Checklist for Banks to Comply with Anti-Money Laundering Regulations
Banks and other financial institutions are required to implement an anti-money laundering and anti-terrorist financing compliance programme in most worldwide jurisdictions in order to identify and prevent money laundering and terrorism financing activities and meet their regulatory requirements.
Many banks, however, find that attaining AML/CFT compliance is a difficult process: they must guarantee that they gather the essential information from clients, check transactions on a regular basis, and, if necessary, report suspicious behaviour to the proper authorities.
Adding to the difficulty, banks must be informed of new criminal techniques and potential legislative changes that may influence their internal anti-money laundering procedures and modify their compliance duties.
Due to the administrative overhead, banks should create a compliance checklist that supports and informs their AML programme in order to manage their AML/CFT duties and ensure the efficacy and efficiency of AML procedures. Banks may use an AML checklist to not only create their AML infrastructure but also manage their day-to-day reaction to money laundering concerns.
As a result, the following critical aspects of an effective AML compliance checklist should be included:
Training on anti-money laundering regulations
Bank staff should get AML training, according to FATF standards, in order to stay competent of spotting suspicious conduct that might suggest money laundering or terrorism funding. As a result, a continuous AML training plan should be included in a bank’s compliance checklist in order to respond to new legislation and growing criminal tactics.
Compliance Officer
In accordance with FATF guidelines, a bank’s AML checklist should contain a need to select a compliance officer to oversee the AML compliance programme and act as a liaison with the financial authorities. The compliance officer should be a senior employee with the authority and knowledge to successfully carry out their duties.
AML Measures Based on Risk
Banks must use a risk-based strategy to AML/CFT in order to comply with FATF (Financial Action Task Force) standards.
This means that banks must adopt AML responses that are comparable to the criminal risks they face, with higher-risk clients receiving more intensive customer due diligence, sanctions screening, and transaction monitoring procedures and lower-risk customers receiving simpler measures.
In most countries, the risk-based approach is at the heart of AML law, and AML checklists should be flexible enough to handle the scale reactions that it requires.
Verification of Identity
Identity verification is an important part of risk-based AML/CFT: in order to deploy proper AML actions, institutions need to know who they’re working with and what risk they pose.
Customer due diligence (CDD) steps should be prioritised in an AML checklist, including enhanced due diligence (EDD) measures for higher-risk consumers. In practice, CDD should be able to reliably determine:
- The nature of the customer’s involvement in the business.
- Personal information on a customer, such as their name, address, and date of birth.
- Beneficial ownership of a business in which the owner is not the client or consumer.
Status of PEP
Banks must determine whether a customer is a politically exposed person (PEP) who is more likely to be involved in money laundering. Clients who are discovered to be PEPs or who become PEPs should be subjected to stricter due diligence. To guarantee that any changes in status are recognised, a bank’s AML checklist should include PEP screening during onboarding and throughout the business relationship.
Sanctions Screening
Banks must avoid doing business with people, businesses, or nations that are included on international sanctions lists. With this in mind, a bank’s anti-money laundering (AML) checklist should include a sanctions screening procedure that considers all relevant lists, including those published by national and international agencies. Customers must be screened against the US Office of Foreign Assets Control (OFAC) sanctions list as well as the UN Security Council sanctions list in the United States, for example.
Transaction Monitoring
AML checklists should concentrate on assisting banks in maintaining continuous compliance, which includes monitoring customer transactions for suspicious behaviour in respect to their risk profile. Transaction monitoring should be put up to detect:
- Transactions that exceed regulatory limits
- Unusual transactions, such as those involving unusually large sums or a high volume of transactions
- Transaction patterns that are unusual
- Transactions with PEPs or sanctioned people
- Transactions with nations that pose a high risk
- Customer-related negative media stories
Reports of Suspicious Activity
Should potential money laundering be found, bank AML checklists should contain the mechanism for filing a suspicious activity report (SAR) with the financial authorities. The procedure for submitting a SAR should be transparent and involve participation from top management.
Record-keeping
Every stage of the AML procedure necessitates the preservation of records. Banks must assess risk based on customer records, and any subsequent investigations by authorities will necessitate the disclosure of information contained in those same client records. With this in mind, bank anti-money laundering (AML) checklists should address the necessity for good documentation and record-keeping from onboarding to monitoring, screening, and SAR reporting.
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Too Many Matches, Too Little Risk: Rethinking Name Screening in Australia
When every name looks suspicious, real risk becomes harder to see.
Introduction
Name screening has long been treated as a foundational control in financial crime compliance. Screen the customer. Compare against watchlists. Generate alerts. Investigate matches.
In theory, this process is simple. In practice, it has become one of the noisiest and least efficient parts of the compliance stack.
Australian financial institutions continue to grapple with overwhelming screening alert volumes, the majority of which are ultimately cleared as false positives. Analysts spend hours reviewing name matches that pose no genuine risk. Customers experience delays and friction. Compliance teams struggle to balance regulatory expectations with operational reality.
The problem is not that name screening is broken.
The problem is that it is designed and triggered in the wrong way.
Reducing false positives in name screening requires a fundamental shift. Away from static, periodic rescreening. Towards continuous, intelligence-led screening that is triggered only when something meaningful changes.

