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Prospect Screening in the Digital Age: Challenges and Opportunities

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Tookitaki
18 April 2023
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6 min

In today's fast-paced and globalized financial landscape, prospect screening has become essential to every financial institution's risk management strategy. Ensuring that clients are screened thoroughly helps organizations comply with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations and reduces the likelihood of becoming involved with high-risk individuals or entities that could harm their reputation and financial stability.

The digital age has revolutionized the way financial institutions conduct business, creating both opportunities and challenges for prospect screening. The shift towards online and digital financial services has accelerated the need for financial institutions to adapt their screening processes, as they now have access to vast amounts of data and must navigate an increasingly complex regulatory landscape. While digital advancements offer new tools and techniques for effective screening, they also introduce novel risks and potential vulnerabilities that must be addressed.

This blog aims to explore the challenges and opportunities that financial institutions face in the realm of prospect screening in the digital age. We will discuss the impact of technology, evolving regulations, and the changing nature of financial crime on screening processes. Additionally, we will highlight Tookitaki's innovative solutions designed to help financial institutions streamline and enhance their prospect screening practices in this dynamic environment.

Understanding Prospect Screening

Prospect screening is the process of evaluating potential clients or customers before establishing a business relationship with them. This process helps financial institutions and other businesses assess the risk associated with a particular client, ensuring that they comply with  AML, CTF and other regulatory requirements.

Prospect screening involves conducting due diligence on potential clients by verifying their identity, checking their background, and evaluating their risk profile. This includes checking for any involvement in criminal activities, financial fraud, or connections to sanctioned individuals, organizations, or countries. The screening process may involve using various tools and databases, such as watchlists, sanction lists, and adverse media searches, to gather relevant information about the client.

By conducting thorough prospect screening, financial institutions can identify high-risk clients, prevent illicit activities, maintain compliance with relevant regulations, and safeguard their reputation and financial stability.

Real time prospect screening flow

Challenges of Prospect Screening in the Digital Age

A. Evolving regulatory landscape

The ever-changing regulatory landscape presents a significant challenge for financial institutions in the digital age. As regulators worldwide continue to tighten AML and CTF requirements, financial institutions must constantly update their prospect screening processes to ensure compliance with new rules and guidelines. This necessitates ongoing monitoring of regulatory changes and the ability to adapt screening procedures quickly and efficiently.

B. Data privacy concerns

Data privacy is a growing concern in the digital age, as financial institutions have access to vast amounts of personal information about their clients. Ensuring the proper handling, storage, and sharing of sensitive data is crucial to maintaining client trust and adhering to data protection regulations. Financial institutions must strike a balance between conducting thorough prospect screening and respecting their clients' privacy rights.

C. Cross-border complexities

The globalization of finance has led to increased cross-border transactions and partnerships, introducing additional complexities to the prospect screening process. Financial institutions must navigate diverse legal and regulatory environments while screening clients from different countries, often requiring the use of multiple data sources and languages. This can lead to inconsistencies and inefficiencies in the screening process.

D. Resource constraints

Prospect screening can be a resource-intensive process, particularly for smaller financial institutions that may lack the personnel or technology to conduct thorough and efficient screenings. As regulatory requirements continue to evolve and expand, financial institutions must allocate more resources to prospect screening, potentially diverting them from other critical business functions.

E. New risks posed by emerging technologies

Emerging technologies, such as virtual assets, cryptocurrencies, and digital payment platforms, have introduced new risks and vulnerabilities to the financial system. Criminals are increasingly exploiting these technologies to facilitate money laundering and other illicit activities, making it more challenging for financial institutions to identify and mitigate risks during the prospect screening process. Staying ahead of these emerging threats requires continuous innovation and the adoption of new screening tools and techniques.

