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JMLSG Guidance and Its Importance in the UK AML Regime

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Tookitaki
16 Dec 2020
7 min
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JMLSG stands for the Joint Money Laundering Steering Group. It’s a multi-disciplinary committee which was created to provide assistance in interpreting UK Money Laundering Regulations. The private-sector body regularly publishes guidance notes, known as JMLSG guidance, on the UK money laundering regulations.

The JMLSG guidance plays an important role in helping financial institutions and other key industries to ensure that they comply with the UK’s anti-money laundering and counter-terrorist financing (AML/CTF) regulations. In this article, we will discuss JMLSG, the JMLSG guidance and its role in the UK AML regime.

 

Who Are the Members of JMLSG?

JMLSG consists of members from leading UK trade associations who are part of the financial service industry. It also includes representatives from the Building Societies Association, the British Bankers’ Association, and the Association of British Insurers. The following are the current members of JMLSG, according to their official website.

  • Association for Financial Markets in Europe (AFME)
  • The Association of British Credit Unions Limited (ABCUL)
  • Association of British Insurers (ABI)
  • Association of Foreign Banks (AFB)
  • British Venture Capital Association (BVCA)
  • Building Societies Association (BSA)
  • Electronic Money Association (EMA)
  • European Venues and Intermediaries Association (EVIA)
  • Finance & Leasing Association (FLA)
  • The Investment Association (IA)
  • Loan Market Association (LMA)
  • The Personal Investment Management and Financial Advice Association (PIMFA)
  • The Investing and Savings Alliance (TISA)
  • UK Finance (UKF)

 

What Is the Aim of JMLSG?

The JMLSG aims to assist financial institutions in the UK to adopt better practices in the prevention of money laundering and terrorist financing. Its guidance notes are to clarify the country’s AML regulations and to guide financial institutions on the implementation of proper AML processes and procedures.

 

What is the JMLSG Guidance?

The JMLSG has set forth AML guidelines to help assist the financial sector. These guidelines are neither legally binding nor punishable at an offence. However, they have HM Treasury’s approval. The JMLSG guidance helps financial institutions (FIs) to develop a compliance programme with policies and procedures that are fit to the organisation’s needs.

The guidance by JMLSG determines the necessary requirements that the financial entities need in order to detect, investigate, and prevent money laundering and terrorist financing. It allows the FIs to apply the required regulations based on their personal experience, products and services, clients and transactions.

Although it’s not compulsory for FIs to follow the JMLSG guidance, the adoption, however, is a sign of having good AML compliance measures. The guidance is not over-prescriptive but provides a base from which an FI’s management can develop tailored policies and procedures that are appropriate for their business. It remains the responsibility of an FI to make its own judgement on individual cases, on a risk-based approach.

The purpose of the JMLSG guidance is to:

  • Outline the legal and regulatory framework for anti-money laundering/countering terrorist financing (AML/CTF) requirements and systems across the financial services sector
  • Interpret the requirements of the relevant law and regulations, and how they may be implemented in practice
  • Indicate good industry practice in AML/CTF procedures through a proportionate, risk-based approach
  • Assist firms in designing and implementing the systems and controls necessary to mitigate the risks of the firm being used in connection with money laundering and the financing of terrorism.

Read More: Financial Conduct Authority: Money Laundering in The UK

The Current JMLSG Guidance

The current JMLSG guidance is available in three parts:

  1. Generic guidance for the UK financial sector,
  2. Sectoral guidance
  3. Specialist guidance.

We give a quick rundown of the general guidance's content here.

 The Responsibility of Senior Management

According to the JMLSG, senior management in an FI has a responsibility to ensure that its policies, controls and procedures are appropriately designed, implemented and effectively operated.

The senior management needs to ensure that the Financial Conduct Authority makes written policies and procedures available to the FI’s employees. It is also the responsibility of management to consider any risk factors relating to clients, jurisdictions, the geographic location of the institute, transactions, products, and services, and so on.

The senior management should be engaged at every step of the decision-making processes while taking ownership of the risk-based approach. The management will be responsible in case the risk-based approach is inadequate.

Internal Controls

The JMLSG provides guidance on the internal controls that will help FIs meet their obligations in respect to the prevention of money laundering and terrorist financing.