Why Name Screening Generates So Much Noise
Most name screening programmes follow a familiar pattern.
- Customers are screened at onboarding
- Entire customer populations are rescreened when watchlists update
- Periodic batch rescreening is performed to “stay safe”
While this approach maximises coverage, it guarantees inefficiency.
Names rarely change, but screening repeats
The majority of customers retain the same name, identity attributes, and risk profile for years. Yet they are repeatedly screened as if they were new risk events.
Watchlist updates are treated as universal triggers
Minor changes to watchlists often trigger mass rescreening, even when the update is irrelevant to most customers.
Screening is detached from risk context
A coincidental name similarity is treated the same way regardless of customer risk, behaviour, or history.
False positives are not created at the point of matching alone. They are created upstream, at the point where screening is triggered unnecessarily.
Why This Problem Is More Acute in Australia
Australian institutions face conditions that amplify the impact of false positives.
A highly multicultural customer base
Diverse naming conventions, transliteration differences, and common surnames increase coincidental matches.
Lean compliance teams
Many Australian banks operate with smaller screening and compliance teams, making inefficiency costly.
Strong regulatory focus on effectiveness
AUSTRAC expects risk-based, defensible controls, not mechanical rescreening that produces noise without insight.
High customer experience expectations
Repeated delays during onboarding or reviews quickly erode trust.
For community-owned institutions in Australia, these pressures are felt even more strongly. Screening noise is not just an operational issue. It is a trust issue.
Why Tuning Alone Will Never Fix False Positives
When alert volumes rise, the instinctive response is tuning.
- Adjust name match thresholds
- Exclude common names
- Introduce whitelists
While tuning plays a role, it treats symptoms rather than causes.
Tuning asks:
“How do we reduce alerts after they appear?”
The more important question is:
“Why did this screening event trigger at all?”
As long as screening is triggered broadly and repeatedly, false positives will persist regardless of how sophisticated the matching logic becomes.
The Shift to Continuous, Delta-Based Name Screening
The first major shift required is how screening is triggered.
Modern name screening should be event-driven, not schedule-driven.
There are only three legitimate screening moments.
1. Customer onboarding
At onboarding, full name screening is necessary and expected.
New customers are screened against all relevant watchlists using the complete profile available at the start of the relationship.
This step is rarely the source of persistent false positives.
2. Ongoing customers with profile changes (Delta Customer Screening)
Most existing customers should not be rescreened unless something meaningful changes.
Valid triggers include:
- Change in name or spelling
- Change in nationality or residency
- Updates to identification documents
- Material KYC profile changes
Only the delta, not the entire customer population, should be screened.
This immediately eliminates:
- Repeated clearance of previously resolved matches
- Alerts with no new risk signal
- Analyst effort spent revalidating the same customers
3. Watchlist updates (Delta Watchlist Screening)
Not every watchlist update justifies rescreening all customers.
Delta watchlist screening evaluates:
- What specifically changed in the watchlist
- Which customers could realistically be impacted
For example:
- Adding a new individual to a sanctions list should only trigger screening for customers with relevant attributes
- Removing a record should not trigger any screening
This precision alone can reduce screening alerts dramatically without weakening coverage.

Why Continuous Screening Alone Is Not Enough
While delta-based screening removes a large portion of unnecessary alerts, it does not eliminate false positives entirely.
Even well-triggered screening will still produce low-risk matches.
This is where most institutions stop short.
The real breakthrough comes when screening is embedded into a broader Trust Layer, rather than operating as a standalone control.
The Trust Layer: Where False Positives Actually Get Solved
False positives reduce meaningfully only when screening is orchestrated with intelligence, context, and prioritisation.
In a Trust Layer approach, name screening is supported by:
Customer risk scoring
Screening alerts are evaluated alongside dynamic customer risk profiles. A coincidental name match on a low-risk retail customer should not compete with a similar match on a higher-risk profile.
Scenario intelligence
Screening outcomes are assessed against known typologies and real-world risk scenarios, rather than in isolation.
Alert prioritisation
Residual screening alerts are prioritised based on historical outcomes, risk signals, and analyst feedback. Low-risk matches no longer dominate queues.
Unified case management
Consistent investigation workflows ensure outcomes feed back into the system, reducing repeat false positives over time.
False positives decline not because alerts are suppressed, but because attention is directed to where risk actually exists.
Why This Approach Is More Defensible to Regulators
Australian regulators are not asking institutions to screen less. They are asking them to screen smarter.
A continuous, trust-layer-driven approach allows institutions to clearly explain:
- Why screening was triggered
- What changed
- Why certain alerts were deprioritised
- How decisions align with risk
This is far more defensible than blanket rescreening followed by mass clearance.
Common Mistakes That Keep False Positives High
Even advanced institutions fall into familiar traps.
- Treating screening optimisation as a tuning exercise
- Isolating screening from customer risk and behaviour
- Measuring success only by alert volume reduction
- Ignoring analyst experience and decision fatigue
False positives persist when optimisation stops at the module level.
Where Tookitaki Fits
Tookitaki approaches name screening as part of a Trust Layer, not a standalone engine.
Within the FinCense platform:
- Screening is continuous and delta-based
- Customer risk context enriches decisions
- Scenario intelligence informs relevance
- Alert prioritisation absorbs residual noise
- Unified case management closes the feedback loop
This allows institutions to reduce false positives while remaining explainable, risk-based, and regulator-ready.
How Success Should Be Measured
Reducing false positives should be evaluated through:
- Reduction in repeat screening alerts
- Analyst time spent on low-risk matches
- Faster onboarding and review cycles
- Improved audit outcomes
- Greater consistency in decisions
Lower alert volume is a side effect. Better decisions are the objective.
Conclusion
False positives in name screening are not primarily a matching problem. They are a design and orchestration problem.
Australian institutions that rely on periodic rescreening and threshold tuning will continue to struggle with alert fatigue. Those that adopt continuous, delta-based screening within a broader Trust Layer fundamentally change outcomes.
By aligning screening with intelligence, context, and prioritisation, name screening becomes precise, explainable, and sustainable.
Too many matches do not mean too much risk.
They usually mean the system is listening at the wrong moments.

Detecting Money Mule Networks Using Transaction Monitoring in Malaysia
Money mule networks are not hiding in Malaysia’s financial system. They are operating inside it, every day, at scale.
Why Money Mule Networks Have Become Malaysia’s Hardest AML Problem
Money mule activity is no longer a side effect of fraud. It is the infrastructure that allows financial crime to scale.
In Malaysia, organised crime groups now rely on mule networks to move proceeds from scams, cyber fraud, illegal gambling, and cross-border laundering. Instead of concentrating risk in a few accounts, funds are distributed across hundreds of ordinary looking customers.
Each account appears legitimate.
Each transaction seems small.
Each movement looks explainable.
But together, they form a laundering network that moves faster than traditional controls.
This is why money mule detection has become one of the most persistent challenges facing Malaysian banks and payment institutions.
And it is why transaction monitoring, as it exists today, must fundamentally change.

