PayTo is revolutionising payments in Australia, but it is also creating new fraud risks that demand smarter detection strategies.

Australia’s payments landscape is evolving rapidly. The introduction of PayTo, a digital payment service built on the New Payments Platform (NPP), promises faster, smarter, and more secure payments for consumers and businesses. With PayTo, customers can authorise third parties to initiate payments directly from their bank accounts, improving convenience and efficiency.

But with innovation comes risk. Fraudsters are already targeting PayTo’s new infrastructure with sophisticated scams and laundering schemes. For banks, fintechs, and payment providers, understanding PayTo fraud risks in Australia is essential to protecting customers and meeting AUSTRAC’s compliance requirements.

What is PayTo?

PayTo is an NPP service that allows businesses and authorised third parties to initiate real-time payments directly from customer bank accounts.

Key features include:

• Real-Time Payments: Funds move instantly.
• Customer Authorisation: Customers approve payment agreements through their banking app.
• Enhanced Transparency: Customers can view and manage payment agreements in real time.

PayTo is designed to replace direct debit systems with a faster and more customer-friendly solution.

Why PayTo is a Fraud Target

1. Instant Transfers

Like NPP, PayTo enables real-time settlement, giving banks little time to reverse fraudulent transfers.

2. Authorised Push Payment (APP) Scams

Fraudsters trick victims into approving fraudulent payment agreements, bypassing controls.

3. Synthetic Identities

Criminals use fake or stolen identities to set up fraudulent PayTo agreements.

4. Business Email Compromise (BEC)

Scammers impersonate vendors, convincing businesses to authorise fraudulent PayTo arrangements.

5. Mule Accounts

PayTo can be exploited to quickly move funds through mule networks before detection.

Key PayTo Fraud Risks in Australia

1. Compromised Authorisations
   Fraudsters manipulate customers into approving payment agreements.
2. Fake Merchants
   Shell companies create fraudulent PayTo agreements to receive illicit funds.
3. Account Takeover Fraud
   Criminals hijack legitimate accounts and set up PayTo arrangements.
4. Overcharging Schemes
   Fraudulent businesses use PayTo to debit higher amounts than agreed.
5. Cross-Border Laundering
   Funds moved via PayTo can be layered through remittance channels or offshore accounts.

Red Flags for PayTo Fraud

• Customers creating multiple PayTo agreements in a short period.
• Agreements linked to newly opened or high-risk accounts.
• Payment amounts inconsistent with stated business purpose.
• Transfers to accounts with no history of business activity.
• Customers disputing authorisations shortly after approval.
• Rapid pass-through transactions with no balance retention.

AUSTRAC Compliance and PayTo

AUSTRAC requires reporting entities to:

• Monitor PayTo transactions in real time.
• File Suspicious Matter Reports (SMRs) for unusual agreements or payments.
• Maintain records of authorisations and transactions.
• Integrate PayTo into AML/CTF programs and risk assessments.

Failure to adapt compliance frameworks to PayTo could expose banks to regulatory penalties.

Best Practices for Managing PayTo Fraud Risks

1. Strengthen Onboarding Controls
   Verify merchants and businesses rigorously before allowing PayTo arrangements.
2. Adopt Real-Time Monitoring
   Monitor PayTo agreements and transactions continuously, not in batches.
3. Leverage AI and Machine Learning
   Use adaptive models to detect anomalies in PayTo usage.
4. Educate Customers
   Raise awareness of PayTo scams, particularly APP and BEC fraud.
5. Collaborate Across Industry
   Share typologies and intelligence through networks like the AFC Ecosystem.
6. Audit Regularly
   Conduct reviews to ensure PayTo controls are effective and compliant.

Case Example: Community-Owned Banks Adapting Early

Community-owned banks such as Regional Australia Bank and Beyond Bank are taking proactive steps to incorporate PayTo into their compliance frameworks. By adopting advanced platforms, they ensure their customers benefit from PayTo’s convenience while remaining protected from fraud risks.