It is recommended that FIs appoint a member of their board (or comparable management body) or senior management as the officer in charge of the firm's money laundering compliance.They also need to carry out screening of relevant employees and agents appointed by the firm, both before they are recruited, and at regular intervals during the course of their employment and establish an independent internal audit function.

The Nominated Officers/MLROs

FIs must appoint a Nominated Officer or Money Laundering Reporting Officer (MLRO) to ensure that the firm maintains compliance with the Financial Conduct Authority’s (FCA) regulatory systems.

The firm’s nominated officer will monitor the routine functions and money laundering policies. They will also give more information on any questioning related to the FCA or help in understanding the UK’s legislation better.

A Risk-based Approach

The risk-based approach is endorsed by the FATF recommendations 1 and 10 and the Basel Paper among others.

The JMLSG suggests the following actions to ensure a risk-based approach.

    • Carry out a formal, and regular, money laundering/terrorist financing risk assessment, including market changes, and changes in products, customers and the wider environment
    • Ensure internal policies, controls and procedures, including staff awareness, adequately reflect the risk assessment
    • Ensure customer identification and acceptance procedures reflect the risk characteristics of customers
    • Ensure arrangements for monitoring systems and controls are robust, and reflect the risk characteristics of customers

Customer Due Diligence

The group lists out the following Customer Due Diligence (CDD) measures for FIs in its guidance.

    • Must carry out prescribed CDD measures for all customers not covered by exemptions
    • Must have systems to deal with identification issues in relation to those who cannot produce the standard evidence
    • Must take a risk-based approach when applying enhanced due diligence to take account of the greater potential for money laundering in higher-risk cases, specifically with respect of PEPs and correspondent relationships
    • Some persons/entities must not be dealt with
    • Must have specific policies about the financially (and socially) excluded
    • If satisfactory evidence of identity is not obtained, the business relationship must not proceed further
    • Must have some system for keeping customer information up to date

Suspicious Activities, Reporting and Data Protection

The JMLSG suggests the following actions:

    • Enquiries made in respect to disclosures must be documented
    • The reasons why a Suspicious Activity Report (SAR) was, or was not, submitted should be recorded
    • Any communications made with or received from the authorities, including the NCA, in relation to a SAR should be maintained on file
    • In cases where advance notice of a transaction or of arrangements is given, the need for prior consent before it is allowed to proceed should be considered

Staff Awareness, Training and Alertness

The JMLSG suggests the following actions:

    • Provide appropriate training to make relevant employees aware of money laundering and terrorist financing issues, including how these crimes operate and how they might take place through the firm
    • Ensure that relevant employees are provided with information on, and understand, the legal position of the firm and of individual members of staff, and of changes to these legal positions
    • Consider providing relevant employees with case studies and examples related to the firm’s business
    • Train relevant employees in how to operate a risk-based approach to AML/CTF

Record Keeping

According to the JMLSG, FIs have the following core obligations:

    • Firms must retain copies of, or references to, the evidence they obtained of a customer’s identity and details of customer transactions for five years after the end of the customer relationship or five years after the completion of an occasional transaction
    • Firms should retain details of actions taken in respect of internal and external suspicion reports and details of information considered by the nominated officer in respect of an internal report where no external report is made
    • Firms must delete any personal data relating to CDD and client transactions in accordance with Regulation 40

 

How Can Tookitaki Help Financial Institutions in the UK?

As a fast-growing Regtech company, Tookitaki has developed an end-to-end AML compliance platform called the Anti-Money Laundering Suite (AMLS). It offers multiple solutions catering to the core AML activities such as transaction monitoring, name screening, transaction screening and customer risk scoring. Powered by advanced machine learning, AMLS addresses the market needs and provides an effective and scalable AML compliance solution.

To learn more about our AML solution and its unique features that help financial institutions to enhance their risk-based AML compliance programmes, book a meeting with one of our experts today. 

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Blogs
24 Nov 2025
6 min
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Singapore’s Secret Weapon Against Dirty Money? Smarter AML Investigation Tools

In the fight against financial crime, investigation tools can make or break your compliance operations.

With Singapore facing growing threats from money mule syndicates, trade-based laundering, and cyber-enabled fraud, the need for precise and efficient anti-money laundering (AML) investigations has never been more urgent. In this blog, we explore how AML investigation tools are evolving to help compliance teams in Singapore accelerate detection, reduce false positives, and stay audit-ready.

