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What Should Fintechs Do to Ensure AML Compliance in Philippines

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Tookitaki
29 July 2022
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6 min

The Philippines is one of the largest and fast-growing economies in Southeast Asia. Its relatively young population and broad mobile network penetration have boosted the country's internet-based businesses, especially the fintech sector. It is a global hotspot for fintech and financial services today.

The Philippines has a rising number of fintech startups, while its traditional banks are launching more online services to address the needs of its internet-savvy customers. While the Philippine government has favourable policies for fintech companies, COVID-19 marked the sector's growth. The pandemic led to a surge in demand for online payment solutions. Digital payments are projected to reach $29.6 million in value this year.

However, the country's Anti-Money Laundering and Combating of Financing of Terrorism (AML/CFT) system is yet to catch up with the growth, and criminals have been exploiting the country's weaknesses to launder money. Consequently, the Philippines has been placed among The Financial Action Task Force (FATF) grey list countries.

Therefore, it is critical for fintech companies seeking a license to have a formal anti-money laundering system of internal controls. Meanwhile, existing financial institutions should work towards enhancing the effectiveness and efficiency of their AML compliance programmes.

In this article, we have picked up a few essential action items relevant to fintech companies, including payment service providers, wallet operators and crypto businesses, to ensure risk-based AML compliance. We also explain how fintech companies can fulfil AML regulatory requirements with cutting-edge solutions.

 

What Does the Regulator Say?

As part of the country's efforts to move out of the FATF grey list, the Philippine central bank, Bangko Sentral ng Pilipinas (BSP), has issued fresh guidance to all supervised financial institutions in the country on conducting institutional risk assessments (IRAs).

The BSP looks to provide financial institutions with "practicable insights" to achieve optimal results in the IRA process. It also wants the institutions to adopt a risk-based approach while designing and implementing countermeasures against money laundering, terrorist financing and proliferation financing (ML/TF/PF).

The recommendations in the guidance paper are in line with the country's anti-money laundering (AML) regulations and international standards, including the Anti-Money Laundering Act of 2001 (AMLA) and the Financial Action Task Force (FATF) standards.

This guidance is intended for all financial institutions and presents a generic, flexible approach to IRA. The BSP notes that the guidance can be tailored to the nature and complexity of a financial institution's activities and operations, including those with simple business models.

Learn More: CFT Compliance in Hong Kong

Why is IRA Important for Fintechs?

 

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  • According to the BSP, IRA is the "cornerstone of risk-based approach" to detecting and preventing ML/TF/PF and mitigating sanctions risk. The results from IRA would help develop or enrich anti-financial crime policies, systems, controls and procedures and ensure efficient and risk-focused allocation of resources.
  • The AMLA and the FATF standards require financial institutions to have a risk-based approach to preventing financial crimes. The procedures resulting from IRA would help financial institutions comply with AMLA and FATF requirements, according to the BSP. The IRA would help a fintech company in the following ways:
    • Provide a clear picture to the senior management on the ML/TF/PF and sanctions risks landscape as well as AML/CTPF control gaps and present improvement opportunities.
    • Inform remediation strategies and development or enhancements of AML/CTPF policies, systems, controls, processes and procedures.
    • Help focus on issues and concerns that present higher risks that warrant enhanced mitigation measures.
    • Use reduced preventive measures to identified low-risk areas so that unnecessary requirements are not imposed on lower-risk clients, products, and services.

 

How Can a Fintech Create an Effective IRA Process?

Here is a detailed guide on how a fintech company can create an efficient, effective and sustainable IRA process.

 

Step 1: Plan and Define the Scope of IRA

The BSP says that the prime goal of the assessment should be to identify the sources of ML/TF/PF risks and vulnerabilities. Furthermore, fintech companies must set the ambit, coverage and the covered period of the IRA and clarify if they are conducting combined or individual assessments for ML/TF/PF and sanctions risks. The other action items in this stage include:

  • Preparing a project plan with details on the involved personnel and setting milestones and timelines
  • Devising a feasible mechanism for the collection of relevant quantitative and qualitative data or information, data analysis and updating

 

Step 2: Select the Appropriate Methodology

While there is no "one-size-fits-all" approach to IRA, fintech companies should select a risk assessment methodology proportionate to the nature and complexity of their activities and operations. Accordingly, companies with complex procedures and structures may have a more detailed assessment process, while less complex companies may use a simple methodology. However, the selected method should be able to reasonably capture and analyse the company's risk and achieve the defined objectives.

