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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
26 Dec 2025
6 min
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The Complete AML Software Guide for Banks and Financial Institutions

AML software is no longer just a compliance requirement. It is a core system that determines how effectively banks detect risk, protect customers, and operate with confidence.

Introduction

Anti money laundering compliance has changed dramatically over the past decade. What was once a largely rules driven, reactive process is now a complex, intelligence led discipline shaped by real time payments, evolving criminal behaviour, and increasing regulatory expectations.

At the centre of this shift sits AML software.

For banks, credit unions, fintechs, and regulated financial institutions, AML software is no longer just a monitoring tool. It is the engine that connects customer risk assessment, transaction monitoring, investigations, regulatory reporting, and governance into a single operational framework.

This guide explains what AML software actually does in modern financial institutions, how it is used day to day, where legacy systems fall short, and what organisations should look for when evaluating modern AML platforms. It is written for compliance leaders, operations teams, and decision makers who want clarity rather than marketing language.

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What Is AML Software in Practice

At a high level, AML software helps financial institutions identify, assess, and manage money laundering and related financial crime risks. But that definition only scratches the surface.

In practice, AML software performs five interconnected functions.

1. Customer risk assessment

AML software evaluates customer risk based on factors such as profile characteristics, geographic exposure, product usage, and known risk indicators. This risk assessment influences how closely a customer is monitored over time.

2. Transaction monitoring

The software continuously analyses transactions to identify unusual or suspicious activity. This includes detecting behavioural anomalies, velocity changes, structuring patterns, and potential laundering techniques.

3. Alert generation and prioritisation

When suspicious behaviour is detected, AML software generates alerts and prioritises them based on risk. High quality systems focus on alert relevance, not volume.

4. Investigation and case management

AML software provides tools for investigators to review alerts, analyse context, document findings, and make defensible decisions.

5. Regulatory reporting and auditability

The system supports the preparation of suspicious matter reports and maintains audit trails that demonstrate compliance to regulators.

AML software is therefore not a single module. It is an ecosystem that supports the entire AML lifecycle.

How AML Software Is Used Inside Banks

Understanding how AML software is used day to day helps explain why its quality matters so much.

Continuous monitoring

AML software runs constantly in the background, analysing millions of transactions and behavioural signals. It must operate reliably at scale without disrupting customer activity.

Analyst driven decision making

Alerts generated by AML software are reviewed by analysts who rely on the system to provide context, evidence, and clarity. The software shapes how quickly and accurately decisions can be made.

Ongoing risk management

Customer risk is not static. AML software updates risk profiles as behaviour changes, ensuring that monitoring remains proportionate.

Governance and oversight

Compliance leaders use AML software to track alert volumes, investigation outcomes, reporting timelines, and control effectiveness.

When AML software performs well, teams work with focus and confidence. When it performs poorly, inefficiency and risk multiply quickly.

Why Legacy AML Software Struggles Today

Many institutions still operate AML platforms designed for a very different risk environment. These systems struggle for several reasons.

Static rules

Legacy systems rely heavily on fixed thresholds. Criminals adapt quickly to these rules, reducing their effectiveness.

High false positives

Broad rules generate large volumes of alerts that are ultimately benign. This overwhelms teams and obscures real risk.

Limited behavioural intelligence

Older systems focus on transactions in isolation rather than understanding customer behaviour over time.

Fragmented workflows

Detection, investigation, and reporting often sit in separate tools, forcing analysts to piece together context manually.

Poor explainability

When systems cannot clearly explain why an alert was triggered, tuning becomes difficult and audit exposure increases.

As payments become faster and crime more sophisticated, these limitations become more pronounced.

What Modern AML Software Does Differently

Modern AML software platforms are built to address the realities of today’s financial crime landscape.

Behaviour driven detection

Instead of relying solely on rules, modern AML software analyses how customers normally behave and flags meaningful deviations.

Risk based alerting

Alerts are prioritised based on risk, allowing teams to focus on what matters most.

Integrated case management

Detection and investigation sit within a unified workflow, reducing friction and improving consistency.

Explainable analytics

Risk scores and alerts are transparent, with clear reasoning that supports regulatory scrutiny.

Scalability and performance

Modern platforms handle high transaction volumes and real time payments without degradation.

These capabilities do not eliminate the need for human judgement. They support it.

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Core Components of Effective AML Software

While implementations vary, strong AML software typically includes the following components.