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What Are AML Investigation Tools?

AML investigation tools are technology solutions that assist compliance teams in detecting, analysing, documenting, and reporting suspicious financial activity. These tools bridge the gap between alert generation and action — providing context, workflow, and intelligence to identify real risk from noise.

These tools can be:

  • Standalone modules within AML software
  • Integrated into broader case management systems
  • Powered by AI, machine learning, or rules-based engines

Why They Matter in the Singapore Context

Singapore’s financial services sector faces increasing pressure from regulators, counterparties, and the public to uphold world-class compliance standards. Investigation tools help institutions:

  • Quickly triage and resolve alerts from transaction monitoring or screening systems
  • Understand customer behaviour and transactional context
  • Collaborate across teams for efficient case resolution
  • Document decisions in a regulator-ready audit trail

Key Capabilities of Modern AML Investigation Tools

1. Alert Contextualisation

Investigators need context around each alert:

  • Who is the customer?
  • What’s their risk rating?
  • Has this activity occurred before?
  • What other products do they use?

Good tools aggregate this data into a single view to save time and prevent errors.

2. Visualisation of Transaction Patterns

Network graphs and timelines show links between accounts, beneficiaries, and geographies. These help spot circular payments, layering, or collusion.

3. Narrative Generation

AI-generated case narratives can summarise key findings and explain the decision to escalate or dismiss an alert. This saves time and ensures consistency in reporting.

4. Investigator Workflow

Assign tasks, track time-to-resolution, and route high-risk alerts to senior reviewers — all within the system.

5. Integration with STR Filing

Once an alert is confirmed as suspicious, the system should auto-fill suspicious transaction report (STR) templates for MAS submission.

Common Challenges Without Proper Tools

Many institutions still struggle with manual or legacy investigation processes:

  • Copy-pasting between systems and spreadsheets
  • Investigating the same customer multiple times due to siloed alerts
  • Missing deadlines for STR filing
  • Poor audit trails, leading to compliance risk

In high-volume environments like Singapore’s fintech hubs or retail banks, these inefficiencies create operational drag.

Real-World Example: Account Takeover Fraud via Fintech Wallets

An e-wallet provider in Singapore noticed a spike in high-value foreign exchange transactions.

Upon investigation, the team found:

  • Victim accounts were accessed via compromised emails
  • Wallet balances were converted into EUR/GBP instantly
  • Funds were moved to mule accounts and out to crypto exchanges

Using an investigation tool with network mapping and device fingerprinting, the compliance team:

  • Identified shared mule accounts across multiple victims
  • Escalated the case to the regulator within 24 hours
  • Blocked future similar transactions using rule updates
ChatGPT Image Nov 24, 2025, 10_00_56 AM

Tookitaki’s FinCense: Investigation Reinvented

Tookitaki’s FinCense platform provides end-to-end investigation capabilities designed for Singapore’s regulatory and operational needs.

Features That Matter:

  • FinMate: An AI copilot that analyses alerts, recommends actions, and drafts case narratives
  • Smart Disposition: Automatically generates case summaries and flags key findings
  • Unified Case Management: Investigators work from a single dashboard that integrates monitoring, screening, and risk scoring
  • MAS-Ready Reporting: Customisable templates for local regulatory formats
  • Federated Intelligence: Access 1,200+ community-driven typologies from the AFC Ecosystem to cross-check against ongoing cases

Results From Tookitaki Clients:

  • 72% fewer false positives
  • 3.5× faster resolution times
  • STR submission cycles shortened by 60%

Regulatory Expectations from MAS

Under MAS guidelines, financial institutions must:

  • Have effective alert management processes
  • Ensure timely investigation and STR submission
  • Maintain records of all investigations and decisions
  • Demonstrate scenario tuning and effectiveness reviews

A modern AML investigation tool supports all these requirements, reducing operational and audit burden.

AML Investigation and Emerging Threats

1. Deepfake-Fuelled Impersonation

Tools must validate biometric data and voiceprints to flag synthetic identities.

2. Crypto Layering

Graph-based tracing of wallet addresses is increasingly vital as laundering moves to decentralised finance.