What Makes Money Mule Networks So Difficult to Detect
Mule networks succeed not because controls are absent, but because controls are fragmented.
Several characteristics make mule activity uniquely elusive.
Legitimate Profiles, Illicit Use
Mules are often students, gig workers, retirees, or low-risk retail customers. Their KYC profiles rarely raise concern at onboarding.
Small Amounts, Repeated Patterns
Funds are broken into low-value transfers that stay below alert thresholds, but repeat across accounts.
Rapid Pass-Through
Money does not rest. It enters and exits accounts quickly, often within minutes.
Channel Diversity
Transfers move across instant payments, wallets, QR platforms, and online banking to avoid pattern consistency.
Networked Coordination
The true risk is not a single account. It is the relationships between accounts, timing, and behaviour.
Traditional AML systems are designed to see transactions.
Mule networks exploit the fact that they do not see networks.
Why Transaction Monitoring Is the Only Control That Can Expose Mule Networks
Customer due diligence alone cannot solve the mule problem. Many mule accounts look compliant on day one.
The real signal emerges only once accounts begin transacting.
Transaction monitoring is critical because it observes:
- How money flows
- How behaviour changes over time
- How accounts interact with one another
- How patterns repeat across unrelated customers
Effective mule detection depends on behavioural continuity, not static rules.
Transaction monitoring is not about spotting suspicious transactions.
It is about reconstructing criminal logistics.
How Mule Networks Commonly Operate in Malaysia
While mule networks vary, many follow a similar operational rhythm.
- Individuals are recruited through social media, messaging platforms, or informal networks.
- Accounts are opened legitimately.
- Funds enter from scam victims or fraud proceeds.
- Money is rapidly redistributed across multiple mule accounts.
- Funds are consolidated and moved offshore or converted into assets.
No single transaction is extreme.
No individual account looks criminal.
The laundering emerges only when behaviour is connected.
Transaction Patterns That Reveal Mule Network Behaviour
Modern transaction monitoring must move beyond red flags and identify patterns at scale.
Key indicators include:
Repeating Flow Structures
Multiple accounts receiving similar amounts at similar times, followed by near-identical onward transfers.
Rapid In-and-Out Activity
Consistent pass-through behaviour with minimal balance retention.
Shared Counterparties
Different customers transacting with the same limited group of beneficiaries or originators.
Sudden Velocity Shifts
Sharp increases in transaction frequency without corresponding lifestyle or profile changes.
Channel Switching
Movement between payment rails to break linear visibility.
Geographic Mismatch
Accounts operated locally but sending funds to unexpected or higher-risk jurisdictions.
Individually, these signals are weak.
Together, they form a mule network fingerprint.

Why Even Strong AML Programs Miss Mule Networks
This is where detection often breaks down operationally.
Many Malaysian institutions have invested heavily in AML technology, yet mule networks still slip through. The issue is not intent. It is structure.
Common internal blind spots include:
- Alert fragmentation, where related activity appears across multiple queues
- Fraud and AML separation, delaying escalation of scam-driven laundering
- Manual network reconstruction, which happens too late
- Threshold dependency, which criminals actively game
- Investigator overload, where volume masks coordination
By the time a network is manually identified, funds have often already exited the system.
Transaction monitoring must evolve from alert generation to network intelligence.
The Role of AI in Network-Level Mule Detection
AI changes mule detection by shifting focus from transactions to behaviour and relationships.
Behavioural Modelling
AI establishes normal transaction behaviour and flags coordinated deviations across customers.
Network Analysis
Machine learning identifies hidden links between accounts that appear unrelated on the surface.
Pattern Clustering
Similar transaction behaviours are grouped, revealing structured activity.
Early Risk Identification
Models surface mule indicators before large volumes accumulate.
Continuous Learning
Confirmed cases refine detection logic automatically.
AI enables transaction monitoring systems to act before laundering completes, not after damage is done.
Tookitaki’s FinCense: Network-Driven Transaction Monitoring in Practice
Tookitaki’s FinCense approaches mule detection as a network problem, not a rule tuning exercise.
FinCense combines transaction monitoring, behavioural intelligence, AI-driven network analysis, and regional typology insights into a single platform.
This allows Malaysian institutions to identify mule networks early and intervene decisively.
Behavioural and Network Intelligence Working Together
FinCense analyses transactions across customers, accounts, and channels simultaneously.
It identifies:
- Shared transaction rhythms
- Coordinated timing patterns
- Repeated fund flow structures
- Hidden relationships between accounts
What appears normal in isolation becomes suspicious in context.
Agentic AI That Accelerates Investigations
FinCense uses Agentic AI to:
- Correlate alerts into network-level cases
- Highlight the strongest risk drivers
- Generate investigation narratives
- Reduce manual case assembly
Investigators see the full story immediately, not scattered signals.
Federated Intelligence Across ASEAN
Money mule networks rarely operate within a single market.
Through the Anti-Financial Crime Ecosystem, FinCense benefits from typologies and behavioural patterns observed across ASEAN.
This provides early warning of:
- Emerging mule recruitment methods
- Cross-border laundering routes
- Scam-driven transaction patterns
For Malaysia, this regional context is critical.
Explainable Detection for Regulatory Confidence
Every network detection in FinCense is transparent.
Compliance teams can clearly explain:
- Why accounts were linked
- Which behaviours mattered
- How the network was identified
- Why escalation was justified
This supports enforcement without sacrificing governance.
A Real-Time Scenario: How Mule Networks Are Disrupted
Consider a real-world sequence.
Minute 0: Multiple low-value transfers enter separate retail accounts.
Minute 7: Funds are redistributed across new beneficiaries.
Minute 14: Balances approach zero.
Minute 18: Cross-border transfers are initiated.
Individually, none breach thresholds.
FinCense identifies the network by:
- Clustering similar transaction timing
- Detecting repeated pass-through behaviour
- Linking beneficiaries across customers
- Matching patterns to known mule typologies
Transactions are paused before consolidation completes.
The network is disrupted while funds are still within reach.
What Transaction Monitoring Must Deliver to Stop Mule Networks
To detect mule networks effectively, transaction monitoring systems must provide:
- Network-level visibility
- Behavioural baselining
- Real-time processing
- Cross-channel intelligence
- Explainable AI outputs
- Integrated AML investigations
- Regional typology awareness
Anything less allows mule networks to scale unnoticed.
The Future of Mule Detection in Malaysia
Mule networks will continue to adapt.
Future detection strategies will rely on:
- Network-first monitoring
- AI-assisted investigations
- Real-time interdiction
- Closer fraud and AML collaboration
- Responsible intelligence sharing
Malaysia’s regulatory maturity and digital infrastructure position it well to lead this shift.
Conclusion
Money mule networks thrive on fragmentation, speed, and invisibility.
Detecting them requires transaction monitoring that understands behaviour, relationships, and coordination, not just individual transactions.
If an institution is not detecting networks, it is not detecting mule risk.
Tookitaki’s FinCense enables this shift by transforming transaction monitoring into a network intelligence capability. By combining AI-driven behavioural analysis, federated regional intelligence, and explainable investigations, FinCense empowers Malaysian institutions to disrupt mule networks before laundering completes.
In modern financial crime prevention, visibility is power.
And networks are where the truth lives.