Customer risk engine

Establishes and updates risk profiles that influence monitoring intensity.

Transaction monitoring engine

Analyses activity across channels and products.

Alert management

Organises and prioritises alerts for efficient review.

Case management

Provides structured workflows, evidence capture, and decision documentation.

Reporting and audit layer

Supports regulatory reporting and maintains complete audit trails.

The strength of an AML platform depends on how well these components work together.

Regulatory Expectations and AML Software

Regulators do not mandate specific technologies, but they do expect outcomes that AML software must support.

Financial institutions are expected to demonstrate:

  • A risk based approach to monitoring
  • Clear reasoning behind decisions
  • Timely escalation and reporting
  • Consistent investigation quality
  • Strong governance and auditability

AML software is the primary mechanism through which these expectations are met in practice.

How to Evaluate AML Software

Selecting AML software is a strategic decision with long term implications. Institutions should evaluate platforms across several dimensions.

1. Detection quality

Does the software surface meaningful risk or generate noise.

2. Explainability

Can analysts and auditors understand why alerts were triggered.

3. Operational efficiency

Does the system reduce manual effort and investigation time.

4. Scalability

Can it handle growth in customers, transactions, and complexity.

5. Integration

Does it connect smoothly with existing systems and data sources.

6. Governance

Does it support oversight, reporting, and regulatory interaction.

Evaluations should focus on real operational outcomes, not feature lists.

Common Mistakes Institutions Make

Several mistakes frequently undermine AML software investments.

Treating AML software as a compliance checkbox

This leads to minimal implementations that fail under real pressure.

Over customising rules

Excessive customisation increases complexity and maintenance burden.

Ignoring investigator experience

If analysts struggle to use the system, effectiveness drops quickly.

Failing to revisit models

AML software must evolve continuously as risk changes.

Avoiding these mistakes requires both technology and governance discipline.

The Role of AI in Modern AML Software

AI plays an increasingly important role in AML software, but its value depends on how it is applied.

Effective uses of AI include:

  • Detecting subtle behavioural anomalies
  • Identifying complex networks
  • Supporting alert prioritisation
  • Assisting investigators with context and summaries

AI should enhance transparency and control, not replace them. Explainability remains critical.

How AML Software Supports Operational Resilience

AML systems are now considered critical operational infrastructure.

Strong AML software contributes to resilience by:

  • Reducing manual dependency
  • Supporting consistent processes
  • Handling volume spikes during scam waves
  • Providing clear evidence during regulatory reviews

This aligns AML more closely with enterprise risk and operational stability.

Where Tookitaki Fits in the AML Software Landscape

Tookitaki approaches AML software as an intelligence driven, end to end platform rather than a collection of disconnected tools.

Through its FinCense platform, institutions can:

  • Apply behaviour based detection
  • Reduce false positives
  • Support consistent investigations
  • Maintain clear explainability
  • Evolve typologies continuously

This approach supports institutions of varying sizes, including community owned banks such as Regional Australia Bank, in building AML programs that are effective, scalable, and defensible.

The Future of AML Software

AML software continues to evolve as financial crime changes.

Key directions include:

  • Greater use of behavioural intelligence
  • Stronger integration across fraud and AML
  • Increased use of AI assisted investigations
  • More emphasis on explainability and governance
  • Continuous adaptation rather than periodic upgrades

Institutions that view AML software as a strategic capability rather than a static system will be better positioned for the future.

Conclusion

AML software sits at the heart of modern financial crime prevention. It shapes how risk is detected, how decisions are made, and how institutions demonstrate compliance.

As financial crime grows more complex and regulators demand greater clarity, the quality of AML software becomes a defining factor in a bank’s ability to operate safely and efficiently.

The most effective AML platforms do not simply generate alerts. They provide intelligence, structure, and confidence across the entire compliance lifecycle.

For banks and financial institutions, investing in the right AML software is not just about meeting regulatory expectations. It is about building a resilient, trusted, and future ready organisation.

The Complete AML Software Guide for Banks and Financial Institutions
Blogs
24 Dec 2025
6 min
read

Building a Stronger Defence: How an Anti-Fraud System Protects Singapore’s Financial Institutions

Fraud is evolving fast—and your defences need to evolve faster.