3. Mule Account Clusters

AI-based clustering tools can identify unusual movement patterns across otherwise low-risk individuals.

4. Instant Payments Risk

Real-time investigation support is needed for PayNow, FAST, and other instant channels.

How to Evaluate a Vendor

Ask these questions:

  • Can your tool integrate with our current transaction monitoring system?
  • How do you handle false positive reduction?
  • Do you support scenario simulation and tuning?
  • Is your audit trail MAS-compliant?
  • Can we import scenarios from other institutions (e.g. AFC Ecosystem)?

Looking Ahead: The Future of AML Investigations

AML investigations are evolving from reactive tasks to intelligence-led workflows. Tools are getting:

  • Agentic AI: Copilots like FinMate suggest next steps, reducing guesswork
  • Community-Driven: Knowledge sharing through federated systems boosts preparedness
  • More Visual: Risk maps, entity graphs, and timelines help understand complex flows
  • Smarter Thresholds: ML-driven dynamic thresholds reduce alert fatigue

Conclusion: Investigation is Your Last Line of Defence

In an age of instant payments, cross-border fraud, and synthetic identities, the role of AML investigation tools is mission-critical. Compliance officers in Singapore must be equipped with solutions that go beyond flagging transactions — they must help resolve them fast and accurately.

Tookitaki’s FinCense, with its AI-first approach and regulatory alignment, is redefining how Singaporean institutions approach AML investigations. It’s not just about staying compliant. It’s about staying smart, swift, and one step ahead of financial crime.

Singapore’s Secret Weapon Against Dirty Money? Smarter AML Investigation Tools
Blogs
24 Nov 2025
6 min
read

Fraud Detection Software for Banks: Inside the Digital War Room

Every day in Australia, fraud teams fight a silent battle. This is the story of how they do it, and the software helping them win.

Prologue: The Alert That Shouldn’t Have Happened

It is 2:14 pm on a quiet Wednesday in Sydney.
A fraud investigator at a mid-sized Australian bank receives an alert:
Attempted transfer: 19,800 AUD — flagged as “possible mule routing”.

The transaction looks ordinary.
Local IP.
Registered device.
Customer active for years.

Nothing about it screams fraud.

But the software sees something the human eye cannot:
a subtle deviation in typing cadence, geolocation drift over the past month, and a behavioural mismatch in weekday spending patterns.

This is not the customer.
This is someone pretending to be them.

The transfer is blocked.
The account is frozen.
A customer is protected from losing their savings.

This is the new frontline of fraud detection in Australian banking.
A place where milliseconds matter.
Where algorithms, analysts, and behavioural intelligence work together in near real time.

And behind it all sits one critical layer: fraud detection software built for the world we live in now, not the world we used to live in.

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Chapter 1: Why Fraud Detection Has Become a War Room Operation

Fraud has always existed, but digital banking has changed its scale, speed, and sophistication.
Australian banks are facing:

  • Real-time scams through NPP
  • Deepfake-assisted social engineering
  • Mule networks recruiting on TikTok
  • Synthetic IDs built from fragments of real citizens
  • Remote access scams controlling customer devices
  • Cross-border laundering through fintech rails
  • Account takeover via phishing and malware

Fraud today is not one person trying their luck.
It is supply-chain crime.

And the only way banks can fight it is by transforming fraud detection into a dynamic, intelligence-led discipline supported by software that thinks, learns, adapts, and collaborates.

Chapter 2: What Modern Fraud Detection Software Really Does

Forget the outdated idea that fraud detection is simply about rules.

Modern software must:

  • Learn behaviour
  • Spot anomalies
  • Detect device manipulation
  • Understand transaction velocity
  • Identify network relationships
  • Analyse biometrics
  • Flag mule-like patterns
  • Predict risk, not just react to it

The best systems behave like digital detectives.

They observe.
They learn.
They connect dots humans cannot connect in real time.

Chapter 3: The Six Capabilities That Define Best-in-Class Fraud Detection Software

1. Behavioural Biometrics

Typing speed.
Mouse movement.
Pressure on mobile screens.
Session navigation patterns.

These signals reveal whether the person behind the device is the real customer or an impostor.

2. Device Intelligence

Device fingerprinting, jailbreak checks, emulator detection, and remote-access-trojan indicators now play a key role in catching account takeover attempts.