 

Step 3: Identify Various ML/TF/PF Threats and Vulnerabilities

Fintech companies should try to understand the threat environment by listing known threats, such as relevant predicate offences and their proceeds. For this purpose, they need to gather information related to known or suspected threats and sectors, products or services that have been or may be exploited by criminals.

Fintechs should also identify the intrinsic or inherent risks before introducing preventive measures. Customers should be risk-scored based on the company's business relationships with them, including the products, services, and delivery channels they avail or utilise, geographic location of the customer and their transactions, new developments or technologies available to them and historical patterns of customers' transactions.

 

Step 4: Analyse ML/TF/PF or Sanctions Risks

Fintechs should conduct a thorough and informed assessment of the identified risks' nature, sources, likelihood, and consequences. The level and seriousness of each risk type should be determined in terms of their degree and relative importance or using a likelihood and impact matrix. After the analysis, the compliance team should assign a relative value or risk level for each identified risk.

 

Step 5: Evaluate Risk

Following the risk analysis, fintech companies should determine the priorities and develop strategies commensurate with the level of assessed residual risks. Depending on the level of risk appetite, the companies must employ methods such as acceptance, prevention (prohibiting certain products, services, or activities), or mitigation (or reduction).

 

Step 6: Prepare a Report for Senior Management

The risk assessment results and corresponding recommendations shall be reported to the board of directors for approval. If the fintech makes any amendments to its existing AML/CTPF policies and procedures based on the recommendations, the board should disseminate them to the concerned personnel for effective implementation.

 

Step 7: Monitor and Re-assess the IRA

Once the action plans from the IRA are implemented with proper systems and processes, fintech companies should assign the responsibility for monitoring the action plan to key personnel. The accountable staff should periodically report the functioning of the action plan to the board. The BSP recommends conducting IRAs at least every two years, depending on internal and external developments such as newly identified financial crime, changes in business operations and a spike in the volume and value of transactions and STRs.

While updating the IRA, fintech companies should also review the methods and assumptions used along with the adequacy of data, information and reports. This will ensure reasonable and meaningful results from IRA.

 

Step 8: Conduct Additional Risk Assessment for New Products/Services

When they develop new products/services and business practices, such as new delivery mechanisms and modern technologies, fintech companies should conduct additional risk assessments. They should consider the functionalities/features of the products and services and target market/customers, among others. They should be aware of risky features that allow customer anonymity, disguised ownership, concealed source of funds, large cash transactions and cross-border transactions. In case of high residual risk, they should institute additional controls, such as limits to transactions and further due diligence on transactions crossing thresholds.

 

How Can Tookitaki Help with Your AML Compliance?

With modern technologies such as artificial intelligence and machine learning at the forefront, compliance departments can address many of these issues effectively. With proper implementation, these technologies can bring in a paradigm shift in the way financial institutions approach financial crimes and compliance risk at large.

This is an area where machine learning-powered platforms like Tookitaki can add value. Our end-to-end AML/CFT analytics solution, the Anti-Money Laundering Suite (AMLS),  can create next-generation compliance programmes, encompassing key processes such as transaction monitoring, AML screening and customer AML risk scoring on a single platform.

The suite comprises our Transaction Monitoring, Dynamic Risk Review, Smart Screening and Case Management solutions under one roof for all your AML needs. AMLS achieves new levels of accuracy and speed by providing the industry's only shared typology platform, allowing our clients to break through silos and benefit from the industry's collective AML insights. Our coordinated, collaborative and innovative approach enables everyone to join forces in the fight against financial crime.

Both modern and traditional financial institutions across the globe are building agile and scalable compliance programmes using AMLS, making us a partner of choice.

Talk to our expert to learn more about our AML solution and how Tookitaki can be your partner of choice for enhancing risk-based AML compliance programmes.

 

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Blogs
03 Feb 2026
6 min
read

The Car That Never Existed: How Trust Fueled Australia’s Gumtree Scam

1. Introduction to the Scam

In December 2025, what appeared to be a series of ordinary private car sales quietly turned into one of Australia’s more telling marketplace fraud cases.