Opportunities for Financial Institutions

A. Leveraging AI and machine learning

The advent of AI and machine learning offers significant opportunities for financial institutions to enhance their prospect screening processes. These advanced technologies can automate various aspects of the screening process, helping organizations identify patterns, anomalies, and risks more effectively. By incorporating AI-driven analytics and risk assessment tools, financial institutions can streamline their screening efforts, reduce false positives, and increase the accuracy of their risk evaluations.

B. Enhanced due diligence with digital tools

Digital tools and data sources can significantly improve the efficiency and effectiveness of due diligence efforts. Financial institutions can access real-time information to make informed decisions about potential clients by leveraging comprehensive databases, watchlists, and adverse media searches. These tools can also help organizations stay up-to-date with the latest regulatory requirements and industry best practices, ensuring they maintain robust and compliant screening processes.

C. Streamlining the onboarding process

The use of digital technologies can help financial institutions expedite the onboarding process for new clients. By automating data collection, verification, and risk assessment tasks, organizations can reduce the time and effort required to onboard new clients, enhancing the overall customer experience. Streamlined onboarding can also help financial institutions grow their customer base by minimizing delays and frustrations often associated with traditional, manual screening processes.

D. Strengthening customer relationships through effective screening

Effective prospect screening can contribute to building stronger customer relationships by demonstrating a commitment to compliance, integrity, and security. By implementing robust screening processes, financial institutions can instill trust in their clients, ensuring that they are doing business with reputable partners. A proactive approach to risk management can also help organizations minimize potential reputational damage and financial losses resulting from associations with high-risk individuals or entities.

Tookitaki's Smart Screening Solution for Prospect Screening

Tookitaki's Anti-Money Laundering Suite (AMLS) is a groundbreaking, award-winning solution that modernises compliance processes for banks and fintechs. Among its three core modules, the Smart Screening module focuses on prospect, name, and transaction screening, helping financial institutions stay ahead of financial crime risks and meet regulatory requirements.

AI-driven risk assessment and customer profiling

Tookitaki's Prospect Screening solution leverages AI-powered fuzzy identity matching to enable real-time screening capabilities for prospect onboarding. It assesses risks and profiles customers by screening them against various watchlists, including the UN sanctions lists, PEP databases, and adverse media. This AI-driven approach streamlines the screening process, reduces false positives, and assists compliance specialists in various scenarios.

Key features and benefits of Tookitaki's Prospect Screening solution

Tookitaki's AMLS Prospect Screening solution offers several key features and benefits:

  • Comprehensive watchlist coverage: The solution can screen against any number and kind of watchlists, both third-party and internal blacklists and whitelists.
  • Hybrid two-pass matching approach: Combines statistical similarity and the common key method for higher precision and recall, resulting in fewer false positivesand false negatives.
  • Full explainability: Provides complete transparency for each match, allowing financial institutions to understand and justify their screening decisions.
  • API integration: Seamlessly integrates with existing systems, streamlining the onboarding process and reducing operational costs.
  • Scalable and adaptable: Designed to grow with your organization and adapt to changing regulatory requirements and industry standards.

Adaptable to evolving regulations and industry standards

Tookitaki's AMLS Prospect Screening solution is built to adapt to the ever-changing regulatory landscape and industry standards. By continuously updating its algorithms, data sources, and methodologies, Tookitaki ensures that its solution remains compliant with the latest regulations and best practices. This adaptability empowers financial institutions to maintain robust prospect screening processes, protecting them from potential reputational damage and financial losses associated with non-compliance.

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Embracing the Digital Transformation in Prospect Screening

As the financial industry continues to evolve in the digital age, it is crucial for financial institutions to embrace digital transformation in prospect screening. By leveraging advanced technologies, financial institutions can address the challenges posed by the evolving financial crime landscape and regulatory requirements.

The continued development and adoption of advanced technologies, such as AI and machine learning will drive the future of prospect screening and compliance in the financial industry. Financial institutions will increasingly rely on these innovative solutions to mitigate risks, enhance due diligence, and keep up with changing regulatory requirements. As the industry moves forward, we can expect increased collaboration among stakeholders, greater focus on data sharing and analysis, and more robust regulatory frameworks.

