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Solving crimes in the financial landscape: A Q&A with Tookitaki

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Tookitaki
05 January 2023
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12 min

“REDEFINING financial crime compliance to make the world a better place.”

Following the company’s motto, Tookitaki’s initiative of breaking silos and providing a platform to collaborate and fight financial crime, the company expanded their business in the Philippine market to bring scalable and machine learning-powered product offerings to help financial institutions address money laundering risks.

Tookitaki (a Thunes company) is a regulatory technology company offering financial crime detection and prevention solutions to some of the world’s leading banks and fintech companies to help them transform their anti-money laundering (AML) and compliance technology needs.

Founded in November 2014, the company employs over 100 people across the US, the UK, Singapore, Taiwan, Indonesia, the Philippines, and the UAE.

To know more about Tookitaki and its approach in providing end-to-end financial crime solutions to some of the world’s leading financial institutions, BusinessWorld reached out to Tookitaki’s Chief Executive Officer and founder Abhishek Chatterjee to share his thoughts and insights. Below is the excerpt of the interview:

Please introduce us to Tookitaki. What are your visions and goals?

Mr. Chatterjee: Headquartered in Singapore, Tookitaki provides end-to-end financial crime solutions to some of the world’s leading financial institutions. In the ASEAN region, some of the largest banks and fintech companies rely on Tookitaki to transform their AML compliance needs. Tookitaki was founded in November 2014 and employs over 100 employees across our offices in Asia, Europe, and the US.

Fighting financial crime needs to be a collective effort through centralized intelligence-gathering. Aimed at breaking silos, the AFC (anti-financial crime) Ecosystem, includes a network of experts and provides a platform for the experts to create a knowledge base to share financial crime scenarios.

This collective intelligence is the ability of a large group of AFC experts to pool their knowledge, data, and skills to tackle complex problems related to financial crime and pursue innovative ideas.

The AFC ecosystem is a game changer since it helps remove the information vacuum created by siloed operations. Our network of experts includes risk advisers, legal firms, AFC specialists, consultancies, and financial institutions from across the globe.

Tookitaki’s AML Suite (AMLS) is an operating system comprising four modules, such as transaction monitoring, smart screening, customer risk scoring, and the Case Manager, under one roof to address our customers’ compliance requirements. It provides holistic risk coverage, sharper detection, and significantly fewer false alerts. It can be deployed in multiple environments including the public cloud, private cloud, and data center.

The AFC Ecosystem and the AMLS work in tandem and help our stakeholders widen their view of risk from an internal one to an industry-wide one across organizations and borders. Moreover, they can do so without compromising privacy and security.

Tookitaki means to hide and seek in Bengali. The name perfectly articulates our intention to uncover the hide-and-seek nature of financial crime with artificial intelligence.

Today, Tookitaki (A Thunes company) is leading AML initiatives in most of the key digital banks in Asia. One of the largest digital banks in the Philippines, one of the world’s largest fintech and payment companies headquartered in China, one of Asia’s largest digital banks based out of Singapore, and one of the fastest-growing crypto wallets based out of Asia.

Tookitaki’s innovations in regulatory compliance have been acknowledged worldwide. Chartis Research named the company a Rising Star in its 2021 RiskTech 100 report. In 2020, the company won the Regulation Asia Awards for Excellence and G20TechSprint accelerator. In 2019, the company was featured in the World Economic Forum’s Technology Pioneer List.

 

What products and services do you plan to offer in the local market, and how would you differentiate Tookitaki from other vendors providing AML compliance solutions? What makes it “innovative” in addressing a regulatory or market need?

Mr. Chatterjee: At Tookitaki, we have always believed that technology is for the greater good. The AFC Ecosystem is a community-driven first of its kind initiative aimed at breaking silos and providing a platform to collaborate and fight financial crime. The AFC Ecosystem’s single motto is to break silos and provide a platform where AFC experts across the globe can use their knowledge and expertise to build a safer society.

The AFC Ecosystem is a game changer since it helps remove the information vacuum created by siloed operations. Our network of experts includes risk advisers, legal firms, AFC specialists, consultancies, and financial institutions from across the globe.

Underpinning it is a valued partnership program that is mutually beneficial for all stakeholders engaged in reducing the laundering of illicit proceeds of crime and terrorism.

Tookitaki’s offerings in the Philippines primarily include the AFC Ecosystem and the AMLS.

