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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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16 Jan 2026
5 min
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From Firefighting to Foresight: Rethinking Transaction Fraud Prevention in Singapore

Fraudsters are playing a smarter game, shouldn’t your defences be smarter too?

Transaction fraud in Singapore is no longer just a security issue—it’s a strategic challenge. As payment ecosystems evolve, fraudsters are exploiting digital rails, behavioural loopholes, and siloed detection systems to slip through unnoticed.

In this blog, we explore why traditional fraud prevention methods are falling short, what a next-gen transaction fraud prevention framework looks like, and how Singapore’s financial institutions can future-proof their defences.

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Why Transaction Fraud is Escalating in Singapore

Singapore has one of the most advanced digital banking infrastructures in the world. But with innovation comes risk.

Key Drivers of Fraud Risk:

  • Real-time payments: PayNow and FAST leave little time for fraud detection.
  • Cross-border flows: Illicit funds are moved via remittance corridors and fintech platforms.
  • Proliferation of fintech apps: Fraudsters exploit weak KYC and transaction monitoring in niche apps.
  • Evolving scam tactics: Social engineering, deepfake impersonation, and phishing are on the rise.

The result? Singaporean banks are experiencing a surge in mule account activity, identity theft, and layered fraud involving multiple platforms.

What is Transaction Fraud Prevention?

Transaction fraud prevention refers to systems, strategies, and intelligence tools used by financial institutions to:

  • Detect fraudulent transactions
  • Stop or flag suspicious activity in real time
  • Reduce customer losses
  • Comply with regulatory expectations

The key is prevention, not just detection. This means acting before money is moved or damage is done.

Traditional Fraud Prevention: Where It Falls Short

Legacy fraud prevention frameworks often rely on:

  • Static rule-based thresholds
  • After-the-fact detection
  • Manual reviews for high-value alerts
  • Limited visibility across products or platforms

The problem? Fraud today is fast, adaptive, and complex. These outdated approaches miss subtle patterns, overwhelm investigators, and delay intervention.

A New Framework for Transaction Fraud Prevention

Next-gen fraud prevention combines speed, context, intelligence, and collaboration.

Core Elements:

1. Real-Time Transaction Monitoring

Every transaction is assessed for risk as it happens—across all payment channels.

2. Behavioural Risk Models

Fraud detection engines compare current actions against baseline behaviour for each customer.

3. AI-Powered Risk Scoring

Advanced machine learning models assign dynamic risk scores that influence real-time decisions.

4. Federated Typology Sharing

Institutions access fraud scenarios shared by peer banks and regulators without exposing sensitive data.

5. Graph-Based Network Detection

Analysts visualise connections between mule accounts, devices, locations, and beneficiaries.

6. Integrated Case Management

Suspicious transactions are directly escalated into investigation pipelines with enriched context.

Real-World Examples of Preventable Fraud

✅ Utility Scam Layering

Scammers use stolen accounts to pay fake utility bills, then request chargebacks to mask laundering. These can be caught through layered transaction patterns.

✅ Deepfake CEO Voice Scam

A finance team almost transfers SGD 500,000 after receiving a video call from a “CFO.” Behavioural anomalies and device risk profiling can flag this in real-time.

✅ Organised Mule Account Chains

Funds pass through 8–10 sleeper accounts before exiting the system. Graph analytics expose these as coordinated rather than isolated events.

The Singapore Edge: Localising Fraud Prevention

Fraud patterns in Singapore have unique characteristics:

  • Local scam syndicates often use SingPass and SMS spoofing
  • Elderly victims targeted through impersonation scams
  • Fintech apps used for layering due to fewer controls

A good fraud prevention system should reflect:

  • MAS typologies and alerts
  • Red flags derived from real scam cases
  • Adaptability to local payment systems like FAST, PayNow, GIRO
ChatGPT Image Jan 16, 2026, 11_40_33 AM

How Tookitaki Enables Smart Transaction Fraud Prevention

Tookitaki’s FinCense platform offers an integrated fraud and AML prevention suite that:

  • Monitors transactions in real-time using adaptive AI and federated learning
  • Supports scenario-based detection built from 1,200+ community-contributed typologies
  • Surfaces network-level risk signals using graph analytics
  • Auto-generates case summaries for faster STR filing and reporting
  • Reduces false positives while increasing true fraud detection rates

With FinCense, banks are moving from passive alerts to proactive intervention.

