Compliance Hub

JMLSG Guidance and Its Importance in the UK AML Regime

Site Logo
Tookitaki
16 Dec 2020
7 min
read

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. 

By submitting the form, you agree that your personal data will be processed to provide the requested content (and for the purposes you agreed to above) in accordance with the Privacy Notice

success icon

We’ve received your details and our team will be in touch shortly.

In the meantime, explore how Tookitaki is transforming financial crime prevention.
Learn More About Us
Oops! Something went wrong while submitting the form.

Ready to Streamline Your Anti-Financial Crime Compliance?

Our Thought Leadership Guides

Blogs
22 Aug 2025
4 min
read

Stopping Fraud in Its Tracks: Transaction Fraud Prevention in Taiwan’s Digital Age

Fraud moves fast and in Taiwan’s digital-first economy, transaction fraud prevention has become the frontline of trust.

With payment volumes soaring across e-wallets, online banking, and instant transfers, the fight against fraud is no longer about catching criminals after the fact. It’s about detecting and stopping them in real time. Advanced platforms such as Tookitaki’s FinCense are redefining how financial institutions in Taiwan and beyond approach this challenge — blending AI, collaboration, and regulatory alignment to build smarter defences.

Talk to an Expert

Taiwan’s Digital Finance Boom and the Fraud Challenge

Taiwan has become one of Asia’s leaders in digital payments, with e-wallet adoption rising sharply and cross-border transactions powering e-commerce. But speed and convenience come with vulnerabilities:

  • Account Takeover (ATO): Fraudsters gain access to accounts via phishing or malware.
  • Money Mules: Recruited individuals move illicit funds through small-value transactions.
  • Synthetic Identities: Fake profiles slip past onboarding checks to exploit payment rails.

Regulators such as the Financial Supervisory Commission (FSC) have ramped up requirements, urging banks and payment firms to adopt risk-based monitoring. But compliance alone isn’t enough — prevention requires smarter tools and adaptive intelligence, the kind being pioneered by Tookitaki’s AI-powered compliance platform.

What Is Transaction Fraud Prevention?

At its core, transaction fraud prevention means identifying, analysing, and blocking suspicious payments before they can be completed. Unlike post-event investigations, prevention focuses on:

  1. Real-Time Detection – Flagging anomalies instantly.
  2. Behavioural Analytics – Profiling normal user patterns to spot deviations.
  3. Risk Scoring – Assigning risk levels to every transaction.
  4. Adaptive Learning – Using AI to refine rules as fraud evolves.

For Taiwan, where instant payments via the Financial Information Service Co. (FISC) platform are mainstream, real-time fraud prevention is a necessity. Platforms like FinCense help banks achieve this by combining speed with precision.

Key Fraud Risks in Taiwan

1. Account Takeover via Phishing

Taiwanese banks report rising cases of SMS phishing (“smishing”), where fraudsters impersonate institutions. Once accounts are breached, rapid fund transfers are executed before victims react.

2. Online Investment Scams

Cross-border scam syndicates target Taiwanese consumers with fraudulent investment schemes, funnelling proceeds through mule networks.

3. Social Engineering

“Pig butchering” scams, romance fraud, and fake job offers have become prominent, with victims manipulated into initiating fraudulent transfers themselves.

4. Merchant Fraud

E-commerce sellers set up fake storefronts, collect payments, and disappear, leaving banks to handle disputes and reputational risks.

ChatGPT Image Aug 21, 2025, 01_37_44 PM

Strategies for Effective Transaction Fraud Prevention

Real-Time Monitoring

Fraud can unfold in seconds. Systems must analyse every transaction as it occurs, applying machine learning to flag suspicious transfers instantly. Tookitaki’s FinCense does this by ingesting real-time data streams and applying dynamic thresholds that adapt as fraud tactics change.

AI-Driven Risk Modelling

Instead of static rules, AI models learn from both fraud attempts and genuine behaviour. For example, FinCense leverages federated learning from a global network of institutions, enabling it to detect anomalies like unusual device fingerprints or abnormal transaction velocity — even when fraudsters attempt never-before-seen tactics.

Cross-Institution Collaboration

Fraudsters rarely confine themselves to one bank. Taiwan’s industry can strengthen defences by sharing red flags across institutions. Through the AFC Ecosystem, Tookitaki empowers banks and fintechs to access shared typologies and indicators, helping the industry act collectively against emerging fraud schemes.