Innovative solutions, such as Tookitaki's AMLS Smart Screening module, play a vital role in overcoming the challenges faced by financial institutions in prospect screening. These advanced tools enable businesses to effectively identify and manage risks, streamline processes, and improve compliance while maintaining a positive customer experience.

Tookitaki's AMLS Prospect Screening solution offers a comprehensive, adaptable, and efficient approach to prospect screening in the digital age. By leveraging AI-driven risk assessment and customer profiling, Tookitaki's solution helps financial institutions overcome the challenges of prospect screening while staying ahead of financial crime risks and regulatory requirements. We encourage financial institutions to book a demo and experience firsthand the benefits of Tookitaki's innovative prospect screening solution for their businesses.

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Blogs
15 Sep 2025
6 min
read

Fake Bonds, Real Losses: Unpacking the ANZ Premier Wealth Investment Scam

Introduction: A Promise Too Good to Be True

An email lands in an inbox. The sender looks familiar, the branding is flawless, and the offer seems almost irresistible: exclusive Kiwi bonds through ANZ Premier Wealth, safe and guaranteed at market-beating returns.

For many Australians and New Zealanders in June 2025, this was no hypothetical. The emails were real, the branding was convincing, and the investment opportunity appeared to come from one of the region’s most trusted banks.

But it was all a scam.

ANZ was forced to issue a public warning after fraudsters impersonated its Premier Wealth division, sending out fake offers for bond investments. Customers who wired money were not buying bonds — they were handing their savings directly to criminals.

This case is more than a cautionary tale. It represents a growing wave of investment scams across ASEAN and ANZ, where fraudsters weaponise trust, impersonate brands, and launder stolen funds with alarming speed.

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The Anatomy of the Scam

According to ANZ’s official notice, fraudsters:

  • Impersonated ANZ Premier Wealth staff. Scam emails carried forged ANZ branding, professional signatures, and contact details that closely mirrored legitimate channels.
  • Promoted fake bonds. Victims were promised access to Kiwi and corporate bonds, products usually seen as safe, government-linked investments.
  • Offered exclusivity. Positioning the deal as a Premier Wealth opportunity added credibility, making the offer seem both exclusive and limited.
  • Spoofed domains. Emails originated from look-alike addresses, making it difficult for the average customer to distinguish real from fake.

The scam’s elegance lay in its simplicity. There was no need for fake apps, complex phishing kits, or deepfakes. Just a trusted brand, professional language, and the lure of safety with superior returns.

Why Victims Fell for It: The Psychology at Play

Fraudsters know that logic bends under the weight of trust and urgency. This scam exploited four psychological levers:

  1. Brand Authority. ANZ is a household name. If “ANZ” says a bond is safe, who questions it?
  2. Exclusivity. By labelling it a Premier Wealth offer, the scam hinted at privileged access — only for the chosen few.
  3. Fear of Missing Out. “Limited time only” messaging pressured quick action. The less time victims had to think, the less likely they were to spot inconsistencies.
  4. Professional Presentation. Logos, formatting, even fake signatures gave the appearance of authenticity, reducing natural scepticism.

The result: even financially literate individuals were vulnerable.

ChatGPT Image Sep 13, 2025, 11_02_17 AM

The Laundering Playbook Behind the Scam

Once funds left victims’ accounts, the fraud didn’t end — it evolved into laundering. While details of this specific case remain under investigation, patterns from similar scams offer a likely playbook:

  1. Placement. Victims wired money into accounts controlled by money mules, often locals recruited under false pretences.
  2. Layering. Funds were split and moved quickly:
    • From mule accounts into shell companies posing as “investment firms.”
    • Through remittance channels across ASEAN.
    • Into cryptocurrency exchanges to break traceability.
  3. Integration. Once disguised, the money resurfaced as seemingly legitimate — in real estate, vehicles, or layered back into financial markets.