Evaluating Transaction Fraud Prevention Software: Key Questions

  • Can it monitor all transaction types in real time?
  • Does it allow dynamic threshold tuning based on risk?
  • Can it integrate with existing AML or case management tools?
  • Does it use real-world scenarios, not just abstract rules?
  • Can it support regulatory audits with explainable decisions?

Best Practices for Proactive Fraud Prevention

  1. Combine fraud and AML views for holistic oversight
  2. Use shared typologies to learn from others’ incidents
  3. Deploy AI responsibly, ensuring interpretability
  4. Flag anomalies early, even if not yet confirmed as fraud
  5. Engage fraud operations teams in model tuning and validation

Looking Ahead: Future of Transaction Fraud Prevention

The future of fraud prevention is:

  • Predictive: Using AI to simulate fraud before it happens
  • Collaborative: Sharing signals across banks and fintechs
  • Contextual: Understanding customer intent, not just rules
  • Embedded: Integrated into every step of the payment journey

As Singapore’s financial sector continues to grow in scale and complexity, fraud prevention must keep pace—not just in technology, but in mindset.

Final Thoughts: Don’t Just Detect—Disrupt

Transaction fraud prevention is no longer just about stopping bad transactions. It’s about disrupting fraud networks, protecting customer trust, and reducing operational cost.

With the right strategy and systems in place, Singapore’s financial institutions can lead the region in smarter, safer finance.

Because when money moves fast, protection must move faster.

From Firefighting to Foresight: Rethinking Transaction Fraud Prevention in Singapore
Blogs
14 Jan 2026
6 min
read

Fraud Detection and Prevention: How Malaysia Can Stay Ahead of Modern Financial Crime

n a world of instant payments and digital trust, fraud detection and prevention has become the foundation of Malaysia’s financial resilience.

Fraud Has Become a Daily Reality in Digital Banking

Fraud is no longer a rare or isolated event. In Malaysia’s digital economy, it has become a persistent and evolving threat that touches banks, fintechs, merchants, and consumers alike.

Mobile banking, QR payments, e-wallets, instant transfers, and online marketplaces have reshaped how money moves. But these same channels are now prime targets for organised fraud networks.

Malaysian financial institutions are facing rising incidents of:

  • Investment and impersonation scams
  • Account takeover attacks
  • Mule assisted payment fraud
  • QR and wallet abuse
  • Cross-border scam syndicates
  • Fraud that transitions rapidly into money laundering

Fraud today is not just about loss. It damages trust, disrupts customer confidence, and creates regulatory exposure.

This is why fraud detection and prevention is no longer a standalone function. It is a core capability that determines how safe and trusted the financial system truly is.

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What Does Fraud Detection and Prevention Really Mean?

Fraud detection and prevention refers to the combined ability to identify fraudulent activity early and stop it before financial loss occurs.

Detection focuses on recognising suspicious behaviour.
Prevention focuses on intervening in real time.

Together, they form a continuous protection cycle that includes:

  • Monitoring customer and transaction behaviour
  • Identifying anomalies and risk patterns
  • Assessing intent and context
  • Making real-time decisions
  • Blocking or challenging suspicious activity
  • Learning from confirmed fraud cases

Modern fraud detection and prevention is proactive, not reactive. It does not wait for losses to occur before acting.

Why Fraud Detection and Prevention Is Critical in Malaysia

Malaysia’s financial environment creates unique challenges that make advanced fraud controls essential.

1. Instant Payments Leave No Margin for Error

With real-time transfers and QR payments, fraudulent funds can move out of the system in seconds. Post-transaction reviews are simply too late.

2. Scams Drive a Large Share of Fraud

Many fraud cases involve customers initiating legitimate looking transactions after being manipulated through social engineering. Traditional rules struggle to detect these scenarios.

3. Mule Networks Enable Scale

Criminals distribute fraud proceeds across many accounts to avoid detection. Individual transactions may look harmless, but collectively they form organised fraud networks.