Regulatory Alignment

The FSC requires strict fraud monitoring standards. Tookitaki’s compliance solutions are designed with explainable AI and governance frameworks, aligning directly with regulatory expectations while maintaining operational efficiency.

Customer Awareness

Technology alone isn’t enough. Banks should run consumer education campaigns to help customers spot phishing attempts and suspicious investment offers. FinCense complements this by reducing false positives, ensuring customers are not unnecessarily disrupted while genuine fraud attempts are intercepted.

Transaction Fraud Prevention in Practice

Case Example:

A Taiwanese bank detected an unusual pattern where multiple accounts began transferring small sums to the same overseas merchant. Using behavioural analytics powered by AI, the system flagged it as mule activity. Within minutes, the institution froze accounts, reported to the FSC, and prevented further losses.

Solutions like FinCense allow this type of proactive monitoring at scale, reducing detection lag and limiting potential reputational damage.

How Technology Is Raising the Bar

Transaction fraud prevention is no longer just about blacklists or simple thresholds. Cutting-edge solutions now combine:

  • Machine Learning Models trained on fraud typologies
  • Federated Intelligence Sharing across institutions to learn from global red flags
  • Explainable AI (XAI) to ensure transparency in decisions
  • Automated Investigation Tools to reduce false positives and improve efficiency

Tookitaki’s FinCense unites these capabilities into a single compliance platform — enabling financial institutions in Taiwan to monitor transactions in real time, adapt to evolving risks, and demonstrate clear accountability to regulators.

Why Transaction Fraud Prevention Matters for Taiwan’s Reputation

Taiwan’s financial system is a trusted hub in Asia. Yet with global watchdogs like FATF scrutinising AML/CFT effectiveness, a weak approach to fraud prevention could tarnish the country’s standing.

Robust prevention not only protects banks and customers — it safeguards Taiwan’s role as a secure, innovation-driven financial market. Tookitaki’s role as the “Trust Layer to fight financial crime” helps institutions balance growth and security, ensuring trust remains central to Taiwan’s digital finance journey.

Conclusion: Building Smarter Defences for Tomorrow

Fraudsters are fast, but Taiwan’s financial industry can be faster. By investing in transaction fraud prevention powered by AI, data collaboration, and regulatory alignment, banks and payment firms can build a financial system rooted in trust.

With advanced platforms like Tookitaki’s FinCense, institutions can move beyond reactive defence and adopt proactive, intelligent, and collective prevention strategies. Taiwan now has the opportunity to set the benchmark for Asia — proving that convenience and security can go hand in hand.

Stopping Fraud in Its Tracks: Transaction Fraud Prevention in Taiwan’s Digital Age
Blogs
22 Aug 2025
5 min
read

Chasing Zero Fraud: Finding the Best Anti-Fraud Solution for Australia

Fraudsters are getting smarter — but the best anti-fraud solutions are evolving even faster.

Fraud in Australia is no longer just about stolen credit cards or phishing emails. Today, fraudsters use AI deepfakes, synthetic identities, and mule networks to move billions through legitimate institutions. Scamwatch reports that Australians lost over AUD 3 billion in 2024, and regulators are tightening expectations. In this climate, choosing the best anti-fraud solution isn’t just an IT decision — it’s a strategic imperative.

Talk to an Expert

Why Fraud Prevention Has Become Business-Critical in Australia

1. Instant Payment Risks

The New Payments Platform (NPP) has made payments faster, but it also allows criminals to launder money in seconds.

2. Social Engineering & Scam Surge

Romance scams, impersonation fraud, and investment scams are rising sharply. Many involve victims authorising payments themselves — a challenge for traditional detection systems.

3. Regulatory Pressure

AUSTRAC and ASIC expect financial institutions to adopt proactive fraud prevention. Weak controls can lead to fines, reputational loss, and customer churn.

4. Consumer Trust

Australians expect safe, frictionless digital experiences. A single fraud incident can erode customer loyalty.

What Defines the Best Anti-Fraud Solution?

1. Real-Time Fraud Detection

The solution must monitor and analyse transactions instantly, with no batch delays.