This lifecycle illustrates why investment scams are not just consumer fraud. They are also money laundering pipelines that demand the attention of compliance teams and regulators.

A Regional Epidemic

The ANZ Premier Wealth scam is part of a broader pattern sweeping ASEAN and ANZ:

  • New Zealand: The Financial Markets Authority recently warned of deepfake investment schemes featuring fake political endorsements. Victims were shown fabricated “news” videos before being directed to fraudulent platforms.
  • Australia: In Western Australia alone, more than A$10 million was lost in 2025 to celebrity-endorsement scams, many using doctored images and fabricated interviews.
  • Philippines and Cambodia: Scam centres linked to investment fraud continue to proliferate, with US sanctions targeting companies enabling their operations.

These cases underscore a single truth: investment scams are industrialising. They no longer rely on lone actors but on networks, infrastructure, and sophisticated social engineering.

Red Flags for Banks and E-Money Issuers

Financial institutions sit at the intersection of prevention. To stay ahead, they must look for red flags across transactions, customer behaviour, and KYC/CDD profiles.

1. Transaction-Level Indicators

  • Transfers to new beneficiaries described as “bond” or “investment” payments.
  • Repeated mid-value international transfers inconsistent with customer history.
  • Rapid pass-through of funds through personal or SME accounts.
  • Small initial transfers followed by large lump sums after “trust” is established.

2. KYC/CDD Risk Indicators

  • Beneficiary companies lacking investment licenses or regulator registrations.
  • Accounts controlled by individuals with no financial background receiving large investment-related flows.
  • Overlapping ownership across multiple “investment firms” with similar addresses or directors.

3. Customer Behaviour Red Flags

  • Elderly or affluent customers suddenly wiring large sums under urgency.
  • Customers unable to clearly explain the investment’s mechanics.
  • Reports of unsolicited investment opportunities delivered via email or social media.

Together, these signals create the scenarios compliance teams must be trained to detect.

Regulatory and Industry Response

ANZ’s quick warning reflects growing industry awareness, but the response must be collective.

  • ASIC and FMA: Both regulators maintain registers of licensed investments and regularly issue alerts. They stress that legitimate offers will always appear on official websites.
  • Global Coordination: Investment scams often cross borders. Victims in Australia and New Zealand may be wiring money to accounts in Southeast Asia. This makes regulatory cooperation across ASEAN and ANZ critical.
  • Consumer Education: Banks and regulators are doubling down on campaigns warning customers that if an investment looks too good to be true, it usually is.

Still, fraudsters adapt faster than awareness campaigns. Which is why technology-driven detection is essential.

How Tookitaki Strengthens Defences

Tookitaki’s solutions are designed for exactly these challenges — scams that evolve, spread, and cross borders.

1. AFC Ecosystem: Shared Intelligence

The AFC Ecosystem aggregates scenarios from global compliance experts, including typologies for investment scams, impersonation fraud, and mule networks. By sharing knowledge, institutions in Australia and New Zealand can learn from cases in the Philippines, Singapore, or beyond.

2. FinCense: Scenario-Driven Monitoring

FinCense transforms these scenarios into live detection. It can flag:

  • Victim-to-mule account flows tied to investment scams.
  • Patterns of layering through multiple personal accounts.
  • Transactions inconsistent with KYC profiles, such as pensioners wiring large “bond” payments.

3. AI Agents: Faster Investigations

Smart Disposition reduces noise by auto-summarising alerts, while FinMate acts as an AI copilot to link entities and uncover hidden relationships. Together, they help compliance teams act before scam proceeds vanish offshore.

4. The Trust Layer

Ultimately, Tookitaki provides the trust layer between institutions, customers, and regulators. By embedding collective intelligence into detection, banks and EMIs not only comply with AML rules but actively safeguard their reputations and customer trust.