4. Cross-Border Exposure Is Growing

Fraud proceeds are often routed quickly to offshore accounts or foreign payment platforms, increasing complexity and recovery challenges.

5. Regulatory Expectations Are Rising

Bank Negara Malaysia expects institutions to demonstrate strong preventive controls, timely intervention, and consistent governance over fraud risk.

Fraud detection and prevention solutions must therefore operate in real time, understand behaviour, and adapt continuously.

How Fraud Detection and Prevention Works

An effective fraud protection framework operates through multiple layers of intelligence.

1. Data Collection and Context Building

The system analyses transaction details, customer history, device information, channel usage, and behavioural signals.

2. Behavioural Profiling

Each customer has a baseline of normal behaviour. Deviations from this baseline raise risk indicators.

3. Anomaly Detection

Machine learning models identify unusual activity such as abnormal transfer amounts, sudden changes in transaction patterns, or new beneficiaries.

4. Risk Scoring and Decisioning

Each event receives a dynamic risk score. Based on this score, the system decides whether to allow, challenge, or block the activity.

5. Real-Time Intervention

High-risk transactions can be stopped instantly before funds leave the system.

6. Investigation and Feedback

Confirmed fraud cases feed back into the system, improving future detection accuracy.

This closed-loop approach allows fraud detection and prevention systems to evolve alongside criminal behaviour.

Why Traditional Fraud Controls Are Failing

Many financial institutions still rely on outdated fraud controls that were designed for slower, simpler environments.

Common shortcomings include:

  • Static rules that fail to detect new fraud patterns
  • High false positives that disrupt legitimate customers
  • Manual reviews that delay intervention
  • Limited behavioural intelligence
  • Siloed fraud and AML systems
  • Poor visibility into coordinated fraud activity

Fraud has evolved into a fast-moving, adaptive threat. Controls that do not learn and adapt quickly become ineffective.

The Role of AI in Fraud Detection and Prevention

Artificial intelligence has transformed fraud prevention from a reactive process into a predictive capability.

1. Behavioural Intelligence

AI understands how customers normally transact and flags subtle deviations that static rules cannot capture.

2. Predictive Detection

AI models identify early indicators of fraud before losses occur.

3. Real-Time Decisioning

AI enables instant responses without human delay.

4. Reduced False Positives

Contextual analysis helps avoid unnecessary transaction blocks and customer friction.

5. Explainable Decisions

Modern AI systems provide clear reasons for each decision, supporting governance and customer communication.

AI powered fraud detection and prevention is now essential for institutions operating in real-time payment environments.

ChatGPT Image Jan 13, 2026, 08_53_33 PM

Tookitaki’s FinCense: A Unified Approach to Fraud Detection and Prevention

While many solutions treat fraud as a standalone problem, Tookitaki’s FinCense approaches fraud detection and prevention as part of a broader financial crime ecosystem.

FinCense integrates fraud prevention, AML monitoring, onboarding intelligence, and case management into a single platform. This unified approach is especially powerful in Malaysia’s fast-moving digital landscape.

Agentic AI for Real-Time Fraud Prevention

FinCense uses Agentic AI to analyse transactions and customer behaviour in real time.

The system:

  • Evaluates behavioural context instantly
  • Detects coordinated activity across accounts
  • Generates clear risk explanations
  • Recommends appropriate actions

This allows institutions to prevent fraud at machine speed while retaining transparency and control.

Federated Intelligence Through the AFC Ecosystem

Fraud patterns rarely remain confined to one institution or one country.

FinCense connects to the Anti-Financial Crime Ecosystem, enabling fraud detection and prevention to benefit from shared regional intelligence across ASEAN.

Malaysian institutions gain early visibility into:

  • Scam driven fraud patterns
  • Mule behaviour observed in neighbouring markets
  • QR and wallet abuse techniques
  • Emerging cross-border fraud typologies

This collaborative intelligence significantly strengthens local defences.

Explainable AI for Trust and Governance

Every fraud decision in FinCense is explainable.