There were no phishing emails or malicious links. No fake investment apps or technical exploits. Instead, the deception unfolded through something far more familiar and trusted: online classified listings, polite conversations between buyers and sellers, and the shared enthusiasm that often surrounds rare and vintage cars.

Using Gumtree, a seller advertised a collection of highly sought-after classic vehicles. The listings looked legitimate. The descriptions were detailed. The prices were realistic, sitting just below market expectations but not low enough to feel suspicious.

Buyers engaged willingly. Conversations moved naturally from photos and specifications to ownership history and condition. The seller appeared knowledgeable, responsive, and credible. For many, this felt like a rare opportunity rather than a risky transaction.

Then came the deposits.

Small enough to feel manageable.
Large enough to signal commitment.
Framed as standard practice to secure interest amid competing buyers.

Shortly after payments were made, communication slowed. Explanations became vague. Inspections were delayed. Eventually, messages went unanswered.

By January 2026, police investigations revealed that the same seller was allegedly linked to multiple victims across state lines, with total losses running into tens of thousands of dollars. Authorities issued public appeals for additional victims, suggesting that the full scale of the activity was still emerging.

This was not an impulsive scam.
It was not built on fear or urgency.
And it did not rely on technical sophistication.

It relied on trust.

The case illustrates a growing reality in financial crime. Fraud does not always force entry. Sometimes, it is welcomed in.

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2. Anatomy of the Scam

Unlike high-velocity payment fraud or account takeover schemes, this alleged operation was slow, deliberate, and carefully structured to resemble legitimate private transactions.

Step 1: Choosing the Right Asset

Vintage and collectible vehicles were a strategic choice. These assets carry unique advantages for fraudsters:

  • High emotional appeal to buyers
  • Justification for deposits without full payment
  • Wide pricing ranges that reduce benchmarking certainty
  • Limited expectation of escrow or institutional oversight

Classic cars often sit in a grey zone between casual marketplace listings and high-value asset transfers. That ambiguity creates room for deception.

Scarcity played a central role. The rarer the car, the greater the willingness to overlook procedural gaps.

Step 2: Building Convincing Listings

The listings were not rushed or generic. They included:

  • Clear, high-quality photographs
  • Detailed technical specifications
  • Ownership or restoration narratives
  • Plausible reasons for selling

Nothing about the posts triggered immediate suspicion. They blended seamlessly with legitimate listings on the platform, reducing the likelihood of moderation flags or buyer hesitation.

This was not volume fraud.
It was precision fraud.

Step 3: Establishing Credibility Through Conversation

Victims consistently described the seller as friendly and knowledgeable. Technical questions were answered confidently. Additional photos were provided when requested. Discussions felt natural rather than scripted.

This phase mattered more than the listing itself. It transformed a transactional interaction into a relationship.

Once trust was established, the idea of securing the vehicle with a deposit felt reasonable rather than risky.

Step 4: The Deposit Request

Deposits were positioned as customary and temporary. Common justifications included:

  • Other interested buyers
  • Pending inspections
  • Time needed to arrange paperwork

The amounts were carefully calibrated. They were meaningful enough to matter, but not so large as to trigger immediate alarm.

This was not about extracting maximum value at once.
It was about ensuring compliance.

Step 5: Withdrawal and Disappearance

After deposits were transferred, behaviour changed. Responses became slower. Explanations grew inconsistent. Eventually, communication stopped entirely.

By the time victims recognised the pattern, funds had already moved beyond easy recovery.

The scam unravelled not because the story collapsed, but because victims compared experiences and realised the similarities.

3. Why This Scam Worked: The Psychology at Play

This case succeeded by exploiting everyday assumptions rather than technical vulnerabilities.

1. Familiarity Bias

Online classifieds are deeply embedded in Australian consumer behaviour. Many people have bought and sold vehicles through these platforms without issue. Familiarity creates comfort, and comfort reduces scepticism.

Fraud thrives where vigilance fades.

2. Tangibility Illusion

Physical assets feel real even when they are not. Photos, specifications, and imagined ownership create a sense of psychological possession before money changes hands.

Once ownership feels real, doubt feels irrational.

3. Incremental Commitment

The deposit model lowers resistance. Agreeing to a smaller request makes it psychologically harder to disengage later, even when concerns emerge.