3. Network Link Analysis

Modern fraud does not occur in isolation.
Software must map:

  • Shared devices
  • Shared addresses
  • Linked mule accounts
  • Common beneficiaries
  • Suspicious payment clusters

This is how syndicates are caught.

4. Real-Time Risk Scoring

Fraud cannot wait for batch jobs.
Software must analyse patterns as they happen and block or challenge the transaction instantly.

5. Cross-Channel Visibility

Fraud moves across onboarding, transfers, cards, wallets, and payments.
Detection must be omnichannel, not siloed.

6. Analyst Assistance

The best software does not overwhelm investigators.
It assists them by:

  • Summarising evidence
  • Highlighting anomalies
  • Suggesting next steps
  • Reducing noise

Fraud teams fight harder when the software fights with them.

ChatGPT Image Nov 23, 2025, 07_23_27 PM

Chapter 4: Inside an Australian Bank’s Digital Fraud Team

Picture this scene.

A fraud operations centre in Melbourne.
Multiple screens.
Live dashboards.
Analysts monitoring spikes in activity.

Suddenly, the software detects something:
A cluster of small transfers moving rapidly into multiple new accounts.
Amounts just below reporting thresholds.
Accounts opened within the last three weeks.
Behaviour consistent with mule recruitment.

This is not random.
This is an organised ring.

The fraud team begins tracing the pattern using network graphs visualised by the software.
Connections emerge.
A clear structure forms.
Multiple accounts tied to the same device.
Shared IP addresses across suburbs.

Within minutes, the team has identified a mule network operating across three states.

They block the accounts.
Freeze the funds.
Notify the authorities.
Prevent a chain of victims.

This is fraud detection software at its best:
Augmenting human instinct with machine intelligence.

Chapter 5: The Weaknesses of Old Fraud Detection Systems

Some Australian banks still rely on systems that:

  • Use rigid rules
  • Miss behavioural patterns
  • Cannot detect deepfakes
  • Struggle with NPP velocity
  • Generate high false positives
  • Cannot identify linked accounts
  • Have no real-time capabilities
  • Lack explainability for AUSTRAC or internal audit

These systems were designed for a slower era, when payments were not instantaneous and criminals did not use automation.

Old systems do not fail because they are old.
They fail because the world has changed.

Chapter 6: What Australian Banks Should Look For in Fraud Detection Software (A Modern Checklist)

1. Real-Time Analysis for NPP

Detection must be instant.

2. Behavioural Intelligence

Software should learn how customers normally behave and identify anomalies.

3. Mule Detection Algorithms

Australia is experiencing a surge in mule recruitment.
This is now essential.

4. Explainability

Banks must be able to justify fraud decisions to regulators and customers.

5. Cross-Channel Intelligence

Transfers, cards, NPP, mobile apps, and online banking must speak to each other.

6. Noise Reduction

Software must reduce false positives, not amplify them.

7. Analyst Enablement

Investigators should receive context, not clutter.

8. Scalability for Peak Fraud Events

Fraud often surges during crises, holidays, and scams going viral.

9. Localisation

Australian fraud patterns differ from other regions.

10. Resilience

APRA CPS 230 demands operational continuity and strong third-party governance.

Fraud software is now part of a bank’s resilience framework, not just its compliance toolkit.

Chapter 7: How Tookitaki Approaches Fraud Detection

Tookitaki’s approach to fraud detection is built around one core idea:
fraudsters behave like networks, not individuals.

FinCense analyses risk across relationships, devices, behaviours, and transactions to detect patterns traditional systems miss.

What makes it different:

1. A Behaviour-First Model

Instead of relying on static rules, the system understands customer behaviour over time.
This helps identify anomalies that signal account takeover or mule activity.

2. Investigation Intelligence

Tookitaki supports analysts with enriched context, visual evidence, and prioritised risks, reducing decision fatigue.

3. Multi-Channel Detection

Fraud does not stay in one place, and neither does the software.
It connects signals across payments, wallets, online banking, and transfers.

4. Designed for Both Large and Community Banks

Institutions such as Regional Australia Bank benefit from accurate detection without operational complexity.

5. Built for Real-Time Environments

FinCense supports high-velocity payments, enabling institutions to detect risk at NPP speed.