Singapore’s financial sector, long considered a benchmark for trust and security, is facing a new wave of fraud threats. As scammers become more coordinated, tech-savvy, and cross-border in nature, the old ways of fighting fraud no longer suffice. It’s time to talk about the real solution: a modern Anti-Fraud System.

In this blog, we explore what makes an effective anti-fraud system, how it works, and why it’s essential for financial institutions operating in Singapore.

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What is an Anti-Fraud System?

An anti-fraud system is a set of technologies, processes, and intelligence models that work together to detect and prevent fraudulent activities in real time. It goes beyond basic rule-based monitoring and includes:

  • Behavioural analytics
  • Machine learning and anomaly detection
  • Real-time alerts and case management
  • Integration with external risk databases

This system forms the first line of defence for banks, fintechs, and payment platforms—helping them identify fraud before it causes financial loss or reputational damage.

The Fraud Landscape in Singapore: Why This Matters

Singapore’s position as a global financial hub makes it an attractive target for fraudsters. According to the latest police reports:

  • Over S$1.3 billion was lost to scams between 2021 and 2024
  • Investment scams, phishing, and business email compromise (BEC) are among the top fraud types
  • Mule accounts and cross-border remittance laundering continue to rise

This changing landscape demands real-time protection. Relying solely on manual reviews or post-fraud investigations can leave institutions exposed.

Core Features of a Modern Anti-Fraud System

An effective anti-fraud solution is not just a dashboard with alerts. It’s a layered, intelligent system designed to evolve with the threat. Here are its key components:

1. Real-Time Transaction Monitoring

Detect suspicious patterns as they happen—such as unusual velocity, destination mismatches, or abnormal timings.

2. Behavioural Analytics

Understand baseline customer behaviours and flag deviations, even if the transaction appears normal on the surface.

3. Multi-Channel Integration

Monitor fraud signals across payments, digital banking, mobile apps, ATMs, and even offline touchpoints.

4. Risk Scoring and Decision Engines

Assign dynamic risk scores based on real-time data, and automate low-risk approvals or high-risk interventions.

5. Case Management Workflows

Enable investigation teams to prioritise, narrate, and report fraud cases efficiently within a unified system.

6. Continuous Learning via AI

Use feedback loops to improve detection models and adapt to new fraud techniques over time.

Key Fraud Types a Strong System Should Catch

  • Account Takeover (ATO): Where fraudsters use stolen credentials or biometrics to hijack accounts
  • Authorised Push Payment Fraud (APP): Victims are socially engineered into sending money willingly
  • Synthetic Identity Fraud: Fake profiles created with a mix of real and false data to open accounts
  • Money Mule Activity: Rapid in-and-out fund movement across multiple accounts, often linked to scams
  • Payment Diversion & Invoice Fraud: Common in B2B transactions and cross-border settlements

Compliance and Fraud: Two Sides of the Same Coin

While AML and fraud prevention often sit in different departments, modern anti-fraud systems blur the lines. For example:

  • A mule account used in a scam can also be part of a money laundering ring
  • Layering via utility payments may signal both laundering and unauthorised funds

Singapore’s regulators—including MAS and the Commercial Affairs Department—expect institutions to implement robust controls across both fraud and AML risk. That means your system should support integrated oversight.

Challenges Faced by Financial Institutions

Implementing a strong anti-fraud system is not without its hurdles:

  • High false positives overwhelm investigation teams
  • Siloed systems between fraud, compliance, and customer experience teams
  • Lack of localised threat data, especially for emerging typologies
  • Legacy infrastructure that can't scale with real-time needs

To solve these challenges, the solution must be both intelligent and adaptable.

How Tookitaki Helps: A Next-Gen Anti-Fraud System for Singapore

Tookitaki’s FinCense platform is a purpose-built compliance suite that brings AML and fraud detection under one roof. For anti-fraud operations, it offers:

  • Real-time monitoring across all payment types
  • Federated learning to learn from shared risk signals across banks without sharing sensitive data
  • Scenario-based typologies curated from the AFC Ecosystem to cover mule networks, scam layering, and synthetic identities
  • AI-powered Smart Disposition Engine that reduces investigation time and false alerts

Singapore institutions already using Tookitaki report:

  • 3.5x analyst productivity improvement
  • 72% reduction in false positives
  • Faster detection of new scam types through community-driven scenarios
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Five Best Practices to Strengthen Your Anti-Fraud System

  1. Localise Detection Models: Use region-specific typologies and scam techniques
  2. Integrate AML and Fraud: Build a shared layer of intelligence
  3. Automate Where Possible: Focus your analysts on complex cases
  4. Use Explainable AI: Ensure regulators and investigators can audit decisions
  5. Collaborate with Ecosystems: Tap into shared intelligence from peers and industry networks

Final Thoughts: Smarter, Not Just Faster

In the race against fraud, speed matters. But intelligence matters more.