Each step reinforces the previous one.

4. Absence of Pressure

Unlike aggressive scams, this scheme avoided overt coercion. There were no threats, no deadlines framed as ultimatums. The absence of pressure made the interaction feel legitimate.

Trust was not demanded.
It was cultivated.

4. The Financial Crime Lens Behind the Case

Although framed as marketplace fraud, the mechanics mirror well-documented financial crime typologies.

1. Authorised Payment Manipulation

Victims willingly transferred funds. Credentials were not compromised. Systems were not breached. Consent was engineered, a defining characteristic of authorised push payment fraud.

This places responsibility in a grey area, complicating recovery and accountability.

2. Mule-Compatible Fund Flows

Deposits were typically paid via bank transfer. Once received, funds could be quickly dispersed through:

  • Secondary accounts
  • Cash withdrawals
  • Digital wallets
  • Cross-border remittances

These flows resemble early-stage mule activity, particularly when multiple deposits converge into a single account over a short period.

3. Compression of Time and Value

The entire scheme unfolded over several weeks in late 2025. Short-duration fraud often escapes detection because monitoring systems are designed to identify prolonged anomalies rather than rapid trust exploitation.

Speed was not the weapon.
Compression was.

Had the activity continued, the next phase would likely have involved laundering and integration into the broader financial system.

ChatGPT Image Feb 2, 2026, 01_22_57 PM

5. Red Flags for Marketplaces, Banks, and Regulators

This case highlights signals that extend well beyond online classifieds.

A. Behavioural Red Flags

  • Repeated listings of high-value assets without completed handovers
  • Sellers avoiding in-person inspections or third-party verification
  • Similar narratives reused across different buyers

B. Transactional Red Flags

  • Multiple deposits from unrelated individuals into a single account
  • Rapid movement of funds after receipt
  • Payment destinations inconsistent with seller location

C. Platform Risk Indicators

  • Reuse of listing templates across different vehicles
  • High engagement but no verifiable completion of sales
  • Resistance to escrow or verified handover mechanisms

These indicators closely resemble patterns seen in mule networks, impersonation scams, and trust-based payment fraud.

6. How Tookitaki Strengthens Defences

This case reinforces why modern fraud prevention cannot remain siloed.

1. Scenario-Driven Intelligence from the AFC Ecosystem

Expert-contributed scenarios help institutions recognise patterns such as:

  • Trust-based deposit fraud
  • Short-duration impersonation schemes
  • Asset-backed deception models

These scenarios focus on behaviour, not just transaction values.

2. Behavioural Pattern Recognition

Tookitaki’s intelligence approach prioritises:

  • Repetition where uniqueness is expected
  • Consistency across supposedly independent interactions
  • Velocity mismatches between intent and behaviour

These signals often surface risk before losses escalate.

3. Cross-Domain Fraud Thinking

The same intelligence principles used to detect:

  • Account takeover
  • Authorised payment scams
  • Mule account activity

are directly applicable to marketplace-driven fraud, where deception precedes payment.

Fraud does not respect channels. Detection should not either.

7. Conclusion

The Gumtree vintage car scam is a reminder that modern fraud rarely announces itself.

Sometimes, it looks ordinary.
Sometimes, it sounds knowledgeable.
Sometimes, it feels trustworthy.

This alleged scheme succeeded not because victims were careless, but because trust was engineered patiently, credibly, and without urgency.

As fraud techniques continue to evolve, institutions must move beyond static checks and isolated monitoring. The future of prevention lies in understanding behaviour, recognising improbable patterns, and connecting intelligence across platforms, payments, and ecosystems.

Because when trust is being sold, the signal is already there.

The Car That Never Existed: How Trust Fueled Australia’s Gumtree Scam
Blogs
20 Jan 2026
6 min
read

The Illusion of Safety: How a Bond-Style Investment Scam Fooled Australian Investors

Introduction to the Case

In December 2025, Australian media reports brought attention to an alleged investment scheme that appeared, at first glance, to be conservative and well structured. Professionally worded online advertisements promoted what looked like bond-style investments, framed around stability, predictable returns, and institutional credibility.

For many investors, this did not resemble a speculative gamble. It looked measured. Familiar. Safe.