Tookitaki is not designed to overwhelm banks with rules.
It is designed to give them a clear picture of risk in a world where fraud changes daily.

Chapter 8: The Future of Fraud Detection in Australian Banking

1. Deepfake-Resistant Identity Verification

Banks will need technology that can detect video, voice, and biometric spoofing.

2. Agentic AI Assistants for Investigators

Fraud teams will have copilots that surface insights, summarise cases, and provide investigative recommendations.

3. Network-Wide Intelligence Sharing

Banks will fight fraud together, not alone, through federated learning and shared typology networks.

4. Real-Time Customer Protection

Banks will block suspicious payments before they leave the customer’s account.

5. Predictive Fraud Prevention

Systems will identify potential mule behaviour before the account becomes active.

Fraud detection will become proactive, not reactive.

Conclusion

Fraud detection software is no longer a technical add-on.
It is the digital armour protecting customers, banks, and the integrity of the financial system.

The frontline has shifted.
Criminals operate as organised networks, use automation, manipulate devices, and exploit real-time payments.
Banks need software built for this reality, not yesterday’s.

The right fraud detection solution gives banks something they cannot afford to lose:
time, clarity, and confidence.

Because in today’s Australian financial landscape, fraud moves fast.
Your software must move faster.

Fraud Detection Software for Banks: Inside the Digital War Room
Blogs
21 Nov 2025
6 min
read

AML Software in Australia: The 7 Big Questions Every Bank Should Be Asking in 2025

Choosing AML software used to be a technical decision. In 2025, it has become one of the most strategic choices a bank can make.

Introduction

Australia’s financial sector is entering a defining moment. Instant payments, cross-border digital crime, APRA’s tightening expectations, AUSTRAC’s data scrutiny, and the rise of AI are forcing banks to rethink their entire compliance tech stack.

At the centre of this shift sits one critical question: what should AML software actually do in 2025?

This blog does not give you a shopping list or a vendor comparison.
Instead, it explores the seven big questions every Australian bank, neobank, and community-owned institution should be asking when evaluating AML software. These are the questions that uncover risk, expose limitations, and reveal whether a solution is built for the next decade, not the last.

Let’s get into them.

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Question 1: Does the AML Software Understand Risk the Way Australia Defines It?

Most AML systems were designed with global rule sets that do not map neatly to Australian realities.

Australia has:

  • Distinct PEP classifications
  • Localised money mule typologies
  • Syndicated fraud patterns unique to the region
  • NPP-driven velocity in payment behaviour
  • AUSTRAC expectations around ongoing due diligence
  • APRA’s new focus on operational resilience

AML software must be calibrated to Australian behaviours, not anchored to American or European assumptions.

What to look for

  • Localised risk models trained on Australian financial behaviour
  • Models that recognise local account structures and payment patterns
  • Typologies relevant to the region
  • Adaptability to NPP and emerging scams affecting Australians
  • Configurable rule logic for Australia’s regulatory environment

If software treats all markets the same, its risk understanding will always be one step behind Australian criminals.

Question 2: Can the Software Move at the Speed of NPP?

The New Payments Platform changed everything.
What used to be processed in hours is now settled in seconds.

This means:

  • Risk scoring must be real time
  • Monitoring must be continuous
  • Alerts must be triggered instantly
  • Investigators need immediate context, not post-fact analysis

Legacy systems built for batch processing simply cannot keep up with the velocity or volatility of NPP transactions.

What to look for

  • True real-time screening and monitoring
  • Sub-second scoring
  • Architecture built for high-volume environments
  • Scalability without performance drops
  • Real-time alert triaging

If AML software cannot respond before a payment settles, it is already too late.

Question 3: Does the Software Reduce False Positives in a Meaningful Way?

Every vendor claims they reduce false positives.
The real question is how and by how much.

In Australia, many banks spend up to 80 percent of their AML effort investigating low-value alerts. This creates fatigue, delays, and inconsistent decisions.

Modern AML software must:

  • Prioritise alerts based on true behavioural risk
  • Provide contextual information alongside flags
  • Reduce noise without reducing sensitivity
  • Identify relationships, patterns, and anomalies that rules alone miss

What to look for

  • Documented false positive reduction numbers
  • Behavioural analytics that distinguish typical from atypical activity
  • Human-in-the-loop learning
  • Explainable scoring logic
  • Tiered risk categorisation

False positives drain resources.
Reducing them responsibly is a competitive advantage.