Our community comprises of experts covering the entire spectrum of money laundering: placement, layering, and integration. They include Financial Crime Compliance (FCC), law enforcement, and nongovernment organizations to name a few who are all giants in their own right. With this diverse community approach, financial institutions, who are the first line of defense, are empowered to identify “dirty money” patterns that aren’t easily discoverable. Operationalizing this collective intelligence results in the creation of more comprehensive risk policies.

Tookitaki’s AMLS covers the entire customer onboarding and ongoing processes through its transaction monitoring, smart screening, customer risk scoring, and the case manager. Together they provide holistic risk coverage, sharper detection, and significant effort reduction in managing false alerts. It is uniquely designed to complement existing systems by cutting through the noise and clutter generated by large volumes of alerts in legacy transaction monitoring processes.

For our customers like traditional banks and fintech companies, an extensive understanding of their consumers is a must for effective and comprehensive risk policies. The AMLS is a product that enables this through the combination of its Intelligent Alert Detection (IAD) for detection and prevention along with its Smart Alert Management (SAM) for Management.

With technology touching every facet of society, money mules and fraudulent accounts are a growing problem that needs to be addressed to assist in the country’s efforts to prevent financial crime, notably in the government sector. Tookitaki aims to improve the honesty of the Philippines’ financial market by providing comprehensive AML compliance programs for fintech companies, which include payment service providers, e-wallet providers, and virtual asset service providers.

Please elaborate more on Tookitaki’s Anti-Money Laundering Suite or AMLS and how it would apply to banks.

Mr. Chatterjee: Tookitaki’s AMLS covers the entire customer onboarding and ongoing processes through transaction monitoring, smart screening, customer risk scoring and the case manager. Together they provide holistic risk coverage, sharper detection, and significant effort reduction in managing false alerts. It is uniquely designed to complement existing systems by cutting through the noise and clutter generated by large volumes of alerts in legacy transaction monitoring processes.

As mentioned earlier, our AMLS has two main functionalities: IAD and SAM.

The SAM functionality of AMLS specifically helps banks with:

• management and filtering of false alerts

• ease of integration into their current process governance

• operational guidance from past learnings with other banks

Based on our previous customer case studies, we can say that when customers start using the SAM module, they can expect a RoI (return of investment) in approximately nine months and along with that we deliver a superior experience via:

Operational efficiency through alert prioritization

SAM across transaction monitoring and screening helps in automated triaging and helps categorize all alerts into three risk levels: L1 (Low risk), L2 (Moderate risk), and L3 (High risk).

Hence, as part of the alert handling/treatment process, there is no requirement for manual triaging since all alerts have been triaged by SAM into the aforementioned risk levels.

Faster time to market

SAM automatically builds a machine learning (ML) model that trains on customer data. The model result aligns with customer risk policy and data instead of a generic industry ML solution. The in-built Intelligent risk indicator framework automatically generates thousands of risk indicators (data science features) from input data.

An intelligent model learning framework then selects the most relevant risk indicators and chooses the right hyper-parameters to tune the model to achieve high accuracy at optimal compute cost. This is a fully automated process that requires minimal data science effort from the client team.

Continuous improvement

Through our Champion-Challenger which learns from investigator feedback and changing data, continuous improvement occurs systematically. It takes in incremental data, which includes new customers, accounts, transactions, and the latest investigator feedback, and provides consistent results through continuous learning.

Ease of integration into the current process governance

The module integrates seamlessly with the existing systems as well as the primary using standardized data models and ready adapters. Investigators can still use the existing workflow and click on the link to access alert information. This makes it easier to investigate and dispose of alerts faster.

Apart from AML solutions, what other financial crimes does Tookitaki solve?

Mr. Chatterjee: Tookitaki believes in giving back to society. We are on a mission to improve lives by tackling money laundering.

Crimes such as human trafficking, drug trafficking, illegal arms deals, and many more are tied to money laundering. Vulnerable people are being affected daily by this corruption. We offer resources, information, and a strong commitment to helping eliminate money laundering and related crimes.

We have worked closely with the survivors of human trafficking to understand the patterns of behavior around these heinous crimes and determine how we can help tackle them. Our work in this endeavor is driven by a responsibility to help make the world a safer place for everyone.

We believe in using technology for the greater good. We want to lead from the front, where crimes such as trafficking and terrorism can be eliminated via the prevention of financial crime.

What are the factors you considered in choosing the Philippines to launch an AML software tool?

Mr. Chatterjee: With the rise of technology, the world is slowly shifting to cashless transactions. According to a study from 2020-2025, cashless transactions are expected to increase by 80% and cross border payments will be valued at $156 trillion. This borderless transaction increases money laundering crimes and allows money launderers to hide in plain sight undetected.