According to reporting by Australian Broadcasting Corporation, investors were allegedly lured into a fraudulent bond scheme promoted through online advertising channels, with losses believed to run into the tens of millions of dollars. The matter drew regulatory attention from the Australian Securities and Investments Commission, indicating concerns around both consumer harm and market integrity.

What makes this case particularly instructive is not only the scale of losses, but how convincingly legitimacy was constructed. There were no extravagant promises or obvious red flags at the outset. Instead, the scheme borrowed the language, tone, and visual cues of traditional fixed-income products.

It did not look like fraud.
It looked like finance.

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Anatomy of the Alleged Scheme

Step 1: The Digital Lure

The scheme reportedly began with online advertisements placed across popular digital platforms. These ads targeted individuals actively searching for investment opportunities, retirement income options, or lower-risk alternatives in volatile markets.

Rather than promoting novelty or high returns, the messaging echoed the tone of regulated investment products. References to bonds, yield stability, and capital protection helped establish credibility before any direct interaction occurred.

Trust was built before money moved.

Step 2: Constructing the Investment Narrative

Once interest was established, prospective investors were presented with materials that resembled legitimate product documentation. The alleged scheme relied heavily on familiar financial concepts, creating the impression of a structured bond offering rather than an unregulated investment.

Bonds are widely perceived as lower-risk instruments, often associated with established issuers and regulatory oversight. By adopting this framing, the scheme lowered investor scepticism and reduced the likelihood of deeper due diligence.

Confidence replaced caution.

Step 3: Fund Collection and Aggregation

Investors were then directed to transfer funds through standard banking channels. At an individual level, transactions appeared routine and consistent with normal investment subscriptions.

Funds were reportedly aggregated across accounts, allowing large volumes to build over time without immediately triggering suspicion. Rather than relying on speed, the scheme depended on repetition and steady inflows.

Scale was achieved quietly.

Step 4: Movement, Layering, or Disappearance of Funds

While full details remain subject to investigation, schemes of this nature typically involve the redistribution of funds shortly after collection. Transfers between linked accounts, rapid withdrawals, or fragmentation across multiple channels can obscure the connection between investor deposits and their eventual destination.

By the time concerns emerge, funds are often difficult to trace or recover.

Step 5: Regulatory Scrutiny

As inconsistencies surfaced and investor complaints grew, the alleged operation came under regulatory scrutiny. ASIC’s involvement suggests the issue extended beyond isolated misconduct, pointing instead to a coordinated deception with significant financial impact.

The scheme did not collapse because of a single flagged transaction.
It unravelled when the narrative stopped aligning with reality.

Why This Worked: Credibility at Scale

1. Borrowed Institutional Trust

By mirroring the structure and language of bond products, the scheme leveraged decades of trust associated with fixed-income investing. Many investors assumed regulatory safeguards existed, even when none were clearly established.

2. Familiar Digital Interfaces

Polished websites and professional advertising reduced friction and hesitation. When fraud arrives through the same channels as legitimate financial products, it feels routine rather than risky.

Legitimacy was implied, not explicitly claimed.

3. Fragmented Visibility

Different entities saw different fragments of the activity. Banks observed transfers. Advertising platforms saw engagement metrics. Investors saw product promises. Each element appeared plausible in isolation.

No single party had a complete view.

4. Gradual Scaling

Instead of sudden spikes in activity, the scheme allegedly expanded steadily. This gradual growth allowed transaction patterns to blend into evolving baselines, avoiding early detection.

Risk accumulated quietly.

The Role of Digital Advertising in Modern Investment Fraud

This case highlights how digital advertising has reshaped the investment fraud landscape.

Targeted ads allow schemes to reach specific demographics with tailored messaging. Algorithms optimise for engagement, not legitimacy. As a result, deceptive offers can scale rapidly while appearing increasingly credible.

Investor warnings and regulatory alerts often trail behind these campaigns. By the time concerns surface publicly, exposure has already spread.

Fraud no longer relies on cold calls alone.
It rides the same growth engines as legitimate finance.

ChatGPT Image Jan 20, 2026, 11_42_24 AM

The Financial Crime Lens Behind the Case

Although this case centres on investment fraud, the mechanics reflect broader financial crime trends.

1. Narrative-Led Deception

The primary tool was storytelling rather than technical complexity. Perception was shaped early, long before financial scrutiny began.