Spotlight: Tookitaki’s FinCense for PayTo

FinCense, Tookitaki’s compliance platform, is designed to handle real-time payment innovations like PayTo.

• Real-Time Detection: Monitors PayTo agreements and transactions instantly.
• Agentic AI: Learns from evolving PayTo fraud typologies.
• Federated Intelligence: Accesses global scenarios contributed by compliance experts in the AFC Ecosystem.
• Regulator-Ready Reporting: Automates SMRs, TTRs, and IFTIs for AUSTRAC.
• Integrated Case Management: Tracks PayTo-related investigations with full audit trails.
• Cross-Channel Coverage: Links PayTo monitoring with NPP, cards, wallets, and remittances.

By using FinCense, Australian banks can turn PayTo into a secure advantage rather than a compliance challenge.

Future of PayTo Fraud Detection in Australia

1. Deeper AI Integration: AI will play a critical role in spotting fraud in milliseconds.
2. Cross-Border Collaboration: Fraud rings often operate internationally, requiring intelligence-sharing networks.
3. Stronger Customer Controls: Banks will offer more tools for customers to monitor and cancel agreements.
4. Expansion to New Sectors: As PayTo adoption grows, new fraud typologies will emerge.
5. Regulator-Driven Innovation: AUSTRAC will continue pushing for advanced fraud detection tools.

Conclusion

PayTo is a major step forward for Australia’s payments system, offering transparency and convenience for consumers and businesses. But fraudsters are quick to exploit new technologies, making PayTo a high-risk channel for scams and laundering.

Banks must act now to integrate PayTo into their compliance frameworks. Community-owned banks like Regional Australia Bank and Beyond Bank show that strong fraud prevention is achievable at any scale. Platforms like Tookitaki’s FinCense combine AI, federated intelligence, and regulator-ready reporting to keep PayTo safe.

Pro tip: Every innovation brings risk. With the right compliance tools, PayTo can strengthen customer trust instead of exposing banks to fraud.

In today’s high-speed financial world, staying compliant is not enough. You need to stay ahead.

Banks and financial institutions in Singapore face growing challenges in detecting and preventing money laundering. Regulatory expectations are rising, financial crime is evolving rapidly, and traditional compliance tools are no longer enough. The solution? An industry leading AML solution that doesn’t just react to crime, but predicts and prevents it.

This blog dives deep into what truly sets a top-tier AML platform apart, how Singapore’s financial institutions can benefit from smarter compliance systems, and why the next wave of AML success will be built on AI, adaptability, and collaboration.

Singapore’s AML Landscape: A Snapshot

Singapore’s reputation as a trusted financial centre brings both opportunity and responsibility. The Monetary Authority of Singapore (MAS) has positioned itself as a proactive regulator, frequently enhancing AML and Countering the Financing of Terrorism (CFT) expectations in line with evolving threats.

Key trends shaping the AML environment in Singapore include:

• Greater scrutiny on cross-border payment networks
• Rising fraud linked to deepfake scams and mule networks
• Proliferation of shell companies and nominee arrangements
• Heightened expectations for risk-based customer due diligence
• Mandatory suspicious transaction reporting via GoAML

In this environment, firms cannot rely on legacy systems with basic rule engines and slow response times. An industry leading AML solution must support real-time monitoring, intelligent detection, and efficient investigation workflows that align with both MAS requirements and global FATF guidelines.

What Makes an AML Solution Truly Industry Leading?

Not all AML platforms are created equal. Here are the features and capabilities that separate the best from the rest.

1. End-to-End Coverage Across the AML Lifecycle

A leading solution must cover every phase of financial crime prevention — from onboarding and screening to transaction monitoring, case management, investigation, and reporting.