In the Philippines, half of Filipinos own a financial account, as more Filipinos become part of the banking system, financial crimes will become more advanced. Financial institutions need to look beyond traditional tools to solve a sophisticated and growing problem to keep pace with increasing business and regulatory requirements.

The Philippines is in a strategic position because of its rising economy and being the center of international trade and traffic makes it vulnerable to a host of financial crimes and financial terrorism. Moreover, the growing number of money transfers sent by overseas Filipino workers to their loved ones adds to the responsibility of the AMLS.

Do you have data on cases of money laundering in the country?

Mr. Chatterjee: The Anti Money Laundering Report states that the country has always been vulnerable when it comes to money laundering and financial terrorism. It is vital that the country address the growing problem.

What we’ve noticed is that the political landscape in the Philippines is ever-changing. In 2000, the Philippines was placed under the Financial Action Task Force (FATF), falling under its list of Non-Cooperative Countries and Territories due to lack of basic AML frameworks.

The Philippine government enacted Republic Act (RA) 9160 of the Anti-Money Laundering Act of 2001, which preserved the integrity of bank accounts and ensured the Philippines does not become a haven for money laundering activities. As an added precaution, Philippine authorities will assist in transnational investigations to prosecute those found who are found guilty. Since then, in recent years, various laws have amended RA 9160 and various industries involving finances have been added to the existing laws as well as harsher sanctions for those found guilty of money laundering activities. Additional powers were also granted to the Anti-Money Laundering Council and other concerned persons.

The Philippines has returned to the “gray list” as of June 2021. The FATF has commended the country for its continuing efforts to eradicate the threats of money laundering and encourage the country to further strengthen its measures. And we as a trusted partner are pleased to assist the Philippine government with its goal of eradicating and eliminating financial terrorism, no country in the world should be a safe haven for criminals.

Financial institutions are inundated with voluminous false positives and case backlogs that add to costs and prevent them from filtering out high-quality alerts. How does your solution help address this problem?

Mr. Chatterjee: Tookitaki was a pioneer in identifying the use case of ML in AML compliance and our ideas came into reality with our historic partnership with the United Overseas Bank Ltd. (UOB) in Singapore.

In December 2020, we became the first in the Asia-Pacific region to deploy a complete AML solution leveraging ML in production concurrently in transaction monitoring and name screening.

The SAM functionality of AMLS specifically helped with management and filtering of false alerts that eliminated the need for manual triaging since all alerts get triaged by SAM as per categorized risk levels, such as low, medium, and high. Ease of integration into their current process governance thereby making it easier for the investigators to investigate and dispose of alerts faster.

As a result, UOB witnessed 70% reduction in false positives for individual names and 60% reduction in false positives for corporate names. The solution also helped with a 50% reduction in false positives with less than 1% misclassification and 5% increase in fileable suspicious activity reports.

This is yet another example of how Tookitaki sets new standards for the regulatory compliance industry’s fight against money laundering.

We have partnered with well-known fintech companies in the Philippines to assist local companies to stay on top of their compliance requirements and we hope to expand our partnership with even more fintech companies in the future.

What do you think are the biggest risks faced by banks being used for money laundering and how do you plan to mitigate or eliminate these risks?

Mr. Chatterjee: Banks need to have a holistic view of money laundering risks and the threat scape across various banking segments such as corporate, retail, and private. Existing static and granular rules-based approaches, which are oblivious to the holistic trend with a narrow and uni-dimensional focus, are not capable of doing the same. Existing rules-based systems produced a significant volume of false positives. These false leads are a drain on productivity as they take significant time and resources to be disposed of. In the AML compliance space, banks are wasting more $3.5 billion per year chasing false leads because of outdated AML systems that rely on stale rules and scenarios and generate millions of false positives, according to research.

Undoubtedly, using limited resources to close off non-material and unimportant alerts is manual and onerous, resulting in huge backlogs for both processes and missed/delayed suspicious activity report filings. Furthermore, the ballooning costs of AML compliance coupled with the high volume of backlog alerts swamp compliance teams and potentially distract them from “true” high-risk events and customer circumstances.

Alert investigation becomes a time-consuming and labor-intensive affair as the compliance team spends significant time gathering data and analyzing it to differentiate illegitimate activities from legitimate ones. Disparate data sources and highly complex business processes add to the difficulty of the investigation team in analyzing the links between parties and transactions.

As mentioned earlier, Tookitaki’s AMLS includes transaction monitoring, smart screening, customer risk scoring, and case management, a centralized investigation solution.

Transaction monitoring looks for suspicious transactions across different systems. It unlocks the power of Tookitaki’s library of typologies to detect hidden suspicious patterns.