2. Payment Laundering as a Secondary Phase

Illicit activity did not start with concealment. It began with deception, with fund movement and potential laundering following once trust had already been exploited.

3. Blurring of Risk Categories

Investment scams increasingly sit at the intersection of fraud, consumer protection, and AML. Effective detection requires cross-domain intelligence rather than siloed controls.

Red Flags for Banks, Fintechs, and Regulators

Behavioural Red Flags

  • Investment inflows inconsistent with customer risk profiles
  • Time-bound investment offers signalling artificial urgency
  • Repeated transfers driven by marketing narratives rather than advisory relationships

Operational Red Flags

  • Investment products heavily promoted online without clear licensing visibility
  • Accounts behaving like collection hubs rather than custodial structures
  • Spikes in customer enquiries following advertising campaigns

Financial Red Flags

  • Aggregation of investor funds followed by rapid redistribution
  • Limited linkage between collected funds and verifiable underlying assets
  • Payment flows misaligned with stated investment operations

Individually, these indicators may appear explainable. Together, they form a pattern.

How Tookitaki Strengthens Defences

Cases like this reinforce the need for financial crime prevention that goes beyond static rules.

Scenario-Driven Intelligence

Expert-contributed scenarios help surface emerging investment fraud patterns early, even when transactions appear routine and well framed.

Behavioural Pattern Recognition

By focusing on how funds move over time, rather than isolated transaction values, behavioural inconsistencies become visible sooner.

Cross-Domain Risk Awareness

The same intelligence used to detect scam rings, mule networks, and coordinated fraud can also identify deceptive investment flows hidden behind credible narratives.

Conclusion

The alleged Australian bond-style investment scam is a reminder that modern financial crime does not always look reckless or extreme.

Sometimes, it looks conservative.
Sometimes, it promises safety.
Sometimes, it mirrors the products investors are taught to trust.

As financial crime grows more sophisticated, the challenge for institutions is clear. Detection must evolve from spotting obvious anomalies to questioning whether money is behaving as genuine investment activity should.

When the illusion of safety feels convincing, the risk is already present.

The Illusion of Safety: How a Bond-Style Investment Scam Fooled Australian Investors
Blogs
16 Jan 2026
5 min
read

AUSTRAC Has Raised the Bar: What Australia’s New AML Expectations Really Mean

When regulators publish guidance, many institutions look for timelines, grace periods, and minimum requirements.

When AUSTRAC released its latest update on AML/CTF reforms, it did something more consequential. It signalled how AML programs in Australia will be judged in practice from March 2026 onwards.

This is not a routine regulatory update. It marks a clear shift in tone and supervisory intent. For banks, fintechs, remittance providers, and other reporting entities, the message is unambiguous: AML effectiveness will now be measured by evidence, not effort.

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Why this AUSTRAC update matters now

Australia has been preparing for AML/CTF reform for several years. What sets this update apart is the regulator’s explicit clarity on expectations during implementation.

AUSTRAC recognises that:

  • Not every organisation will be perfect on day one
  • Legacy technology and operating models take time to evolve
  • Risk profiles vary significantly across sectors

But alongside this acknowledgement is a firm expectation: regulated entities must demonstrate credible, risk-based progress.

In practical terms, this means strategy documents and remediation roadmaps are no longer sufficient on their own. AUSTRAC is making it clear that supervision will focus on what has actually changed, how decisions are made, and whether risk management is improving in reality.

From AML policy to AML proof

A central theme running through the update is the shift away from policy-heavy compliance towards provable AML effectiveness.

Risk-based AML is no longer a theoretical principle. Supervisors are increasingly interested in:

  • How risks are identified and prioritised
  • Why specific controls exist
  • Whether those controls adapt as threats evolve

For Australian institutions, this represents a fundamental change. AML programs are no longer assessed simply on the presence of controls, but on the quality of judgement and evidence behind them.

Static frameworks that look strong on paper but struggle to evolve in practice are becoming harder to justify.

What AUSTRAC is really signalling to reporting entities

While the update avoids prescriptive instructions, several expectations are clear.

First, risk ownership sits squarely with the business. AML accountability cannot be fully outsourced to compliance teams or technology providers. Senior leadership is expected to understand, support, and stand behind risk decisions.