• Customer Due Diligence (CDD): Automate and update customer profiles with risk scores, documentation, and activity history.
• Screening: Real-time checks against global and regional watchlists, sanctions, and PEP databases.
• Transaction Monitoring: Detect anomalies in real time using rules, AI, and behavioural analytics.
• Case Management: Centralised interface for investigators with contextual insights and audit trails.
• Regulatory Reporting: Integration with STR platforms like GoAML for seamless filing and compliance.

2. Real-Time, Risk-Based Detection

Criminals move fast, and so should your detection systems. Top-tier solutions ingest data and flag suspicious activity in real time, while applying risk-based scoring to prioritise high-impact alerts.

Key benefits include:

• Blocking fraudulent transactions before they settle
• Preventing repeat abuse from mule accounts
• Rapidly identifying high-risk behaviour in customer activity

3. AI-Powered Intelligence

The best AML platforms do not stop at static rules. They combine machine learning, natural language processing, and federated learning to adapt to new fraud techniques and reduce false positives.

Capabilities to look for:

• Dynamic risk scoring that evolves with user behaviour
• Automated narrative generation for STRs
• Pattern recognition across vast datasets
• Cross-institution intelligence sharing without exposing customer data

4. Scenario-Based Detection Frameworks

Instead of generic alerts, industry leading solutions rely on real-world scenarios. These reflect how financial crime actually occurs — from layering through remittance corridors to shell firm misuse and mule account exploitation.

Platforms like FinCense by Tookitaki integrate typologies contributed by experts and peer institutions across Asia. This keeps detection systems current and rooted in lived realities, not just theoretical models.

5. Investigation Support Tools

Flagging activity is one thing. Investigating and documenting it is another. A leading AML solution must make investigations faster, smarter, and regulator-ready.

Best-in-class investigation features include:

• Unified dashboards with customer and transaction context
• Smart copilot assistance to guide analysts
• AI-generated narratives for internal and external reporting
• Escalation workflows and audit logging

These tools reduce case closure time, improve consistency, and ease compliance pressure.

Challenges That Weaken Traditional AML Platforms

Institutions in Singapore using outdated systems often report the following issues:

1. High False Positives

Static rules alone generate too many irrelevant alerts, overwhelming analysts and causing real risks to slip through.

2. Siloed Data Sources

Risk insights are scattered across departments and systems, preventing a unified view of customer activity.

3. Lack of Adaptability

Criminals constantly evolve. Fixed rule engines struggle to detect new fraud patterns like deepfake scams, synthetic identities, or micro-layering.

4. Poor Audit Readiness

Manual documentation, unclear alert reasoning, and fragmented investigations make audit preparation slow and stressful.

5. Limited Collaboration

Without access to regional threat insights, institutions are left to battle financial crime in isolation.

What Sets FinCense Apart as a Leading AML Solution

Tookitaki’s FinCense platform is built to solve the challenges above — and more. Designed with Singapore’s regulatory environment in mind, it combines AI, scenario-based detection, and collaborative intelligence into a unified system.

Here’s what makes it one of Asia’s leading AML solutions:

1. Modular Agentic AI Framework

FinCense is powered by modular AI agents that specialise in distinct parts of the compliance workflow, including detection, alert prioritisation, investigation support, and reporting.

Each agent works independently but connects seamlessly, providing agility and focus while reducing operational burden.

2. 200+ Real-World Typologies via AFC Ecosystem

The AFC Ecosystem is a collaborative knowledge platform where banks, regulators, and compliance experts share fraud and laundering scenarios. FinCense connects directly to this ecosystem, enabling banks to download new typologies and deploy them in real time.

This collective intelligence approach keeps detection capabilities fresh and locally relevant — a major advantage in Singapore’s rapidly shifting landscape.

3. Federated Learning for Cross-Bank Insight

Through federated learning, FinCense enables intelligence sharing without compromising privacy. Banks can learn from fraud patterns seen by others, strengthening their defences against emerging threats.

4. Simulation and Threshold Optimisation

Before going live with a new rule or scenario, FinCense allows teams to simulate its effect. This helps reduce false positives, avoid alert floods, and fine-tune detection thresholds based on actual data.