AI Transaction Monitoring for Detecting RTP Fraud in Australia
Real time payments move money in seconds. Fraud now has the same advantage.
Introduction
Australia’s real time payments infrastructure has changed how money moves. Payments that once took hours or days now settle almost instantly. This speed has delivered clear benefits for consumers and businesses, but it has also reshaped fraud risk in ways traditional controls were never designed to handle.
In real time payment environments, fraud does not wait for end of day monitoring or post transaction reviews. By the time a suspicious transaction is detected, funds are often already gone.
This is why AI transaction monitoring has become central to detecting RTP fraud in Australia. Not as a buzzword, but as a practical response to a payment environment where timing, context, and decision speed determine outcomes.
This blog explores how RTP fraud differs from traditional fraud, why conventional monitoring struggles, and how AI driven transaction monitoring supports faster, smarter detection in Australia’s real time payments landscape.

Why RTP Fraud Is a Different Problem
Real time payment fraud behaves differently from fraud in batch based systems.
Speed removes recovery windows
Once funds move, recovery is difficult or impossible. Detection must happen before or during the transaction, not after.
Scams dominate RTP fraud
Many RTP fraud cases involve authorised payments where customers are manipulated rather than credentials being stolen.
Context matters more than rules
A transaction may look legitimate in isolation but suspicious when viewed alongside behaviour, timing, and sequence.
Volume amplifies risk
High transaction volumes create noise that can hide genuine fraud signals.
These characteristics demand a fundamentally different approach to transaction monitoring.
Why Traditional Transaction Monitoring Struggles with RTP
Legacy transaction monitoring systems were built for slower payment rails.
They rely on:
- Static thresholds
- Post event analysis
- Batch processing
- Manual investigation queues
In RTP environments, these approaches break down.
Alerts arrive too late
Detection after settlement offers insight, not prevention.
Thresholds generate noise
Low thresholds overwhelm teams. High thresholds miss emerging scams.
Manual review does not scale
Human review cannot keep pace with real time transaction flows.
This is not a failure of teams. It is a mismatch between system design and payment reality.
What AI Transaction Monitoring Changes
AI transaction monitoring does not simply automate existing rules. It changes how risk is identified and prioritised in real time.
1. Behavioural understanding rather than static checks
AI models focus on behaviour rather than individual transactions.
They analyse:
- Normal customer payment patterns
- Changes in timing, frequency, and destination
- Sudden deviations from established behaviour
This allows detection of fraud that does not break explicit rules but breaks behavioural expectations.
2. Contextual risk assessment in real time
AI transaction monitoring evaluates transactions within context.
This includes:
- Customer history
- Recent activity patterns
- Payment sequences
- Network relationships
Context allows systems to distinguish between unusual but legitimate activity and genuinely suspicious behaviour.
3. Risk based prioritisation at speed
Rather than treating all alerts equally, AI models assign relative risk.
This enables:
- Faster decisions on high risk transactions
- Graduated responses rather than binary blocks
- Better use of limited intervention windows
In RTP environments, prioritisation is critical.
4. Adaptation to evolving scam tactics
Scam tactics change quickly.
AI models can adapt by:
- Learning from confirmed fraud outcomes
- Adjusting to new behavioural patterns
- Reducing reliance on constant manual rule updates
This improves resilience without constant reconfiguration.
How AI Detects RTP Fraud in Practice
AI transaction monitoring supports RTP fraud detection across several stages.
Pre transaction risk sensing
Before funds move, AI assesses:
- Whether the transaction fits normal behaviour
- Whether recent activity suggests manipulation
- Whether destinations are unusual for the customer
This stage supports intervention before settlement.
In transaction decisioning
During transaction processing, AI helps determine:
- Whether to allow the payment
- Whether to introduce friction
- Whether to delay for verification
Timing is critical. Decisions must be fast and proportionate.
Post transaction learning
After transactions complete, outcomes feed back into models.
Confirmed fraud, false positives, and customer disputes all improve future detection accuracy.

