compliance personal and technology. Having an in-house compliance team may be feasible only for large MSBs. However, the same is usually very expensive and impractical for smaller firms. They would have to rely more on highly intelligent process automation tools and platforms to sift out illegitimate transactions from large data sets.

There should be proper tools to verify the identity of people who transact in cryptocurrencies. They should be able to match and relate blockchain transactions with real identities, creating an end-to-end trail to help with AML investigations. Transaction monitoring tools that dig out suspicious patterns for further investigations are also essential for the AML compliance programmes of crypto MSBs.

The Relevance of Tookitaki Typology Repository in the Crypto World

Tookitaki developed a first-of-its-kind Typology Repository Management (TRM) framework to effectively solve the shortcomings of the present AML transaction monitoring environment. Tookitaki is a provider of proven and in-deployment AML solutions for major and small financial institutions. Through collective intelligence and continual learning, TRM is a novel means of identifying money laundering. Financial institutions will be able to capture shifting customer behaviour and stop bad actors with high accuracy and speed using this advanced machine learning approach, enhancing returns and risk coverage. It detects suspicious cases and prioritises notifications with high accuracy without requiring any personal information.

Tookitaki used the technique to successfully combat money laundering related to cryptocurrencies. We built a TRM-based solution for bitcoin AML compliance as part of the G20TechSprint challenge, a hackathon-style competition jointly organised by the Bank for International Settlements (BIS) and the Saudi G20 Presidency. In the category of monitoring and surveillance, the same team came out on top. Our technology could detect money laundering cases employing cryptocurrency via crypto-exchanges or their connection with banks because TRM can be scaled to cover any type of typologies spanning products, places, tactics, and predicate crime for the purpose of locating cryptocurrency-related funds.

To discover our AML solution and its unique features, request a demo here. 

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Blogs
02 Dec 2025
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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
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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.

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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