5. Smart Disposition Engine and FinMate Copilot

• Smart Disposition suggests recommended actions based on past case outcomes and current alert risk.
• FinMate helps investigators by surfacing relevant information, summarising risk indicators, and preparing case narratives for internal teams or regulators.

These tools speed up case resolution and improve decision quality.

Results Achieved by Leading Institutions in Singapore

Banks and fintechs across Singapore have implemented FinCense to modernise their compliance operations. Outcomes include:

• Up to 65 percent reduction in false positives
• Threefold increase in investigation speed
• Improved STR quality and audit confidence
• Stronger ability to detect cross-border laundering techniques
• Reduced analyst fatigue and higher team satisfaction

How to Choose an Industry Leading AML Solution: A Checklist

Before selecting an AML platform, ask these questions:

• Does the solution support end-to-end AML workflows?
• Can it detect risks in real time and at scale?
• Does it use real-world typologies instead of just rules?
• Is it AI-powered with human-readable outcomes?
• Can it integrate with STR platforms like GoAML?
• Is it modular and customisable for your institution’s needs?
• Does it offer collaborative intelligence or shared insights?
• How quickly can analysts investigate and close cases?

If your current system falls short in multiple areas, it's time to explore smarter alternatives.

The Future of AML in Singapore: From Compliance to Intelligence

AML is no longer just about avoiding penalties. It is about building institutional trust, protecting customers, and staying ahead of criminal networks.

Singapore’s financial ecosystem is moving towards faster payments, digital banking, and borderless finance. This demands AML solutions that are not just reactive, but predictive and intelligent.

Leading platforms like FinCense enable this shift by:

• Detecting threats early with fewer false alerts
• Supporting analysts with AI and smart workflows
• Enabling collaboration across institutions through federated learning
• Meeting regulatory expectations with explainability and traceability

The question is not whether you need an industry leading AML solution. It is whether your institution is ready to take the lead.

Conclusion: Lead the Change, Don’t Chase It

The era of checkbox compliance is over. In Singapore’s evolving financial crime landscape, only those who invest in the right tools will be able to adapt, scale, and lead with confidence.

Choosing an industry leading AML solution like FinCense is not just a technology decision. It is a strategic move toward smarter compliance, stronger resilience, and better outcomes — for your team, your customers, and the financial system as a whole.

Strong AML model risk management is essential for Australian banks to balance innovation, regulatory expectations, and financial crime prevention.

Banks in Australia are under constant pressure to detect and prevent money laundering while meeting the expectations of AUSTRAC and other regulators. Most rely on transaction monitoring models, machine learning algorithms, and risk scoring systems to flag suspicious activity.

But what happens if these models are flawed? Poorly calibrated or biased models can create blind spots, generate excessive false positives, or even miss criminal activity altogether. This is where AML model risk management becomes critical. It ensures that compliance models are accurate, explainable, and effective.

What is AML Model Risk Management?

AML model risk management is the framework for developing, validating, and maintaining models used in anti-money laundering compliance. It ensures models:

• Detect suspicious transactions accurately.
• Produce explainable results for regulators.
• Adapt to new money laundering typologies.
• Avoid bias that may unfairly target or miss certain customer groups.

It is about ensuring compliance technology works as intended, with safeguards against errors or misuse.

Why AML Model Risk Management Matters in Australia

1. AUSTRAC Expectations

AUSTRAC requires banks to demonstrate that their AML systems are effective, transparent, and auditable. Flawed models risk penalties and reputational damage.

2. Real-Time Payment Risks

With the NPP and PayTo, transactions move instantly. Poorly calibrated models may fail to detect mule accounts or layering in time.

3. High Cost of Compliance

False positives drain resources. Model risk management helps reduce noise, improving efficiency.

4. Reputation and Trust

Customers expect banks to protect them. Failures in detection can erode confidence.