Tookitaki’s AMLS generates fewer alerts of higher quality and then segregates them into low, medium, or high-risk alerts so companies can prioritize their investigations. The AMLS also updates regularly to include new money laundering patterns.

Smart screening watches out for high-risk individuals and corporate customers. Tookitaki designed the name screening module to handle a wider range of complex name permutations. To reduce the number of undetermined hits, Tookitaki enriched the module with inference features and additional customer profile identifiers. Tookitaki’s name screening module also reduces false positives, which happens when AML software incorrectly flags a customer as high-risk.

The Customer Risk Scoring module empowers banks in reducing their cost of compliance by providing an actual consumer view. This is backed by dynamic risk assessment that is self-evolving based on consumers’ new financial patterns.

ML models, too, benefit AFC ecosystems. For one, it increases effectiveness in identifying suspicious activities due to its sharper focus on data anomalies rather than threshold triggering. ML models also allow for easier customization of data features to accurately target specific risks, as well as enable extended look-back periods to detect more complex scenarios.

Any other insights you’d like to share?

Mr. Chatterjee: The AFC Ecosystem is now live, which means it is now open to the broader public. The ecosystem has grown considerably over the past few months owing to the active contribution by the experts. The AFC Ecosystem is a strong testament to how technology contributes to the critical mission of helping financial services combat crime and the financing of terrorism. With the ecosystem being open to the public, an AFC Honoree Badge Program has been launched because we believe that together we can make a difference.

(As appeared on Business World)

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Beyond Digital Transfers: The New Playbook of Cross-Border Investment Fraud

In February 2026, the Singapore Police Force arrested a 41-year-old Malaysian national for his suspected involvement in facilitating an investment scam syndicate. Unlike conventional online fraud cases that rely purely on digital transfers, this case reportedly involved the physical collection of cash, gold, and valuables from victims across Singapore.

At first glance, it may appear to be another enforcement headline in a long list of scam-related arrests. But this case reflects something more structural. It signals an evolution in how organised investment fraud networks operate across borders and how they are deliberately reducing digital footprints to evade detection.

For financial institutions, this is not merely a criminal story. It is a warning about the next phase of scam typologies.

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A Familiar Beginning: Digital Grooming and Fabricated Returns

Investment scams typically begin in digital environments. Victims are approached via messaging applications, social media platforms, or dating channels. Fraudsters pose as successful investors, insiders, or professional advisers offering exclusive access to high-yield opportunities.

The grooming process is methodical. Screenshots of fake trading profits are shared. Demo withdrawals are permitted to build credibility. Fabricated dashboards simulate real-time market activity.

Victims are gradually encouraged to increase their investment amounts. By the time suspicion arises, emotional and financial commitment is already significant.

What differentiates the February 2026 case is what happened next.

The Hybrid Shift: From Online Transfers to Physical Collection

As transaction monitoring systems become more sophisticated, fraud syndicates are adapting. Rather than relying exclusively on bank transfers into mule accounts, this network allegedly deployed a physical collector.

Cash, gold bars, and high-value jewellery were reportedly collected directly from victims.

This tactic serves multiple purposes:

  • It reduces immediate digital traceability.
  • It avoids automated suspicious transaction triggers.
  • It delays AML detection cycles.
  • It complicates asset recovery efforts.

Physical collection reintroduces an older money laundering technique into modern scam operations. The innovation is not technological. It is strategic.

Why Cross-Border Facilitators Matter

The involvement of a Malaysian national operating in Singapore underscores the cross-border architecture of contemporary investment fraud.

Using foreign facilitators provides operational advantages:

  1. Reduced long-term financial footprint within the victim jurisdiction.
  2. Faster entry and exit mobility.
  3. Compartmentalisation of roles within the syndicate.
  4. Limited exposure to digital transaction histories.

Collectors often function as intermediaries with minimal visibility into the full structure of the scam. They are paid per assignment and insulated from the digital backend of fraudulent platforms.

This decentralised model mirrors money mule networks, where each participant handles only one fragment of the laundering chain.

The Laundering Layer: What Happens After Collection

Physical collection does not eliminate the need for financial system re-entry. Funds and valuables must eventually be monetised.

Common laundering pathways include:

  • Structured cash deposits across multiple accounts.
  • Conversion of gold into resale proceeds.
  • Transfers via cross-border remittance channels.
  • Use of third-party mule accounts for layering.
  • Conversion into digital assets before onward transfer.

By introducing time delays between collection and deposit, criminals weaken behavioural linkages that monitoring systems rely upon.