Investigators, auditors, and regulators can clearly see:

  • Which behaviours triggered the alert
  • How risk was assessed
  • Why an action was taken

This transparency builds trust and supports regulatory alignment.

Integrated Fraud and AML Protection

Fraud and money laundering are closely linked.

FinCense connects fraud events with downstream AML monitoring, allowing institutions to:

  • Identify mule assisted fraud early
  • Track fraud proceeds across accounts
  • Prevent laundering before escalation

This holistic view disrupts organised crime rather than isolated incidents.

Scenario Example: Preventing a Scam-Driven Transfer

A Malaysian customer initiates a large transfer after receiving investment advice through messaging apps.

On the surface, the transaction appears legitimate.

FinCense detects the risk in real time:

  1. Behavioural analysis flags an unusual transfer amount for the customer.
  2. The beneficiary account shows patterns linked to mule activity.
  3. Transaction timing matches known scam typologies from regional intelligence.
  4. Agentic AI generates a clear risk explanation instantly.
  5. The transaction is blocked and escalated for review.

The customer is protected and funds remain secure.

Benefits of Strong Fraud Detection and Prevention

Advanced fraud protection delivers measurable value.

  • Reduced fraud losses
  • Faster response to emerging threats
  • Lower false positives
  • Improved customer experience
  • Stronger regulatory confidence
  • Better visibility into fraud networks
  • Seamless integration with AML controls

Fraud detection and prevention becomes a strategic enabler rather than a reactive cost.

What to Look for in Fraud Detection and Prevention Solutions

When evaluating fraud platforms, Malaysian institutions should prioritise:

Real-Time Capability
Fraud must be stopped before funds move.

Behavioural Intelligence
Understanding customer behaviour is essential.

Explainability
Every decision must be transparent and defensible.

Integration
Fraud prevention must connect with AML and case management.

Regional Intelligence
ASEAN-specific fraud patterns must be incorporated.

Scalability
Systems must perform under high transaction volumes.

FinCense delivers all of these capabilities within a single unified platform.

The Future of Fraud Detection and Prevention in Malaysia

Fraud will continue to evolve alongside digital innovation.

Key future trends include:

  • Greater use of behavioural biometrics
  • Real-time scam intervention workflows
  • Cross-institution intelligence sharing
  • Deeper convergence of fraud and AML platforms
  • Responsible AI governance frameworks

Malaysia’s strong regulatory environment and digital adoption position it well to lead in next-generation fraud prevention.

Conclusion

Fraud detection and prevention is no longer optional. It is the foundation of trust in Malaysia’s digital financial ecosystem.

As fraud becomes faster and more sophisticated, institutions must rely on intelligent, real-time, and explainable systems to protect customers and assets.

Tookitaki’s FinCense delivers this capability. By combining Agentic AI, federated intelligence, explainable decisioning, and unified fraud and AML protection, FinCense empowers Malaysian institutions to stay ahead of modern financial crime.

In a world where money moves instantly, trust must move faster.

Fraud Detection and Prevention: How Malaysia Can Stay Ahead of Modern Financial Crime
Blogs
14 Jan 2026
6 min
read

From Rules to Reality: Why AML Transaction Monitoring Scenarios Matter More Than Ever

Effective AML detection does not start with alerts. It starts with the right scenarios.

Introduction

Transaction monitoring sits at the heart of every AML programme, but its effectiveness depends on one critical element: scenarios. These scenarios define what suspicious behaviour looks like, how it is detected, and how consistently it is acted upon.

In the Philippines, where digital payments, instant transfers, and cross-border flows are expanding rapidly, the importance of well-designed AML transaction monitoring scenarios has never been greater. Criminal networks are no longer relying on obvious red flags or large, one-off transactions. Instead, they use subtle, layered behaviour that blends into normal activity unless institutions know exactly what patterns to look for.

Many monitoring programmes struggle not because they lack technology, but because their scenarios are outdated, overly generic, or disconnected from real-world typologies. As a result, alerts increase, effectiveness declines, and investigators spend more time clearing noise than uncovering genuine risk.

Modern AML programmes are rethinking scenarios altogether. They are moving away from static rule libraries and toward intelligence-led scenario design that reflects how financial crime actually operates today.