Conclusion: Protecting Trust in the Age of Impersonation

The ANZ Premier Wealth impersonation scam shows that in today’s landscape, trust itself is under attack. Fraudsters no longer just exploit technical loopholes; they weaponise the credibility of established institutions to lure victims.

For banks and fintechs, this means vigilance cannot stop at transaction monitoring. It must extend to understanding scenarios, recognising behavioural red flags, and preparing for scams that look indistinguishable from legitimate offers.

For regulators, the challenge is to build stronger cross-border cooperation and accelerate detection frameworks that can keep pace with the industrialisation of fraud.

And for technology providers like Tookitaki, the mission is clear: to stay ahead of deception with intelligence that learns, adapts, and scales.

Because fake bonds may look convincing, but with the right defences, the real losses they cause can be prevented.

Fake Bonds, Real Losses: Unpacking the ANZ Premier Wealth Investment Scam
Blogs
12 Sep 2025
6 min
read

Flooded with Fraud: Unmasking the Money Trails in Philippine Infrastructure Projects

The Philippines has always lived with the threat of floods. Each typhoon season brings destruction, and the government has poured billions into flood control projects meant to shield vulnerable communities. But while citizens braced for rising waters, another kind of flood was quietly at work: a flood of fraud.

Investigations now reveal that massive chunks of the flood control budget never translated into levees, drainage systems, or protection for communities. Instead, they flowed into the hands of a handful of contractors, politicians, and middlemen.

Since 2012, just 15 contractors cornered nearly ₱100 billion in projects, roughly 20 percent of the total budget. Many projects were “ghosts,” existing only on paper. Meanwhile, luxury cars filled garages, mansions rose in gated villages, and political war chests swelled ahead of elections.

This is not simply corruption. It is a textbook case of money laundering, with ghost projects and inflated contracts acting as conduits for illicit enrichment. For banks, fintechs, and regulators, it is a flashing red signal that the financial system remains a key artery for laundering public funds.

The Anatomy of the Scandal

The Department of Public Works and Highways (DPWH) is tasked with executing infrastructure that keeps cities safe from rising waters. Yet over the past decade, its flood control program has morphed into a honey pot for collusion and fraud.

  • Ghost projects: Entire budgets released for dams, dikes, and drainage systems that were never completed or never built at all.
  • Overpriced contracts: Inflated project costs created buffers for skimming and fund diversion.
  • Kickbacks for campaigns: Portions of project budgets allegedly redirected to finance electoral campaigns, locking in loyalty between politicians and contractors.
  • Cartel behaviour: Fifteen contractors cornering nearly a fifth of the flood control budget, year after year, with suspiciously repeat awards.
  • Lavish lifestyles: Contractors flaunting their wealth through luxury cars, sprawling mansions, and overseas spending.

The human cost is chilling. While typhoon-prone communities remain flooded each year, taxpayer money meant for their protection bankrolls supercars instead of sandbags.

ChatGPT Image Sep 11, 2025, 01_08_50 PM

The Laundering Playbook Behind Ghost Projects

This scandal mirrors the familiar placement-layering-integration framework of money laundering, but applied to public funds.

  1. Placement: Ghost Projects as Entry Points
    Funds are injected into the system under the guise of legitimate project disbursements. With government contracts as a cover, illicit enrichment begins with official-looking payments.
  2. Layering: Overpricing, Subcontracting, and Round-Tripping
    Excess funds are disguised through inflated invoices, subcontractor arrangements, and consultancy contracts. Round-tripping, where money cycles through multiple accounts before returning to the same network, further conceals the origin.
  3. Integration: From Sandbags to Supercars
    Once disguised, the funds re-emerge in legitimate markets such as luxury cars, prime real estate, overseas tuition, or campaign expenses. At this stage, dirty money is fully cleaned and woven into political and economic life.