The fragmentation is deliberate.

Enforcement Is Strengthening — But It Is Reactive

Singapore has progressively tightened its anti-scam framework in recent years. Enhanced penalties, closer collaboration between banks and telcos, and proactive account freezing mechanisms reflect a robust enforcement posture.

The February 2026 arrest reinforces that law enforcement is active and responsive.

However, enforcement occurs after victimisation.

The critical compliance question is whether financial institutions could have identified earlier signals before physical handovers occurred.

Early Signals Financial Institutions Should Watch For

Even hybrid scam models leave footprints.

Transaction-Level Indicators

  • Sudden liquidation of savings instruments.
  • Large ATM withdrawals inconsistent with historical patterns.
  • Structured withdrawals below reporting thresholds.
  • Rapid increase in daily withdrawal limits.
  • Transfers to newly added high-risk payees.

Behavioural Indicators

  • Customers expressing urgency tied to investment deadlines.
  • Emotional distress or secrecy during branch interactions.
  • Resistance to fraud advisories.
  • Repeated interactions with unfamiliar individuals during transactions.

KYC and Risk Signals

  • Cross-border travel inconsistent with employment profile.
  • Linkages to previously flagged mule accounts.
  • Accounts newly activated after dormancy.

Individually, these signals may appear benign. Collectively, they form patterns.

Detection capability increasingly depends on contextual correlation rather than isolated rule triggers.

ChatGPT Image Feb 23, 2026, 04_50_04 PM

Why Investment Fraud Is Becoming Hybrid

The return to physical collection reflects a calculated response to digital oversight.

As financial institutions deploy real-time transaction monitoring and network analytics, syndicates diversify operational channels. They blend:

  • Digital grooming.
  • Offline asset collection.
  • Cross-border facilitation.
  • Structured re-entry into the banking system.

The objective is to distribute risk and dilute visibility.

Hybridisation complicates traditional AML frameworks that were designed primarily around digital flows.

The Cross-Border Risk Environment

The Malaysia–Singapore corridor is characterised by high economic interconnectivity. Labour mobility, trade, tourism, and remittance activity create dense transactional ecosystems.

Such environments provide natural cover for illicit movement.

Short-duration travel combined with asset collection reduces detection exposure. Funds can be transported, converted, or layered outside the primary victim jurisdiction before authorities intervene.

Financial institutions must therefore expand risk assessment models beyond domestic parameters. Cross-border clustering, network graph analytics, and federated intelligence become essential tools.

Strategic Lessons for Compliance Leaders

This case highlights five structural imperatives:

  1. Integrate behavioural analytics with transaction monitoring.
  2. Enhance mule network detection using graph-based modelling.
  3. Monitor structured cash activity alongside digital flows.
  4. Incorporate cross-border risk scoring into alert prioritisation.
  5. Continuously update detection scenarios to reflect emerging typologies.

Static rule sets struggle against adaptive syndicates. Scenario-driven frameworks provide greater resilience.

The Compliance Technology Imperative

Hybrid fraud requires hybrid detection.

Modern AML systems must incorporate:

  • Real-time anomaly detection.
  • Dynamic risk scoring.
  • Scenario-based monitoring models.
  • Network-level clustering.
  • Adaptive learning mechanisms.

The objective is not merely faster alert generation. It is earlier risk identification.

Community-driven intelligence models, where financial institutions contribute and consume emerging typologies, strengthen collective defence. Platforms like Tookitaki’s FinCense, supported by the AFC Ecosystem’s collaborative framework, apply federated learning to continuously update detection logic across institutions. This approach enables earlier recognition of evolving investment scam patterns while reducing investigation time by up to 50 percent.

The focus is prevention, not post-incident reporting.

A Broader Reflection on Financial Crime in 2026

The February 2026 Malaysia–Singapore arrest illustrates a broader reality.

Investment fraud is no longer confined to fake trading apps and mule accounts. It is adaptive, decentralised, and cross-border by design. Physical collection represents not regression but optimisation.

Criminal networks are refining risk management strategies of their own.

For banks and fintechs, the response cannot be incremental. Detection must anticipate adaptation.

Conclusion: The Next Phase of Investment Fraud

Beyond digital transfers lies a more complex fraud architecture.

The February 2026 arrest demonstrates how syndicates blend online deception with offline collection and cross-border facilitation. Each layer is designed to fragment visibility.

Enforcement agencies will continue to dismantle networks. But financial institutions sit at the earliest detection points.

The institutions that succeed will be those that move from reactive compliance to predictive intelligence.

Investment scams are evolving.