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What Are AML Transaction Monitoring Scenarios?

AML transaction monitoring scenarios are predefined detection patterns that describe suspicious transactional behaviour associated with money laundering or related financial crimes.

Each scenario typically defines:

  • the behaviour to be monitored
  • the conditions under which activity becomes suspicious
  • the risk indicators involved
  • the logic used to trigger alerts

Scenarios translate regulatory expectations and typologies into operational detection logic. They determine what the monitoring system looks for and, equally important, what it ignores.

A strong scenario framework ensures that alerts are meaningful, explainable, and aligned with real risk rather than theoretical assumptions.

Why Scenarios Are the Weakest Link in Many AML Programmes

Many institutions invest heavily in transaction monitoring platforms but overlook the quality of the scenarios running within them. This creates a gap between system capability and actual detection outcomes.

One common issue is over-reliance on generic scenarios. These scenarios are often based on high-level guidance and apply the same logic across all customer types, products, and geographies. While easy to implement, they lack precision and generate excessive false positives.

Another challenge is static design. Once configured, scenarios often remain unchanged for long periods. Meanwhile, criminal behaviour evolves continuously. This mismatch leads to declining effectiveness over time.

Scenarios are also frequently disconnected from real investigations. Feedback from investigators about false positives or missed risks does not always flow back into scenario refinement, resulting in repeated inefficiencies.

Finally, many scenario libraries are not contextualised for local risk. Patterns relevant to the Philippine market may differ significantly from those in other regions, yet institutions often rely on globally generic templates.

These weaknesses make scenario design a critical area for transformation.

The Shift from Rule-Based Scenarios to Behaviour-Led Detection

Traditional AML scenarios are largely rule-based. They rely on thresholds, counts, and static conditions, such as transaction amounts exceeding a predefined value or activity involving certain jurisdictions.

While rules still play a role, they are no longer sufficient on their own. Modern AML transaction monitoring scenarios are increasingly behaviour-led.

Behaviour-led scenarios focus on how customers transact rather than how much they transact. They analyse patterns over time, changes in behaviour, and relationships between transactions. This allows institutions to detect suspicious activity even when individual transactions appear normal.

For example, instead of flagging a single large transfer, a behaviour-led scenario may detect repeated low-value transfers that collectively indicate layering or structuring. Instead of focusing solely on geography, it may examine sudden changes in counterparties or transaction velocity.

This shift significantly improves detection accuracy while reducing unnecessary alerts.

ChatGPT Image Jan 13, 2026, 08_42_04 PM

Common AML Transaction Monitoring Scenarios in Practice

While scenarios must always be tailored to an institution’s risk profile, several categories are commonly relevant in the Philippine context.

One category involves rapid movement of funds through accounts. This includes scenarios where funds are received and quickly transferred out with little or no retention, often across multiple accounts. Such behaviour may indicate mule activity or layering.

Another common category focuses on structuring. This involves breaking transactions into smaller amounts to avoid thresholds. When analysed individually, these transactions may appear benign, but taken together they reveal deliberate intent.

Cross-border scenarios are also critical. These monitor patterns involving frequent international transfers, particularly when activity does not align with the customer’s profile or stated purpose.

Scenarios related to third-party funding are increasingly important. These detect situations where accounts are consistently funded or drained by unrelated parties, a pattern often associated with money laundering or fraud facilitation.

Finally, scenarios that monitor dormant or newly opened accounts can be effective. Sudden spikes in activity shortly after account opening or reactivation may signal misuse.

Each of these scenarios becomes far more effective when designed with behavioural context rather than static thresholds.

Designing Effective AML Transaction Monitoring Scenarios

Effective scenarios start with a clear understanding of risk. Institutions must identify which threats are most relevant based on their products, customers, and delivery channels.

Scenario design should begin with typologies rather than rules. Typologies describe how criminals operate in the real world. Scenarios translate those narratives into detectable patterns.

Calibration is equally important. Thresholds and conditions must reflect actual customer behaviour rather than arbitrary values. Overly sensitive scenarios generate noise, while overly restrictive ones miss risk.