RTP Fraud Scenarios Where AI Adds Value
Several RTP fraud scenarios benefit strongly from AI driven monitoring.
Authorised push payment scams
Where customers are manipulated into sending funds themselves.
Sudden behavioural shifts
Such as first time large transfers to new payees.
Payment chaining
Rapid movement of funds across multiple accounts.
Time based anomalies
Unusual payment activity outside normal customer patterns.
Rules alone struggle to capture these dynamics reliably.
Why Explainability Still Matters in AI Transaction Monitoring
Speed does not remove the need for explainability.
Financial institutions must still be able to:
- Explain why a transaction was flagged
- Justify interventions to customers
- Defend decisions to regulators
AI transaction monitoring must therefore balance intelligence with transparency.
Explainable signals improve trust, adoption, and regulatory confidence.
Australia Specific Considerations for RTP Fraud Detection
Australia’s RTP environment introduces specific challenges.
Fast domestic payment rails
Settlement speed leaves little room for post event action.
High scam prevalence
Many fraud cases involve genuine customers under manipulation.
Strong regulatory expectations
Institutions must demonstrate risk based, defensible controls.
Lean operational teams
Efficiency matters as much as effectiveness.
For financial institutions, AI transaction monitoring must reduce burden without compromising protection.
Common Pitfalls When Using AI for RTP Monitoring
AI is powerful, but misapplied it can create new risks.
Over reliance on black box models
Lack of transparency undermines trust and governance.
Excessive friction
Overly aggressive responses damage customer relationships.
Poor data foundations
AI reflects data quality. Weak inputs produce weak outcomes.
Ignoring operational workflows
Detection without response coordination limits value.
Successful deployments avoid these traps through careful design.
How AI Transaction Monitoring Fits with Broader Financial Crime Controls
RTP fraud rarely exists in isolation.
Scam proceeds may:
- Flow through multiple accounts
- Trigger downstream laundering risks
- Involve mule networks
AI transaction monitoring is most effective when connected with broader financial crime monitoring and investigation workflows.
This enables:
- Earlier detection
- Better case linkage
- More efficient investigations
- Stronger regulatory outcomes
The Role of Human Oversight
Even in real time environments, humans matter.
Analysts:
- Validate patterns
- Review edge cases
- Improve models through feedback
- Handle customer interactions
AI supports faster, more informed decisions, but does not remove responsibility.
Where Tookitaki Fits in RTP Fraud Detection
Tookitaki approaches AI transaction monitoring as an intelligence driven capability rather than a rule replacement exercise.
Within the FinCense platform, AI is used to:
- Detect behavioural anomalies in real time
- Prioritise RTP risk meaningfully
- Reduce false positives
- Support explainable decisions
- Feed intelligence into downstream monitoring and investigations
This approach helps institutions manage RTP fraud without overwhelming teams or customers.
What the Future of RTP Fraud Detection Looks Like
As real time payments continue to grow, fraud detection will evolve alongside them.
Future capabilities will focus on:
- Faster decision cycles
- Stronger behavioural intelligence
- Closer integration between fraud and AML
- Better customer communication at the point of risk
- Continuous learning rather than static controls
Institutions that invest in adaptive AI transaction monitoring will be better positioned to protect customers in real time environments.
Conclusion
RTP fraud in Australia is not a future problem. It is a present one shaped by speed, scale, and evolving scam tactics.
Traditional transaction monitoring approaches struggle because they were designed for a slower world. AI transaction monitoring offers a practical way to detect RTP fraud earlier, prioritise risk intelligently, and respond within shrinking time windows.
When applied responsibly, with explainability and governance, AI becomes a critical ally in protecting customers and preserving trust in real time payments.
In RTP environments, detection delayed is detection denied.
AI transaction monitoring helps institutions act when it still matters.

Too Many Matches, Too Little Risk: Rethinking Name Screening in Australia
When every name looks suspicious, real risk becomes harder to see.
Introduction
Name screening has long been treated as a foundational control in financial crime compliance. Screen the customer. Compare against watchlists. Generate alerts. Investigate matches.
In theory, this process is simple. In practice, it has become one of the noisiest and least efficient parts of the compliance stack.
Australian financial institutions continue to grapple with overwhelming screening alert volumes, the majority of which are ultimately cleared as false positives. Analysts spend hours reviewing name matches that pose no genuine risk. Customers experience delays and friction. Compliance teams struggle to balance regulatory expectations with operational reality.
The problem is not that name screening is broken.
The problem is that it is designed and triggered in the wrong way.
Reducing false positives in name screening requires a fundamental shift. Away from static, periodic rescreening. Towards continuous, intelligence-led screening that is triggered only when something meaningful changes.

Why Name Screening Generates So Much Noise
Most name screening programmes follow a familiar pattern.
- Customers are screened at onboarding
- Entire customer populations are rescreened when watchlists update
- Periodic batch rescreening is performed to “stay safe”
While this approach maximises coverage, it guarantees inefficiency.
Names rarely change, but screening repeats
The majority of customers retain the same name, identity attributes, and risk profile for years. Yet they are repeatedly screened as if they were new risk events.
Watchlist updates are treated as universal triggers
Minor changes to watchlists often trigger mass rescreening, even when the update is irrelevant to most customers.
Screening is detached from risk context
A coincidental name similarity is treated the same way regardless of customer risk, behaviour, or history.
False positives are not created at the point of matching alone. They are created upstream, at the point where screening is triggered unnecessarily.
Why This Problem Is More Acute in Australia
Australian institutions face conditions that amplify the impact of false positives.
A highly multicultural customer base
Diverse naming conventions, transliteration differences, and common surnames increase coincidental matches.
Lean compliance teams
Many Australian banks operate with smaller screening and compliance teams, making inefficiency costly.
Strong regulatory focus on effectiveness
AUSTRAC expects risk-based, defensible controls, not mechanical rescreening that produces noise without insight.
High customer experience expectations
Repeated delays during onboarding or reviews quickly erode trust.
For community-owned institutions in Australia, these pressures are felt even more strongly. Screening noise is not just an operational issue. It is a trust issue.
Why Tuning Alone Will Never Fix False Positives
When alert volumes rise, the instinctive response is tuning.
- Adjust name match thresholds
- Exclude common names
- Introduce whitelists
While tuning plays a role, it treats symptoms rather than causes.
Tuning asks:
“How do we reduce alerts after they appear?”
The more important question is:
“Why did this screening event trigger at all?”
As long as screening is triggered broadly and repeatedly, false positives will persist regardless of how sophisticated the matching logic becomes.
The Shift to Continuous, Delta-Based Name Screening
The first major shift required is how screening is triggered.
Modern name screening should be event-driven, not schedule-driven.
There are only three legitimate screening moments.
1. Customer onboarding
At onboarding, full name screening is necessary and expected.
New customers are screened against all relevant watchlists using the complete profile available at the start of the relationship.
This step is rarely the source of persistent false positives.
2. Ongoing customers with profile changes (Delta Customer Screening)
Most existing customers should not be rescreened unless something meaningful changes.
Valid triggers include:
- Change in name or spelling
- Change in nationality or residency
- Updates to identification documents
- Material KYC profile changes
Only the delta, not the entire customer population, should be screened.
This immediately eliminates:
- Repeated clearance of previously resolved matches
- Alerts with no new risk signal
- Analyst effort spent revalidating the same customers
3. Watchlist updates (Delta Watchlist Screening)
Not every watchlist update justifies rescreening all customers.
Delta watchlist screening evaluates:
- What specifically changed in the watchlist
- Which customers could realistically be impacted
For example:
- Adding a new individual to a sanctions list should only trigger screening for customers with relevant attributes
- Removing a record should not trigger any screening
This precision alone can reduce screening alerts dramatically without weakening coverage.