Globally, procurement-related laundering has been flagged repeatedly by the Financial Action Task Force (FATF). In fact, FATF’s 2023 mutual evaluation warned that the Philippines faces serious challenges in addressing public sector corruption risks. The flood control scandal is not just a local embarrassment; it risks pulling the country deeper into scrutiny by international watchdogs.

What Banks Must Watch

Banks sit at the centre of these laundering flows. Every contractor, subcontractor, or political beneficiary needs accounts to receive, move, and disguise illicit funds. This makes banks the first line of defence, and often the last checkpoint before illicit proceeds are fully integrated.

Transaction-Level Red Flags

  • Large and repeated deposits from government agencies into the same small group of contractors.
  • Transfers to shell subcontractors or consultancy firms with little to no delivery capacity.
  • Sudden spikes in cash withdrawals after receiving government disbursements.
  • Circular transactions between contractors and related parties, indicating round-tripping.
  • Luxury purchases such as cars, property, and overseas spending directly following government project inflows.
  • Campaign-linked transfers, with bursts of outgoing payments to political accounts during election seasons.

KYC/CDD Red Flags

  • Contractors with weak financial standing but billion-peso contracts.
  • Hidden ownership ties to politically exposed persons (PEPs).
  • Corporate overlap among multiple contractors, suggesting collusion.
  • Lack of verifiable track records in infrastructure delivery, yet repeated contract awards.

Cross-Border Concerns

Funds may also be siphoned abroad. Banks must scrutinise:

  • Remittances to offshore accounts labelled as “consultancy” or “procurement.”
  • Purchases of high-value overseas assets.
  • Trade-based laundering through manipulated import or export invoices for construction materials.

Banks must not only flag individual transactions but also connect the narrative across accounts, owners, and transaction patterns.

What BSP-Licensed E-Money Issuers Must Watch

The scandal also casts a spotlight on fintech players. BSP-licensed e-money issuers (EMIs) are increasingly part of laundering networks, especially when illicit funds need to be fragmented, hidden, or redirected.

Key risks include:

  • Wallet misuse for political finance, with illicit funds loaded into multiple wallets to bankroll campaigns.
  • Structuring, where large government disbursements are broken into smaller transfers to dodge reporting thresholds.
  • Proxy accounts, with employees or relatives of contractors opening multiple wallets to spread funds.
  • Layering via wallets, with e-money balances converted into bank transfers, prepaid cards, or even crypto exchanges.
  • Unusual bursts of wallet activity around elections or after government fund releases.

For EMIs, the challenge is to monitor not just high-value transactions but also suspicious transaction clusters, where multiple accounts show parallel spikes or transfers that defy normal spending behaviour.

How Tookitaki Strengthens Defences

Schemes like ghost projects thrive because they exploit systemic blind spots. Static rules cannot keep pace with evolving laundering tactics. This is where Tookitaki brings a sharper edge.

AFC Ecosystem: Collective Intelligence

With over 1,500 expert-contributed typologies, the AFC Ecosystem already covers procurement fraud, campaign finance laundering, and luxury asset misuse. These scenarios can be directly applied by Philippine institutions to detect anomalies tied to public fund diversion.

FinCense: Adaptive Detection

FinCense translates these scenarios into live detection rules. It can flag government-to-contractor payments followed by unusual subcontractor layering or sudden spikes in high-value asset spending. Its federated learning model ensures that detection improves continuously across the network.

AI Agents: Cutting Investigation Time

Smart Disposition reduces false positives with automated, contextual alert summaries, while FinMate acts as an AI copilot for investigators. Together, they help compliance teams trace suspicious flows faster, from government disbursements to the eventual luxury car purchase.

The Trust Layer for BSP Institutions

By embedding collective intelligence into everyday monitoring, Tookitaki becomes the trust layer between financial institutions and regulators. This helps BSP and the Anti-Money Laundering Council (AMLC) strengthen national defences against procurement-linked laundering.