  • Velocity monitoring
  • Device and IP fingerprinting
  • Behavioural biometrics
  • Pattern recognition

2. AI and Machine Learning

The best anti-fraud systems use AI to adapt to new typologies:

  • Spot anomalies that rules miss
  • Reduce false positives
  • Continuously improve detection accuracy

3. Multi-Channel Protection

Covers fraud across:

  • Bank transfers
  • Card payments
  • E-wallets and digital wallets
  • Remittances and cross-border corridors
  • Crypto exchanges

4. End-to-End Case Management

Integrated workflows that allow fraud teams to investigate, resolve, and report within the same system.

5. Regulatory Alignment

Supports AUSTRAC compliance with audit trails, suspicious matter reporting, and explainability.

ChatGPT Image Aug 21, 2025, 01_07_51 PM

Use Cases for Anti-Fraud Solutions in Australia

  • Account Takeover (ATO): Detects unusual login + transfer behaviour.
  • Payroll Fraud: Flags sudden beneficiary changes in salary disbursement files.
  • Romance & Investment Scams: Detects unusual transfer chains to new or overseas accounts.
  • Card-Not-Present Fraud: Blocks suspicious e-commerce transactions.
  • Crypto Laundering: Identifies fiat-to-crypto activity linked to high-risk wallets.

Red Flags the Best Anti-Fraud Solution Should Catch

  • Large transfers to newly added beneficiaries
  • Multiple small transactions in rapid succession (smurfing)
  • Login from a new device/IP followed by immediate transfers
  • Customers suddenly transacting with high-risk jurisdictions
  • Beneficiary accounts linked to mule networks

How to Choose the Best Anti-Fraud Solution in Australia

Key questions to ask:

  1. Can it handle real-time detection across all channels?
  2. Does it integrate seamlessly with your AML systems?
  3. Is it powered by adaptive AI that learns from evolving fraud tactics?
  4. How well does it reduce false positives?
  5. Does it meet AUSTRAC’s compliance requirements?
  6. Does it come with local expertise and support?

Spotlight: Tookitaki’s FinCense as the Best Anti-Fraud Solution

Among global offerings, FinCense is recognised as one of the best anti-fraud solutions for Australian institutions.

  • Agentic AI detection for real-time fraud monitoring across banking, payments, and remittances.
  • Federated learning from the AFC Ecosystem, bringing in global crime typologies and real-world scenarios.
  • FinMate AI copilot helps investigators close cases faster with summarised alerts and recommendations.
  • Cross-channel visibility covering transactions from cards to crypto.
  • Regulator-ready transparency with explainable AI and complete audit trails.

FinCense not only detects fraud — it prevents it by continuously learning and adapting to new scam typologies.

Conclusion: Prevention = Protection = Trust

In Australia’s high-speed financial landscape, the best anti-fraud solution is the one that balances real-time detection, adaptive intelligence, and seamless compliance. It’s not just about stopping fraud — it’s about building trust and future-proofing your institution.

Pro tip: Don’t just ask if a solution can detect today’s fraud. Ask if it can evolve with tomorrow’s scams.

Chasing Zero Fraud: Finding the Best Anti-Fraud Solution for Australia
Blogs
21 Aug 2025
5 min
read

Malaysia’s Compliance Edge: Why an Industry-Leading AML Solution Is Now Essential

Financial crime is moving faster than ever — and Malaysia needs an AML solution that can move faster still.

The Rising Stakes in Malaysia’s Fight Against Financial Crime

In Malaysia, the financial sector is at a crossroads. With rapid digitalisation, the boom in fintech adoption, and cross-border flows surging, financial crime has found new entry points. Bank Negara Malaysia (BNM) has been firm in its stance: compliance is not optional, and institutions that fail to meet evolving standards face reputational and financial fallout.

At the same time, fraudsters are becoming more sophisticated. From money mule networks exploiting young workers and students to investment scams powered by social engineering and deepfakes, Malaysia is seeing threats that transcend borders.

Against this backdrop, the demand is clear: financial institutions need an industry-leading AML solution that not only meets regulatory expectations but also builds consumer trust in a fast-changing market.

Talk to an Expert

Why “Industry Leading” Is More Than a Buzzword

Every vendor claims to offer the “best” AML software, but in practice, very few solutions rise to the level of being industry leading. In the Malaysian context, where financial institutions must juggle FATF recommendations, BNM guidelines, and ASEAN cross-border risks, the definition of “industry leading” is clear.