So must the systems built to stop them.

Beyond Digital Transfers: The New Playbook of Cross-Border Investment Fraud
Blogs
23 Feb 2026
6 min
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The Great AML Reset: Why New Zealand’s 2026 Reforms Change Everything

New Zealand is not making a routine regulatory adjustment.

It is restructuring its anti-money laundering and countering financing of terrorism framework in a way that will redefine supervision, compliance expectations, and enforcement outcomes.

With the release of the new National AML/CFT Strategy by the Ministry of Justice and deeper industry analysis from FinCrime Central, one thing is clear: 2026 will mark a decisive turning point in how AML supervision operates in New Zealand.

For banks, fintechs, payment institutions, and reporting entities, this is not just a policy refresh.

It is a structural reset.

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Why New Zealand Is Reforming Its AML Framework

New Zealand’s AML/CFT Act has long operated under a multi-supervisor model. Depending on the type of reporting entity, oversight was split between different regulators.

While the framework ensured coverage, it also created:

  • Variations in interpretation
  • Differences in supervisory approach
  • Inconsistent guidance across sectors
  • Added complexity for multi-sector institutions

The new strategy seeks to resolve these challenges by improving clarity, accountability, and effectiveness.

At its core, the reform is built around three objectives:

  1. Strengthen the fight against serious and organised crime.
  2. Reduce unnecessary compliance burdens for lower-risk businesses.
  3. Improve consistency and coordination in supervision.

This approach aligns with global AML thinking driven by the Financial Action Task Force, which emphasises effectiveness, measurable outcomes, and risk-based supervision over procedural box-ticking.

The shift signals a move away from volume-based compliance and toward impact-based compliance.

The Structural Shift: A Single AML Supervisor

The most significant reform is the move to a single supervisor model.

From July 2026, the Department of Internal Affairs will become New Zealand’s sole AML/CFT supervisor.

What This Means

Centralising supervision is not a cosmetic change. It fundamentally reshapes regulatory engagement.

A single supervisor can provide:

  • Consistent interpretation of AML obligations
  • Streamlined supervisory processes
  • Clearer guidance across industries
  • Unified enforcement strategy

For institutions that previously dealt with multiple regulators, this may reduce fragmentation and confusion.

However, centralisation also means accountability becomes sharper. A unified authority overseeing the full AML ecosystem is likely to bring stronger consistency in enforcement and more coordinated supervisory action.

Simplification does not mean leniency.

It means clarity — and clarity increases expectations.

A Stronger, Sharper Risk-Based Approach

Another cornerstone of the new strategy is proportionality.

Not every reporting entity carries the same level of financial crime risk. Applying identical compliance intensity across all sectors is inefficient and costly.

The new framework reinforces that supervisory focus should align with risk exposure.

This means:

  • Higher-risk sectors may face increased scrutiny.
  • Lower-risk sectors may benefit from streamlined requirements.
  • Supervisory resources will be deployed more strategically.
  • Enterprise-wide risk assessments will carry greater importance.

For financial institutions, this increases the need for defensible risk methodologies. Risk ratings, monitoring thresholds, and control frameworks must be clearly documented and justified.

Proportionality will need to be demonstrated with evidence.

Reducing Compliance Burden Without Weakening Controls

A notable theme in the strategy is the reduction of unnecessary administrative load.

Over time, AML regimes globally have grown increasingly documentation-heavy. While documentation is essential, excessive process formalities can dilute focus from genuine risk detection.

New Zealand’s reset aims to recalibrate the balance.

Key signals include:

  • Simplification of compliance processes where risk is low.
  • Extension of certain reporting timeframes.
  • Elimination of duplicative or low-value administrative steps.
  • Greater enforcement emphasis on meaningful breaches.

This is not deregulation.

It is optimisation.

Institutions that can automate routine compliance tasks and redirect resources toward high-risk monitoring will be better positioned under the new regime.

Intelligence-Led Supervision and Enforcement

The strategy makes clear that money laundering is not a standalone offence. It enables drug trafficking, fraud, organised crime, and other serious criminal activity.

As a result, supervision is shifting toward intelligence-led disruption.

Expect greater emphasis on:

  • Quality and usefulness of suspicious activity reporting
  • Detection of emerging typologies
  • Proactive risk mitigation
  • Inter-agency collaboration

Outcome-based supervision is replacing procedural supervision.

It will no longer be enough to demonstrate that a policy exists. Institutions must show that systems actively detect, escalate, and prevent illicit activity.

Detection effectiveness becomes the benchmark.