Why Continuous Screening Alone Is Not Enough
While delta-based screening removes a large portion of unnecessary alerts, it does not eliminate false positives entirely.
Even well-triggered screening will still produce low-risk matches.
This is where most institutions stop short.
The real breakthrough comes when screening is embedded into a broader Trust Layer, rather than operating as a standalone control.
The Trust Layer: Where False Positives Actually Get Solved
False positives reduce meaningfully only when screening is orchestrated with intelligence, context, and prioritisation.
In a Trust Layer approach, name screening is supported by:
Customer risk scoring
Screening alerts are evaluated alongside dynamic customer risk profiles. A coincidental name match on a low-risk retail customer should not compete with a similar match on a higher-risk profile.
Scenario intelligence
Screening outcomes are assessed against known typologies and real-world risk scenarios, rather than in isolation.
Alert prioritisation
Residual screening alerts are prioritised based on historical outcomes, risk signals, and analyst feedback. Low-risk matches no longer dominate queues.
Unified case management
Consistent investigation workflows ensure outcomes feed back into the system, reducing repeat false positives over time.
False positives decline not because alerts are suppressed, but because attention is directed to where risk actually exists.
Why This Approach Is More Defensible to Regulators
Australian regulators are not asking institutions to screen less. They are asking them to screen smarter.
A continuous, trust-layer-driven approach allows institutions to clearly explain:
- Why screening was triggered
- What changed
- Why certain alerts were deprioritised
- How decisions align with risk
This is far more defensible than blanket rescreening followed by mass clearance.
Common Mistakes That Keep False Positives High
Even advanced institutions fall into familiar traps.
- Treating screening optimisation as a tuning exercise
- Isolating screening from customer risk and behaviour
- Measuring success only by alert volume reduction
- Ignoring analyst experience and decision fatigue
False positives persist when optimisation stops at the module level.
Where Tookitaki Fits
Tookitaki approaches name screening as part of a Trust Layer, not a standalone engine.
Within the FinCense platform:
- Screening is continuous and delta-based
- Customer risk context enriches decisions
- Scenario intelligence informs relevance
- Alert prioritisation absorbs residual noise
- Unified case management closes the feedback loop
This allows institutions to reduce false positives while remaining explainable, risk-based, and regulator-ready.
How Success Should Be Measured
Reducing false positives should be evaluated through:
- Reduction in repeat screening alerts
- Analyst time spent on low-risk matches
- Faster onboarding and review cycles
- Improved audit outcomes
- Greater consistency in decisions
Lower alert volume is a side effect. Better decisions are the objective.
Conclusion
False positives in name screening are not primarily a matching problem. They are a design and orchestration problem.
Australian institutions that rely on periodic rescreening and threshold tuning will continue to struggle with alert fatigue. Those that adopt continuous, delta-based screening within a broader Trust Layer fundamentally change outcomes.
By aligning screening with intelligence, context, and prioritisation, name screening becomes precise, explainable, and sustainable.
Too many matches do not mean too much risk.
They usually mean the system is listening at the wrong moments.

Detecting Money Mule Networks Using Transaction Monitoring in Malaysia
Money mule networks are not hiding in Malaysia’s financial system. They are operating inside it, every day, at scale.
Why Money Mule Networks Have Become Malaysia’s Hardest AML Problem
Money mule activity is no longer a side effect of fraud. It is the infrastructure that allows financial crime to scale.
In Malaysia, organised crime groups now rely on mule networks to move proceeds from scams, cyber fraud, illegal gambling, and cross-border laundering. Instead of concentrating risk in a few accounts, funds are distributed across hundreds of ordinary looking customers.
Each account appears legitimate.
Each transaction seems small.
Each movement looks explainable.
But together, they form a laundering network that moves faster than traditional controls.
This is why money mule detection has become one of the most persistent challenges facing Malaysian banks and payment institutions.
And it is why transaction monitoring, as it exists today, must fundamentally change.

What Makes Money Mule Networks So Difficult to Detect
Mule networks succeed not because controls are absent, but because controls are fragmented.
Several characteristics make mule activity uniquely elusive.
Legitimate Profiles, Illicit Use
Mules are often students, gig workers, retirees, or low-risk retail customers. Their KYC profiles rarely raise concern at onboarding.
Small Amounts, Repeated Patterns
Funds are broken into low-value transfers that stay below alert thresholds, but repeat across accounts.
Rapid Pass-Through
Money does not rest. It enters and exits accounts quickly, often within minutes.
Channel Diversity
Transfers move across instant payments, wallets, QR platforms, and online banking to avoid pattern consistency.
Networked Coordination
The true risk is not a single account. It is the relationships between accounts, timing, and behaviour.
Traditional AML systems are designed to see transactions.
Mule networks exploit the fact that they do not see networks.
Why Transaction Monitoring Is the Only Control That Can Expose Mule Networks
Customer due diligence alone cannot solve the mule problem. Many mule accounts look compliant on day one.
The real signal emerges only once accounts begin transacting.
Transaction monitoring is critical because it observes:
- How money flows
- How behaviour changes over time
- How accounts interact with one another
- How patterns repeat across unrelated customers
Effective mule detection depends on behavioural continuity, not static rules.
Transaction monitoring is not about spotting suspicious transactions.
It is about reconstructing criminal logistics.
How Mule Networks Commonly Operate in Malaysia
While mule networks vary, many follow a similar operational rhythm.
- Individuals are recruited through social media, messaging platforms, or informal networks.
- Accounts are opened legitimately.
- Funds enter from scam victims or fraud proceeds.
- Money is rapidly redistributed across multiple mule accounts.
- Funds are consolidated and moved offshore or converted into assets.
No single transaction is extreme.
No individual account looks criminal.
The laundering emerges only when behaviour is connected.
Transaction Patterns That Reveal Mule Network Behaviour
Modern transaction monitoring must move beyond red flags and identify patterns at scale.
Key indicators include:
Repeating Flow Structures
Multiple accounts receiving similar amounts at similar times, followed by near-identical onward transfers.
Rapid In-and-Out Activity
Consistent pass-through behaviour with minimal balance retention.
Shared Counterparties
Different customers transacting with the same limited group of beneficiaries or originators.
Sudden Velocity Shifts
Sharp increases in transaction frequency without corresponding lifestyle or profile changes.
Channel Switching
Movement between payment rails to break linear visibility.
Geographic Mismatch
Accounts operated locally but sending funds to unexpected or higher-risk jurisdictions.
Individually, these signals are weak.
Together, they form a mule network fingerprint.