An AML solution in Malaysia today must be:

  • AI-driven and adaptive — able to evolve with new money laundering and fraud typologies.
  • Regulator-aligned — transparent, explainable, and in line with AI governance principles.
  • Comprehensive — covering both AML and fraud in real-time, across multiple payment channels.
  • Scalable — capable of supporting banks and fintechs with diverse customer bases and transaction volumes.
  • Collaborative — leveraging intelligence beyond siloed data to detect emerging risks faster.

Anything less leaves financial institutions vulnerable.

The Challenge with Legacy AML Systems

Many Malaysian banks and fintechs still rely on legacy transaction monitoring systems. While these systems may tick the compliance box, they struggle with modern threats. The common pain points include:

  • High false positives — compliance teams are overwhelmed with noise instead of meaningful alerts.
  • Static rule sets — traditional systems cannot keep pace with the speed of criminal innovation.
  • Limited explainability — leaving compliance officers unable to justify decisions to regulators.
  • Fragmentation — siloed systems across AML and fraud prevention create blind spots in detection.

The result? Compliance teams are overstretched, risks are missed, and customer trust is eroded.

ChatGPT Image Aug 20, 2025, 02_35_11 PM

Tookitaki’s FinCense: Malaysia’s Industry-Leading AML Solution

This is where Tookitaki’s FinCense stands apart — not just as another AML system, but as the Trust Layer to fight financial crime.

FinCense is purpose-built to help financial institutions in Malaysia and beyond move from reactive compliance to proactive prevention. Here’s why it leads the industry:

1. Agentic AI Workflows

FinCense harnesses Agentic AI, a next-generation compliance framework where AI agents don’t just analyse data but take proactive actions across the investigation lifecycle. This enables:

  • Automated alert triage
  • Smarter case management
  • Real-time recommendations for compliance officers

The outcome: compliance teams spend less time firefighting and more time making strategic decisions.

2. Federated Learning: Collective Intelligence at Scale

Unlike siloed systems, FinCense taps into a federated learning model through the AFC Ecosystem — a community-driven network of financial institutions, regulators, and compliance experts. This allows Malaysian banks to detect threats that may have first emerged in other ASEAN markets, giving them a head start against syndicates.

3. Explainable, Regulator-Aligned AI

Trust in compliance technology hinges on explainability. FinCense is designed to be fully explainable and auditable, aligned with frameworks like Singapore’s AI Verify. For Malaysian banks, this ensures regulators can clearly understand the basis for alerts, reducing friction and enhancing oversight.

4. End-to-End Coverage: AML + Fraud

FinCense goes beyond AML, offering integrated coverage across:

  • Transaction monitoring
  • Name screening
  • Fraud detection
  • Smart disposition and narration tools for investigations

This eliminates the need for multiple systems and ensures compliance teams have a single view of risk.

5. ASEAN Market Fit

FinCense is not a one-size-fits-all solution. Its scenarios and typologies are tailored to the realities of ASEAN markets, including Malaysia’s unique mix of cross-border remittances, e-wallet adoption, and high cash usage. This localisation ensures higher detection accuracy and relevance.

What This Means for Malaysian Banks and Fintechs

Adopting an industry-leading AML solution like FinCense translates to tangible benefits:

  • Reduced Compliance Costs — through automation and lower false positives.
  • Faster, More Accurate Detection — stopping illicit funds before they can be layered or withdrawn.
  • Regulatory Confidence — meeting BNM and FATF expectations with explainable, auditable AI.
  • Stronger Customer Trust — safeguarding against scams and building confidence in digital finance.

With Malaysia pushing to strengthen its financial system and attract international investment, trust is the new currency. A compliance framework that prevents financial crime effectively is no longer optional — it is foundational.

The Road Ahead: Building Malaysia’s Trust Layer

Financial crime is only going to get smarter. With the rise of instant payments, deepfake-driven scams, and cross-border mule networks, Malaysia’s financial sector needs a solution that evolves just as quickly.

Tookitaki’s FinCense is more than software — it is the Trust Layer that empowers banks and fintechs to detect risks early, protect customers, and stay a step ahead of regulators and criminals alike.

For Malaysian financial institutions, the choice is clear: staying competitive in the region means adopting an industry-leading AML solution that can deliver speed, precision, and transparency at scale.

Malaysia’s Compliance Edge: Why an Industry-Leading AML Solution Is Now Essential