ChatGPT Image Feb 23, 2026, 11_57_38 AM

The 2026 Transition Window

With implementation scheduled for July 2026, institutions have a critical preparation period.

This window should be used strategically.

Key preparation areas include:

1. Reassessing Enterprise-Wide Risk Assessments

Ensure risk classifications are evidence-based, proportionate, and clearly articulated.

2. Strengthening Monitoring Systems

Evaluate whether transaction monitoring frameworks are aligned with evolving typologies and capable of reducing false positives.

3. Enhancing Suspicious Activity Reporting Quality

Focus on clarity, relevance, and timeliness rather than report volume.

4. Reviewing Governance Structures

Prepare for engagement with a single supervisory authority and ensure clear accountability lines.

5. Evaluating Technology Readiness

Assess whether current systems can support intelligence-led supervision.

Proactive alignment will reduce operational disruption and strengthen regulatory relationships.

What This Means for Banks and Fintechs

For regulated entities, the implications are practical.

Greater Consistency in Regulatory Engagement

A single supervisor reduces ambiguity and improves clarity in expectations.

Increased Accountability

Centralised oversight may lead to more uniform enforcement standards.

Emphasis on Effectiveness

Detection accuracy and investigation quality will matter more than alert volume.

Focus on High-Risk Activities

Cross-border payments, digital assets, and complex financial flows may receive deeper scrutiny.

Compliance is becoming more strategic and outcome-driven.

The Global Context

New Zealand’s reform reflects a broader international pattern.

Across Asia-Pacific and Europe, regulators are moving toward:

  • Centralised supervisory models
  • Data-driven oversight
  • Risk-based compliance
  • Reduced administrative friction for low-risk entities
  • Stronger enforcement against serious crime

Financial crime networks operate dynamically across borders and sectors. Static regulatory models cannot keep pace.

AML frameworks are evolving toward agility, intelligence integration, and measurable impact.

Institutions that fail to modernise may struggle under outcome-focused regimes.

Technology as a Strategic Enabler

A smarter AML regime requires smarter systems.

Manual processes and static rule-based monitoring struggle to address:

  • Rapid typology shifts
  • Real-time transaction complexity
  • Cross-border exposure
  • Regulatory focus on measurable outcomes

Institutions increasingly need:

  • AI-driven transaction monitoring
  • Dynamic risk scoring
  • Automated case management
  • Real-time typology updates
  • Collaborative intelligence models

As supervision becomes more centralised and intelligence-led, technology will differentiate institutions that adapt from those that lag.

Where Tookitaki Can Help

As AML frameworks evolve toward effectiveness and proportionality, compliance technology must support both precision and efficiency.

Tookitaki’s FinCense platform enables financial institutions to strengthen detection accuracy through AI-powered transaction monitoring, dynamic risk scoring, and automated case workflows. By leveraging collaborative intelligence through the AFC Ecosystem, institutions gain access to continuously updated typologies and risk indicators contributed by global experts.

In a regulatory environment that prioritises measurable impact over procedural volume, solutions that reduce false positives, accelerate investigations, and enhance detection quality become critical strategic assets.

For institutions preparing for New Zealand’s AML reset, building intelligent, adaptive compliance systems will be essential to meeting supervisory expectations.

A Defining Moment for AML in New Zealand

New Zealand’s new AML/CFT strategy is not about tightening compliance for appearances.

It is about making the system smarter.

By consolidating supervision, strengthening the risk-based approach, reducing unnecessary burdens, and sharpening enforcement focus, the country is positioning itself for a more effective financial crime prevention framework.

For financial institutions, the implications are clear:

  • Risk assessments must be defensible.
  • Detection systems must be effective.
  • Compliance must be proportionate.
  • Governance must be clear.
  • Technology must be adaptive.

The 2026 transition offers an opportunity to modernise before enforcement intensifies.

Institutions that use this period wisely will not only meet regulatory expectations but also improve operational efficiency and strengthen resilience against evolving financial crime threats.

In the fight against money laundering and terrorist financing, structure matters.

But effectiveness matters more.

New Zealand has chosen effectiveness.

The institutions that thrive in this new environment will be those that do the same.

The Great AML Reset: Why New Zealand’s 2026 Reforms Change Everything
Blogs
10 Feb 2026
4 min
read

When Cash Became Code: Inside AUSTRAC’s Operation Taipan and Australia’s Biggest Money Laundering Wake-Up Call

Money laundering does not always hide in the shadows.
Sometimes, it operates openly — at scale — until someone starts asking why the numbers no longer make sense.