5. Innovation Pressure

Banks are adopting AI and machine learning rapidly. Without strong governance, these models may create compliance vulnerabilities.

Key Components of AML Model Risk Management

1. Model Development

Design models using quality data and sound assumptions.

2. Validation and Testing

Independent teams test models for accuracy, fairness, and reliability.

3. Ongoing Monitoring

Regularly assess whether models are performing as expected under real-world conditions.

4. Documentation

Maintain clear records of model design, testing, and updates for regulatory review.

5. Governance

Establish oversight frameworks to manage responsibilities and escalation processes.

Common Risks in AML Models

• Data Bias: Incomplete or unrepresentative data leads to unfair or inaccurate outcomes.
• Overfitting: Models perform well on training data but poorly in the real world.
• Under-Calibration: Rules are too broad, creating excessive false positives.
• Opacity: Black-box AI models make it hard to justify decisions to AUSTRAC.
• Outdated Typologies: Models fail to adapt to evolving money laundering techniques.

Red Flags for Model Risk

• Sudden spikes in false positives.
• Decline in suspicious matter report (SMR) quality.
• Alerts missing emerging fraud or laundering typologies.
• Inconsistent outcomes across customer groups.
• Lack of documentation for model decisions.
• Difficulty explaining model logic to regulators.

Case Example: Community-Owned Banks and Model Risk Management

Community-owned banks like Regional Australia Bank and Beyond Bank have embraced advanced compliance platforms that incorporate robust model governance. By focusing on transparency, validation, and regulator-ready reporting, these banks demonstrate that even mid-sized institutions can achieve world-class AML model risk management.

Spotlight: Tookitaki’s FinCense

FinCense, Tookitaki’s compliance platform, provides industry-leading tools for AML model risk management.

• Simulation Mode: Allows banks to test new scenarios without disrupting operations.
• Agentic AI Models: Continuously adapt while remaining explainable for regulators.
• Federated Intelligence: Accesses AML typologies from the AFC Ecosystem to strengthen detection.
• FinMate AI Copilot: Summarises investigations and creates regulator-ready reports.
• Model Governance: Built-in audit trails and validation tools ensure compliance with AUSTRAC.
• Cross-Channel Protection: Unifies model risk management across banking, wallets, remittances, and crypto.

By embedding strong model risk practices into FinCense, Australian banks can reduce false positives, meet AUSTRAC requirements, and protect customer trust.

Best Practices for AML Model Risk Management

1. Establish Independent Validation Teams: Ensure models are tested by teams separate from developers.
2. Prioritise Explainability: Choose AI models that regulators can understand.
3. Focus on Data Quality: Garbage in, garbage out. Invest in clean, representative data.
4. Monitor Continuously: Regular reviews detect drift and performance issues.
5. Document Thoroughly: Maintain detailed records for regulator inspections.
6. Engage Regulators Early: Proactive communication builds trust with AUSTRAC.

The Future of AML Model Risk Management

1. AI Governance Frameworks: Regulators will require more transparency in AI models.
2. Dynamic Thresholds: Models will update risk thresholds automatically in real time.
3. Federated Learning Models: Institutions will collaborate to strengthen models without sharing raw data.
4. AI Copilots for Validation: Tools like FinMate will automate testing and documentation.
5. Integration with Real-Time Payments: AML models will need to keep pace with instant transactions.

Conclusion

AML model risk management is essential for Australian banks operating in a fast-moving, high-risk financial landscape. With AUSTRAC demanding transparency, and fraudsters exploiting real-time payments, strong model governance is no longer optional.

Community-owned banks like Regional Australia Bank and Beyond Bank prove that robust AML model risk practices are achievable for institutions of all sizes. Platforms like Tookitaki’s FinCense combine Agentic AI, federated intelligence, and simulation tools to deliver compliance that is accurate, transparent, and resilient.

Pro tip: Treat AML models as living systems. Regular testing, validation, and governance are key to keeping compliance strong and fraudsters at bay.