Scenarios should also be differentiated by customer segment. Retail, corporate, SME, and high-net-worth customers exhibit different transaction patterns. Applying the same logic across all segments reduces effectiveness.

Finally, scenarios must be reviewed regularly. Feedback from investigations, regulatory findings, and emerging intelligence should feed directly into ongoing refinement.

The Role of Technology in Scenario Effectiveness

Modern technology significantly enhances how scenarios are designed, executed, and maintained.

Advanced transaction monitoring platforms allow scenarios to incorporate multiple dimensions, including behaviour, relationships, and historical context. This reduces reliance on simplistic rules.

Machine learning models can support scenario logic by identifying anomalies and patterns that inform threshold tuning and prioritisation.

Equally important is explainability. Scenarios must produce alerts that investigators and regulators can understand. Clear logic, transparent conditions, and documented rationale are essential.

Technology should also support lifecycle management, making it easy to test, deploy, monitor, and refine scenarios without disrupting operations.

How Tookitaki Approaches AML Transaction Monitoring Scenarios

Tookitaki treats scenarios as living intelligence rather than static configurations.

Within FinCense, scenarios are designed to reflect real-world typologies and behavioural patterns. They combine rules, analytics, and behavioural indicators to produce alerts that are both accurate and explainable.

A key strength of Tookitaki’s approach is the AFC Ecosystem. This collaborative network allows financial crime experts to contribute new scenarios, red flags, and typologies based on real cases and emerging threats. These insights continuously inform scenario design, ensuring relevance and timeliness.

Tookitaki also integrates FinMate, an Agentic AI copilot that supports investigators by summarising scenario logic, explaining why alerts were triggered, and highlighting key risk indicators. This improves investigation quality and consistency while reducing manual effort.

Together, these elements ensure that scenarios evolve alongside financial crime rather than lag behind it.

A Practical Scenario Example

Consider a bank observing increased low-value transfers across multiple customer accounts. Individually, these transactions fall below thresholds and appear routine.

A behaviour-led scenario identifies a pattern of rapid inbound and outbound transfers, shared counterparties, and consistent timing across accounts. The scenario flags coordinated behaviour indicative of mule activity.

Investigators receive alerts with clear explanations of the pattern rather than isolated transaction details. This enables faster decision-making and more effective escalation.

Without a well-designed scenario, this activity might have remained undetected until losses or regulatory issues emerged.

Benefits of Strong AML Transaction Monitoring Scenarios

Well-designed scenarios deliver tangible benefits across AML operations.

They improve detection quality by focusing on meaningful patterns rather than isolated events. They reduce false positives, allowing investigators to spend time on genuine risk. They support consistency, ensuring similar behaviour is treated the same way across the institution.

From a governance perspective, strong scenarios improve explainability and audit readiness. Regulators can see not just what was detected, but why.

Most importantly, effective scenarios strengthen the institution’s overall risk posture by ensuring monitoring reflects real threats rather than theoretical ones.

The Future of AML Transaction Monitoring Scenarios

AML transaction monitoring scenarios will continue to evolve as financial crime becomes more complex.

Future scenarios will increasingly blend rules with machine learning insights, allowing for adaptive detection that responds to changing behaviour. Collaboration across institutions will play a greater role, enabling shared understanding of emerging typologies without compromising data privacy.

Scenario management will also become more dynamic, with continuous testing, refinement, and performance measurement built into daily operations.

Institutions that invest in scenario maturity today will be better equipped to respond to tomorrow’s threats.

Conclusion

AML transaction monitoring scenarios are the backbone of effective detection. Without strong scenarios, even the most advanced monitoring systems fall short.

By moving from static, generic rules to behaviour-led, intelligence-driven scenarios, financial institutions can dramatically improve detection accuracy, reduce operational strain, and strengthen regulatory confidence.

With Tookitaki’s FinCense platform, enriched by the AFC Ecosystem and supported by FinMate, institutions can ensure their AML transaction monitoring scenarios remain relevant, explainable, and aligned with real-world risk.

In an environment where financial crime constantly adapts, scenarios must do the same.

From Rules to Reality: Why AML Transaction Monitoring Scenarios Matter More Than Ever