Why Even Strong AML Programs Miss Mule Networks
This is where detection often breaks down operationally.
Many Malaysian institutions have invested heavily in AML technology, yet mule networks still slip through. The issue is not intent. It is structure.
Common internal blind spots include:
- Alert fragmentation, where related activity appears across multiple queues
- Fraud and AML separation, delaying escalation of scam-driven laundering
- Manual network reconstruction, which happens too late
- Threshold dependency, which criminals actively game
- Investigator overload, where volume masks coordination
By the time a network is manually identified, funds have often already exited the system.
Transaction monitoring must evolve from alert generation to network intelligence.
The Role of AI in Network-Level Mule Detection
AI changes mule detection by shifting focus from transactions to behaviour and relationships.
Behavioural Modelling
AI establishes normal transaction behaviour and flags coordinated deviations across customers.
Network Analysis
Machine learning identifies hidden links between accounts that appear unrelated on the surface.
Pattern Clustering
Similar transaction behaviours are grouped, revealing structured activity.
Early Risk Identification
Models surface mule indicators before large volumes accumulate.
Continuous Learning
Confirmed cases refine detection logic automatically.
AI enables transaction monitoring systems to act before laundering completes, not after damage is done.
Tookitaki’s FinCense: Network-Driven Transaction Monitoring in Practice
Tookitaki’s FinCense approaches mule detection as a network problem, not a rule tuning exercise.
FinCense combines transaction monitoring, behavioural intelligence, AI-driven network analysis, and regional typology insights into a single platform.
This allows Malaysian institutions to identify mule networks early and intervene decisively.
Behavioural and Network Intelligence Working Together
FinCense analyses transactions across customers, accounts, and channels simultaneously.
It identifies:
- Shared transaction rhythms
- Coordinated timing patterns
- Repeated fund flow structures
- Hidden relationships between accounts
What appears normal in isolation becomes suspicious in context.
Agentic AI That Accelerates Investigations
FinCense uses Agentic AI to:
- Correlate alerts into network-level cases
- Highlight the strongest risk drivers
- Generate investigation narratives
- Reduce manual case assembly
Investigators see the full story immediately, not scattered signals.
Federated Intelligence Across ASEAN
Money mule networks rarely operate within a single market.
Through the Anti-Financial Crime Ecosystem, FinCense benefits from typologies and behavioural patterns observed across ASEAN.
This provides early warning of:
- Emerging mule recruitment methods
- Cross-border laundering routes
- Scam-driven transaction patterns
For Malaysia, this regional context is critical.
Explainable Detection for Regulatory Confidence
Every network detection in FinCense is transparent.
Compliance teams can clearly explain:
- Why accounts were linked
- Which behaviours mattered
- How the network was identified
- Why escalation was justified
This supports enforcement without sacrificing governance.
A Real-Time Scenario: How Mule Networks Are Disrupted
Consider a real-world sequence.
Minute 0: Multiple low-value transfers enter separate retail accounts.
Minute 7: Funds are redistributed across new beneficiaries.
Minute 14: Balances approach zero.
Minute 18: Cross-border transfers are initiated.
Individually, none breach thresholds.
FinCense identifies the network by:
- Clustering similar transaction timing
- Detecting repeated pass-through behaviour
- Linking beneficiaries across customers
- Matching patterns to known mule typologies
Transactions are paused before consolidation completes.
The network is disrupted while funds are still within reach.
What Transaction Monitoring Must Deliver to Stop Mule Networks
To detect mule networks effectively, transaction monitoring systems must provide:
- Network-level visibility
- Behavioural baselining
- Real-time processing
- Cross-channel intelligence
- Explainable AI outputs
- Integrated AML investigations
- Regional typology awareness
Anything less allows mule networks to scale unnoticed.
The Future of Mule Detection in Malaysia
Mule networks will continue to adapt.
Future detection strategies will rely on:
- Network-first monitoring
- AI-assisted investigations
- Real-time interdiction
- Closer fraud and AML collaboration
- Responsible intelligence sharing
Malaysia’s regulatory maturity and digital infrastructure position it well to lead this shift.
Conclusion
Money mule networks thrive on fragmentation, speed, and invisibility.
Detecting them requires transaction monitoring that understands behaviour, relationships, and coordination, not just individual transactions.
If an institution is not detecting networks, it is not detecting mule risk.
Tookitaki’s FinCense enables this shift by transforming transaction monitoring into a network intelligence capability. By combining AI-driven behavioural analysis, federated regional intelligence, and explainable investigations, FinCense empowers Malaysian institutions to disrupt mule networks before laundering completes.
In modern financial crime prevention, visibility is power.
And networks are where the truth lives.

AI Transaction Monitoring for Detecting RTP Fraud in Australia
Real time payments move money in seconds. Fraud now has the same advantage.
Introduction
Australia’s real time payments infrastructure has changed how money moves. Payments that once took hours or days now settle almost instantly. This speed has delivered clear benefits for consumers and businesses, but it has also reshaped fraud risk in ways traditional controls were never designed to handle.
In real time payment environments, fraud does not wait for end of day monitoring or post transaction reviews. By the time a suspicious transaction is detected, funds are often already gone.
This is why AI transaction monitoring has become central to detecting RTP fraud in Australia. Not as a buzzword, but as a practical response to a payment environment where timing, context, and decision speed determine outcomes.
This blog explores how RTP fraud differs from traditional fraud, why conventional monitoring struggles, and how AI driven transaction monitoring supports faster, smarter detection in Australia’s real time payments landscape.