Second, progress must be demonstrable. AUSTRAC has indicated it will consider implementation plans, but only where there is visible execution and momentum behind them.

Third, risk-based judgement will be examined closely. Choosing not to mitigate a particular risk may be acceptable, but only when supported by clear reasoning, governance oversight, and documented evidence.

This reflects a maturing supervisory approach, one that places greater emphasis on accountability and decision-making discipline.

Where AML programs are likely to feel pressure

For many organisations, the reforms themselves are achievable. The greater challenge lies in operationalising expectations consistently and at scale.

A common issue is fragmented risk assessment. Enterprise-wide AML risks often fail to align cleanly with transaction monitoring logic or customer segmentation models. Controls exist, but the rationale behind them is difficult to articulate.

Another pressure point is the continued reliance on static rules. As criminal typologies evolve rapidly, especially in real-time payments and digital ecosystems, fixed thresholds struggle to keep pace.

False positives remain a persistent operational burden. High alert volumes can create an illusion of control while obscuring genuinely suspicious behaviour.

Finally, many AML programs lack a strong feedback loop. Risks are identified and issues remediated, but lessons learned are not consistently fed back into control design or detection logic.

Under AUSTRAC’s updated expectations, these gaps are likely to attract greater scrutiny.

The growing importance of continuous risk awareness

One of the most significant implications of the update is the move away from periodic, document-heavy risk assessments towards continuous risk awareness.

Financial crime threats evolve far more quickly than annual reviews can capture. AUSTRAC’s messaging reflects an expectation that institutions:

  • Monitor changing customer behaviour
  • Track emerging typologies and risk signals
  • Adjust controls proactively rather than reactively

This does not require constant system rebuilds. It requires the ability to learn from data, surface meaningful signals, and adapt intelligently.

Organisations that rely solely on manual tuning and static logic may struggle to demonstrate this level of responsiveness.

ChatGPT Image Jan 16, 2026, 12_09_48 PM

Governance is now inseparable from AML effectiveness

Technology alone will not satisfy regulatory expectations. Governance plays an equally critical role.

AUSTRAC’s update reinforces the importance of:

  • Clear documentation of risk decisions
  • Strong oversight from senior management
  • Transparent accountability structures

Well-governed AML programs can explain why certain risks are accepted, why others are prioritised, and how controls align with the organisation’s overall risk appetite. This transparency becomes essential when supervisors look beyond controls and ask why they were designed the way they were.

What AML readiness really looks like now

Under AUSTRAC’s updated regulatory posture, readiness is no longer about ticking off reform milestones. It is about building an AML capability that can withstand scrutiny in real time.

In practice, this means having:

  • Data-backed and defensible risk assessments
  • Controls that evolve alongside emerging threats
  • Reduced noise so genuine risk stands out
  • Evidence that learning feeds back into detection models
  • Governance frameworks that support informed decision-making

Institutions that demonstrate these qualities are better positioned not only for regulatory reviews, but for sustainable financial crime risk management.

Why this matters beyond compliance

AML reform is often viewed as a regulatory burden. In reality, ineffective AML programs create long-term operational and reputational risk.

High false positives drain investigative resources. Missed risks expose institutions to enforcement action and public scrutiny. Poor risk visibility undermines confidence at board and executive levels.

AUSTRAC’s update should be seen as an opportunity. It encourages a shift away from defensive compliance towards intelligent, risk-led AML programs that deliver real value to the organisation.

Tookitaki’s perspective

At Tookitaki, we view AUSTRAC’s updated expectations as a necessary evolution. Financial crime risk is dynamic, and AML programs must evolve with it.

The future of AML in Australia lies in adaptive, intelligence-led systems that learn from emerging typologies, reduce operational noise, and provide clear visibility into risk decisions. AML capabilities that evolve continuously are not only more compliant, they are more resilient.

Looking ahead to March 2026 and beyond

AUSTRAC has made its position clear. The focus now shifts to execution.

Organisations that aim only to meet minimum reform requirements may find themselves under increasing scrutiny. Those that invest in clarity, adaptability, and evidence-driven AML frameworks will be better prepared for the next phase of supervision.

In an environment where proof matters more than promises, AML readiness is defined by credibility, not perfection.

AUSTRAC Has Raised the Bar: What Australia’s New AML Expectations Really Mean