Question 4: How Does the Software Support Investigator Decision-Making?

Analysts are the heart of AML operations.
Software should not just alert them. It should empower them.

The most advanced AML platforms are moving toward investigator-centric design, helping analysts work faster, more consistently, and with greater clarity.

What to look for

  • Clear narratives attached to alerts
  • Visual network link analysis
  • Relationship mapping
  • Easy access to KYC, transaction history, and behaviour insights
  • Tools that surface relevant context without manual digging

If AML software only generates alerts but does not explain them, it is not modern software. It is a data dump.

ChatGPT Image Nov 20, 2025, 01_58_14 PM

Question 5: Is the AML Software Explainable Enough for AUSTRAC?

AUSTRAC’s reviews increasingly require banks to justify their risk models and demonstrate why a decision was made.

AML software must show:

  • Why an alert was generated
  • What data was used
  • What behavioural markers contributed
  • How the system ranked or prioritised risk
  • How changes over time affected decision logic

Explainability is now a regulatory requirement, not a bonus feature.

What to look for

  • Decision logs
  • Visual explanations
  • Feature attribution for risk scoring
  • Scenario narratives
  • Governance dashboards

Opaque systems that cannot justify their reasoning leave institutions vulnerable during audits.

Question 6: How Well Does the AML Software Align With APRA’s CPS 230 Expectations?

Operational resilience is now a board-level mandate.
AML software sits inside the cluster of critical systems APRA expects institutions to govern closely.

This includes:

  • Third-party risk oversight
  • Business continuity
  • Incident management
  • Data quality controls
  • Outsourcing governance

AML software is no longer evaluated only by compliance teams.
It must satisfy risk, technology, audit, and resilience requirements too.

What to look for

  • Strong uptime track record
  • Clear incident response procedures
  • Transparent service level reporting
  • Secure and compliant hosting
  • Tested business continuity measures
  • Clear vendor accountability and control frameworks

If AML software cannot meet CPS 230 expectations, it cannot meet modern banking expectations.

Question 7: Will the Software Still Be Relevant Five Years From Now?

This is the question few institutions ask, but the one that matters most.
AML software is not a one-year decision. It is a multi-year partnership.

To future-proof compliance, banks must look beyond features and evaluate adaptability.

What to look for

  • A roadmap that includes new crime types
  • AI models that learn responsibly
  • Agentic support tools that help investigators
  • Continuous updates without major uplift projects
  • Collaborative intelligence capabilities
  • Strong alignment with emerging AML trends in Australia

This is where vendors differentiate themselves.
Some provide tools.
A few provide evolution.

A Fresh Look at Tookitaki

Tookitaki has emerged as a preferred AML technology partner among several banks across Asia-Pacific, including institutions in Australia, because it focuses less on building features and more on building confidence.

Confidence that alerts are meaningful.
Confidence that the system is explainable.
Confidence that operations remain stable.
Confidence that investigators have support.
Confidence that intelligence keeps evolving.

Rather than positioning AML as a fixed set of rules, Tookitaki approaches it as a learning discipline.

Its platform, FinCense, helps Australian institutions strengthen:

  • Real time monitoring capability
  • Consistency in analyst decisions
  • Model transparency for AUSTRAC
  • Operational resilience for APRA expectations
  • Adaptability to emerging typologies
  • Scalability for both large and community institutions like Regional Australia Bank

This is AML software designed not only to detect crime, but to grow with the institution.

Conclusion

AML software in Australia is at a crossroads.
The era of legacy rules, static scenarios, and batch processing is ending.
Banks now face a new set of expectations driven by speed, transparency, resilience, and intelligence.

The seven questions in this guide cut through the noise. They help institutions evaluate AML software not as a product, but as a long-term strategic partner for risk management.

Australia’s financial sector is changing quickly.
The right AML software will help banks move confidently into that future.
The wrong one will hold them back.

Pro tip: The strongest AML systems are not just built on good software. They are built on systems that understand the world they operate in, and evolve alongside it.

AML Software in Australia: The 7 Big Questions Every Bank Should Be Asking in 2025