Why RTP Fraud Is a Different Problem
Real time payment fraud behaves differently from fraud in batch based systems.
Speed removes recovery windows
Once funds move, recovery is difficult or impossible. Detection must happen before or during the transaction, not after.
Scams dominate RTP fraud
Many RTP fraud cases involve authorised payments where customers are manipulated rather than credentials being stolen.
Context matters more than rules
A transaction may look legitimate in isolation but suspicious when viewed alongside behaviour, timing, and sequence.
Volume amplifies risk
High transaction volumes create noise that can hide genuine fraud signals.
These characteristics demand a fundamentally different approach to transaction monitoring.
Why Traditional Transaction Monitoring Struggles with RTP
Legacy transaction monitoring systems were built for slower payment rails.
They rely on:
- Static thresholds
- Post event analysis
- Batch processing
- Manual investigation queues
In RTP environments, these approaches break down.
Alerts arrive too late
Detection after settlement offers insight, not prevention.
Thresholds generate noise
Low thresholds overwhelm teams. High thresholds miss emerging scams.
Manual review does not scale
Human review cannot keep pace with real time transaction flows.
This is not a failure of teams. It is a mismatch between system design and payment reality.
What AI Transaction Monitoring Changes
AI transaction monitoring does not simply automate existing rules. It changes how risk is identified and prioritised in real time.
1. Behavioural understanding rather than static checks
AI models focus on behaviour rather than individual transactions.
They analyse:
- Normal customer payment patterns
- Changes in timing, frequency, and destination
- Sudden deviations from established behaviour
This allows detection of fraud that does not break explicit rules but breaks behavioural expectations.
2. Contextual risk assessment in real time
AI transaction monitoring evaluates transactions within context.
This includes:
- Customer history
- Recent activity patterns
- Payment sequences
- Network relationships
Context allows systems to distinguish between unusual but legitimate activity and genuinely suspicious behaviour.
3. Risk based prioritisation at speed
Rather than treating all alerts equally, AI models assign relative risk.
This enables:
- Faster decisions on high risk transactions
- Graduated responses rather than binary blocks
- Better use of limited intervention windows
In RTP environments, prioritisation is critical.
4. Adaptation to evolving scam tactics
Scam tactics change quickly.
AI models can adapt by:
- Learning from confirmed fraud outcomes
- Adjusting to new behavioural patterns
- Reducing reliance on constant manual rule updates
This improves resilience without constant reconfiguration.
How AI Detects RTP Fraud in Practice
AI transaction monitoring supports RTP fraud detection across several stages.
Pre transaction risk sensing
Before funds move, AI assesses:
- Whether the transaction fits normal behaviour
- Whether recent activity suggests manipulation
- Whether destinations are unusual for the customer
This stage supports intervention before settlement.
In transaction decisioning
During transaction processing, AI helps determine:
- Whether to allow the payment
- Whether to introduce friction
- Whether to delay for verification
Timing is critical. Decisions must be fast and proportionate.
Post transaction learning
After transactions complete, outcomes feed back into models.
Confirmed fraud, false positives, and customer disputes all improve future detection accuracy.

RTP Fraud Scenarios Where AI Adds Value
Several RTP fraud scenarios benefit strongly from AI driven monitoring.
Authorised push payment scams
Where customers are manipulated into sending funds themselves.
Sudden behavioural shifts
Such as first time large transfers to new payees.
Payment chaining
Rapid movement of funds across multiple accounts.
Time based anomalies
Unusual payment activity outside normal customer patterns.
Rules alone struggle to capture these dynamics reliably.
Why Explainability Still Matters in AI Transaction Monitoring
Speed does not remove the need for explainability.
Financial institutions must still be able to:
- Explain why a transaction was flagged
- Justify interventions to customers
- Defend decisions to regulators
AI transaction monitoring must therefore balance intelligence with transparency.
Explainable signals improve trust, adoption, and regulatory confidence.
Australia Specific Considerations for RTP Fraud Detection
Australia’s RTP environment introduces specific challenges.
Fast domestic payment rails
Settlement speed leaves little room for post event action.
High scam prevalence
Many fraud cases involve genuine customers under manipulation.
Strong regulatory expectations
Institutions must demonstrate risk based, defensible controls.
Lean operational teams
Efficiency matters as much as effectiveness.
For financial institutions, AI transaction monitoring must reduce burden without compromising protection.
Common Pitfalls When Using AI for RTP Monitoring
AI is powerful, but misapplied it can create new risks.
Over reliance on black box models
Lack of transparency undermines trust and governance.
Excessive friction
Overly aggressive responses damage customer relationships.
Poor data foundations
AI reflects data quality. Weak inputs produce weak outcomes.
Ignoring operational workflows
Detection without response coordination limits value.
Successful deployments avoid these traps through careful design.
How AI Transaction Monitoring Fits with Broader Financial Crime Controls
RTP fraud rarely exists in isolation.
Scam proceeds may:
- Flow through multiple accounts
- Trigger downstream laundering risks
- Involve mule networks
AI transaction monitoring is most effective when connected with broader financial crime monitoring and investigation workflows.
This enables:
- Earlier detection
- Better case linkage
- More efficient investigations
- Stronger regulatory outcomes
The Role of Human Oversight
Even in real time environments, humans matter.
Analysts:
- Validate patterns
- Review edge cases
- Improve models through feedback
- Handle customer interactions
AI supports faster, more informed decisions, but does not remove responsibility.
Where Tookitaki Fits in RTP Fraud Detection
Tookitaki approaches AI transaction monitoring as an intelligence driven capability rather than a rule replacement exercise.
Within the FinCense platform, AI is used to:
- Detect behavioural anomalies in real time
- Prioritise RTP risk meaningfully
- Reduce false positives
- Support explainable decisions
- Feed intelligence into downstream monitoring and investigations
This approach helps institutions manage RTP fraud without overwhelming teams or customers.
What the Future of RTP Fraud Detection Looks Like
As real time payments continue to grow, fraud detection will evolve alongside them.
Future capabilities will focus on:
- Faster decision cycles
- Stronger behavioural intelligence
- Closer integration between fraud and AML
- Better customer communication at the point of risk
- Continuous learning rather than static controls
Institutions that invest in adaptive AI transaction monitoring will be better positioned to protect customers in real time environments.
Conclusion
RTP fraud in Australia is not a future problem. It is a present one shaped by speed, scale, and evolving scam tactics.
Traditional transaction monitoring approaches struggle because they were designed for a slower world. AI transaction monitoring offers a practical way to detect RTP fraud earlier, prioritise risk intelligently, and respond within shrinking time windows.
When applied responsibly, with explainability and governance, AI becomes a critical ally in protecting customers and preserving trust in real time payments.
In RTP environments, detection delayed is detection denied.
AI transaction monitoring helps institutions act when it still matters.