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Conclusion: Beyond the Scandal

The flood control scandal is more than an exposé of wasted budgets. It is a stark reminder that public money, once stolen, does not vanish into thin air. It flows through the financial system, often right under the noses of compliance teams.

The typologies on display—ghost projects, contractor cartels, political kickbacks, and luxury laundering—are not unique to the Philippines. They are part of a global playbook of corruption-driven laundering. But in a country already under FATF scrutiny, the stakes are even higher.

For banks and EMIs, the call to action is urgent: strengthen detection, move beyond static rules, and collaborate across institutions. For regulators, it means demanding transparency, closing loopholes, and leveraging technology that learns and adapts in real time.

At Tookitaki, our role is to ensure institutions are not just reacting after scandals break but detecting patterns before they escalate. By unmasking money trails, enabling collaborative intelligence, and embedding AI-driven defences, we can prevent the next flood of fraud from drowning public trust.

Floods may be natural, but fraud floods are man-made. And unlike typhoons, this one is preventable.

Flooded with Fraud: Unmasking the Money Trails in Philippine Infrastructure Projects
Blogs
03 Sep 2025
7 min
read

How Initiatives Like AI Verify Make AI-Governance & Validation Protocols Integral to AI Deployment Strategy

Introduction: Why Governance-First AI is Rewriting the Financial Crime Playbook

This article is the second instalment in our series, Governance-First AI Strategy: The Future of Financial Crime Detection. The series examines how financial institutions can move beyond box-ticking compliance and embrace AI systems that are transparent, trustworthy, and genuinely effective against crime.

If you missed Part 1 — The AI Governance Crisis: How Compliance-First Thinking Undermines Both Innovation and Compliance — we recommend it as a pre-read. There, we explored how today’s compliance-heavy frameworks have created a paradox: soaring costs, mounting false positives, and declining effectiveness in tackling sophisticated financial crime.

In this second part, we shift from diagnosing the crisis to highlighting solutions. We look at how governance-first AI is being operationalised through initiatives like Singapore’s AI Verify program, which is setting global benchmarks for validation, accountability, and continuous trust in financial crime detection.

The Governance Gap: Moving Beyond Checkbox Compliance

Traditionally, many financial institutions have seen governance as a final-layer exercise: a set of boxes to tick just before launching a new AML system or onboarding a new AI solution. But today’s complex, AI-driven systems have outpaced this outdated approach. Here’s why this gap is so dangerous:

The Risks of Outdated Governance

  • Operational Failure: Financial institutions are reporting false positive alert rates reaching 90% or higher. Analysts spend valuable time on non-issues, while genuine risks can slip through unseen, creating an operational black hole.
  • Regulatory Exposure: Regulators are increasingly sceptical of black-box AI systems that cannot be explained or audited. This raises the risk of costly penalties, strict remediation orders, and reputational damage.
  • Stalled Innovation: The fear of non-compliance can make organisations hesitant to adopt even the most promising AI innovations, worried they will face issues during audits.

Towards Living Governance

True governance means embedding transparency, validation, and accountability across the entire AI lifecycle. This is not a static report, but a dynamic, ongoing protocol that evolves as threats and opportunities do.

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AI Verify: Singapore’s Blueprint for Independent AI Validation

Enter AI Verify: Singapore’s response to the governance challenge, and a model now being emulated worldwide. Developed by the IMDA and AI Verify Foundation, this pioneering program aims to transform governance and validation from afterthoughts into core design principles for any AI system, especially those managing financial crime risk.

Key Features of AI Verify

  • Rigorous, Scenario-Based Testing: Every AI model is evaluated against 400+ real-world financial crime detection scenarios, ensuring that outputs perform accurately across the range of complexities institutions actually face.
  • Multi-language and Cross-Border Application: With testing in both English and Mandarin, AI Verify anticipates the needs of global financial institutions with diverse customer bases and regulatory environments.
  • Zero Tolerance for Hallucinations: The program enforces strict protocols to ensure every AI-generated output is grounded in verifiable, auditable facts. This sharply reduces the risk of hallucinations, a key regulatory concern.
  • Continuous Compliance Assurance: Validation is not a single event. Ongoing monitoring, reporting, and built-in alerts ensure the AI adapts to new criminal typologies and evolving regulatory expectations.