That was the defining lesson of Operation Taipan, one of Australia’s most significant anti-money laundering investigations, led by AUSTRAC in collaboration with major banks and law enforcement. What began as a single anomaly during COVID-19 lockdowns evolved into a case that fundamentally reshaped how Australia detects and disrupts organised financial crime.

Although Operation Taipan began several years ago, its relevance has only grown stronger in 2026. As Australia’s financial system becomes faster, more automated, and increasingly digitised, the conditions that enabled Taipan’s laundering model are no longer exceptional — they are becoming structural. The case remains one of the clearest demonstrations of how modern money laundering exploits scale, coordination, and speed rather than secrecy, making its lessons especially urgent today.

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The Anomaly That Started It All

In 2021, AUSTRAC analysts noticed something unusual: persistent, late-night cash deposits into intelligent deposit machines (IDMs) across Melbourne.

On their own, cash deposits are routine.
But viewed collectively, the pattern stood out.

One individual was repeatedly feeding tens of thousands of dollars into IDMs across different locations, night after night. As analysts widened their lens, the scale became impossible to ignore. Over roughly 12 months, the network behind these deposits was responsible for around A$62 million in cash, accounting for nearly 16% of all cash deposits in Victoria during that period.

This was not opportunistic laundering.
It was industrial-scale financial crime.

How the Laundering Network Operated

Cash as the Entry Point

The syndicate relied heavily on cash placement through IDMs. By spreading deposits across locations, times, and accounts, they avoided traditional threshold-based alerts while maintaining relentless volume.

Velocity Over Stealth

Funds did not linger. Deposits were followed by rapid onward movement through multiple accounts, often layered further through transfers and conversions. Residual balances remained low, limiting exposure at any single point.

Coordination at Scale

This was not a lone money mule. AUSTRAC’s analysis revealed a highly coordinated network, with defined roles, consistent behaviours, and disciplined execution. The laundering succeeded not because transactions were hidden, but because collective behaviour blended into everyday activity.

Why Traditional Controls Failed

Operation Taipan exposed a critical weakness in conventional AML approaches:

Alert volume does not equal risk coverage.

No single transaction crossed an obvious red line. Thresholds were avoided. Rules were diluted. Investigation timelines lagged behind the speed at which funds moved through the system.

What ultimately surfaced the risk was not transaction size, but behavioural consistency and coordination over time.

The Role of the Fintel Alliance

Operation Taipan did not succeed through regulatory action alone. Its breakthrough came through deep public-private collaboration under the Fintel Alliance, bringing together AUSTRAC, Australia’s largest banks, and law enforcement.

By sharing intelligence and correlating data across institutions, investigators were able to:

  • Link seemingly unrelated cash deposits
  • Map network-level behaviour
  • Identify individuals coordinating deposits statewide

This collaborative, intelligence-led model proved decisive — and remains a cornerstone of Australia’s AML posture today.

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The Outcome

Three key members of the syndicate were arrested, pleaded guilty, and were sentenced. Tens of millions of dollars in illicit funds were directly linked to their activities.

But the more enduring impact was systemic.

According to AUSTRAC, Operation Taipan changed Australia’s fight against money laundering, shifting the focus from reactive alerts to proactive, intelligence-led detection.

What Operation Taipan Means for AML Programmes in 2026 and Beyond

By 2026, the conditions that enabled Operation Taipan are no longer rare.

1. Cash Still Matters

Despite the growth of digital payments, cash remains a powerful laundering vector when paired with automation and scale. Intelligent machines reduce friction for customers and criminals.

2. Behaviour Beats Thresholds

High-velocity, coordinated behaviour can be riskier than large transactions. AML systems must detect patterns across time, accounts, and locations, not just point-in-time anomalies.

3. Network Intelligence Is Essential

Institution-level monitoring alone cannot expose syndicates deliberately fragmenting activity. Federated intelligence and cross-institution collaboration are now essential.

4. Speed Is the New Battleground

Modern laundering optimises for lifecycle completion. Detection that occurs after funds have exited the system is already too late.

In today’s environment, the Taipan model is not an outlier — it is a preview.

Conclusion: When Patterns Speak Louder Than Transactions

Operation Taipan succeeded because someone asked the right question:

Why does this much money behave this consistently?

In an era of instant payments, automated cash handling, and fragmented financial ecosystems, that question may be the most important control an AML programme can have.

Operation Taipan is being discussed in 2026 not because it is new — but because the system is finally beginning to resemble the one it exposed.

Australia learned early.
Others would do well to take note.

When Cash Became Code: Inside AUSTRAC’s Operation Taipan and Australia’s Biggest Money Laundering Wake-Up Call