Validation in Action: The Tookitaki Case Study

Tookitaki became the first RegTech company to achieve independent validation under Singapore’s AI Verify program, setting a new industry benchmark for governance-first AI solutions.

  • Accuracy Across Complexity: Our AI systems were validated against an extensive suite of real-world AML scenarios, consistently delivering precise, actionable outcomes in both English and Mandarin.
  • No Hallucinations: With guardrails in place, every AI-generated narrative was rigorously checked for factual soundness and traceability. Investigators and regulators were able to audit the reasoning behind each alert, turning AI from a “black box” into a transparent partner.
  • Compliance, Built-In: Stringent regulatory, privacy, and security requirements were checked throughout the process, ensuring our systems could not only pass today’s audits but also stay ahead of tomorrow’s standards.
  • Strategic Trust: As recognised by media coverage in The Straits Times, Tookitaki’s independent validation became a source of trust for clients, regulators, and business partners, transforming governance into a strategic advantage.

Continuous Validation: Governance as Daily Operational Advantage

What sets AI Verify, and governance-first models more broadly, apart is the principle of continuous validation:

  • Pre-deployment: Before launch, every model is stress-tested for robustness, fairness, and regulatory fit in a controlled, simulated real-world setting.
  • Post-deployment: Continuous monitoring ensures that as new fraud threats and compliance rules arise, the AI adapts immediately, preventing operational surprises and keeping regulator confidence high.

This approach lets financial institutions move from a reactive, firefighting mentality to a proactive, resilient operating style.

The Strategic Payoff: Governance as a Differentiator

What is the true value of independent, embedded validation?

  • Faster, Safer Innovation: Launches of new AI models become quicker and less risky, since validation is built in, not tacked on at the end.
  • Operational Efficiency: With fewer false positives and more explainable decisions, investigative teams can focus energy where it matters most: rooting out real financial crime.
  • Market Leadership: Governance-first adopters signal to clients, partners, and regulators that they take trust, transparency, and responsibility seriously, building long-term advantages in reputation and readiness.
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Conclusion: Tomorrow’s AI, Built on Governance

As we highlighted in Part 1, compliance-first frameworks have proven costly and ineffective, leaving financial institutions trapped in a cycle of escalating spend and diminishing returns. AI Verify demonstrates what a governance-first approach looks like in practice: validation, accountability, and transparency built directly into the design of AI systems.

For Tookitaki, achieving independent validation under AI Verify was not simply a compliance milestone. It was evidence that governance-first AI can deliver measurable trust, precision, and operational advantage. By embedding continuous validation, institutions can move from reactive firefighting to proactive resilience, strengthening both regulatory confidence and market reputation.

Key Takeaways from Part 2:

  1. Governance-first AI shifts the conversation from “being compliant” to “being trustworthy by design.”
  2. Continuous validation ensures models evolve with emerging financial crime typologies and regulatory expectations.
  3. Independent validation transforms governance from a cost centre into a strategic differentiator.

What’s Next in the Series

In Part 3 of our series, Governance-First AI Strategy: The Future of Financial Crime Detection, we will explore one of the most pressing risks in deploying AI for compliance: AI hallucinations. When models generate misleading or fabricated outputs, trust breaks down, both with regulators and within institutions.

We will examine why hallucinations are such a critical challenge in financial crime detection and how governance-first safeguards, including Tookitaki’s own controls, are designed to eliminate these risks and make every AI-driven decision auditable, transparent, and actionable.

Stay tuned.

How Initiatives Like AI Verify Make AI-Governance & Validation Protocols Integral to AI Deployment Strategy