A modern anti-fraud system helps Singapore’s financial institutions move from reactive to proactive. It doesn’t just flag suspicious transactions—it understands context, learns from patterns, and works collaboratively across departments.

The result? Stronger trust. Lower losses. And a future-proof defence.

Building a Stronger Defence: How an Anti-Fraud System Protects Singapore’s Financial Institutions
Blogs
24 Dec 2025
6 min
read

Inside the Modern Transaction Monitoring System: How Banks Detect Risk in Real Time

Every suspicious transaction tells a story — the challenge is recognising it before the money disappears.

Introduction

Transaction monitoring has become one of the most critical pillars of financial crime prevention. For banks and financial institutions in the Philippines, it sits at the intersection of regulatory compliance, operational resilience, and customer trust.

As payment volumes increase and digital channels expand, the number of transactions flowing through financial systems has grown exponentially. At the same time, financial crime has become faster, more fragmented, and harder to detect. Criminal networks no longer rely on single large transactions. Instead, they move funds through rapid, low-value transfers, mule accounts, digital wallets, and cross-border corridors.

In this environment, a transaction monitoring system is no longer just a regulatory requirement. It is the frontline defence that determines whether a financial institution can detect suspicious activity early, respond effectively, and demonstrate control to regulators.

Yet many institutions still operate monitoring systems that were designed for a different era. These systems struggle with scale, generate excessive false positives, and provide limited insight into how risk is truly evolving.

Modern transaction monitoring systems are changing this reality. By combining advanced analytics, behavioural intelligence, and real-time processing, they allow institutions to move from reactive detection to proactive risk management.

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Why Transaction Monitoring Matters More Than Ever

Transaction monitoring has always been a core AML control, but its importance has increased sharply in recent years.

In the Philippines, several factors have intensified the need for strong monitoring capabilities. Digital banking adoption has accelerated, real-time payment rails are widely used, and cross-border remittances remain a major part of the financial ecosystem. These developments bring efficiency and inclusion, but they also create opportunities for misuse.

Criminals exploit speed and volume. They fragment transactions to stay below thresholds, move funds rapidly across accounts, and use networks of mules to obscure ownership. Traditional monitoring approaches, which focus on static rules and isolated transactions, often fail to capture these patterns.

Regulators are also raising expectations. Supervisory reviews increasingly focus on the effectiveness of transaction monitoring systems, not just their existence. Institutions are expected to demonstrate that their systems can detect emerging risks, adapt to new typologies, and produce consistent outcomes.

As a result, transaction monitoring has shifted from a compliance checkbox to a strategic capability that directly impacts regulatory confidence and institutional credibility.

What Is a Transaction Monitoring System?

A transaction monitoring system is a technology platform that continuously analyses financial transactions to identify activity that may indicate money laundering, fraud, or other financial crimes.

At its core, the system evaluates transactions against defined scenarios, rules, and models to determine whether they deviate from expected behaviour. When suspicious patterns are detected, alerts are generated for further investigation.

Modern transaction monitoring systems go far beyond simple rule-based checks. They analyse context, behaviour, relationships, and trends across large volumes of data. Rather than looking at transactions in isolation, they examine how activity unfolds over time and across accounts.

The goal is not to flag every unusual transaction, but to identify patterns that genuinely indicate risk, while minimising unnecessary alerts that consume operational resources.

The Limitations of Traditional Transaction Monitoring Systems

Many financial institutions still rely on monitoring systems that were built years ago. While these systems may technically meet regulatory requirements, they often fall short in practice.

One major limitation is over-reliance on static rules. These rules are typically based on thresholds and predefined conditions. Criminals quickly learn how to stay just below these limits, rendering the rules ineffective.

Another challenge is alert volume. Traditional systems tend to generate large numbers of alerts with limited prioritisation. Investigators spend significant time clearing false positives, leaving less capacity to focus on genuinely high-risk cases.

Legacy systems also struggle with context. They may detect that a transaction is unusual, but fail to consider customer behaviour, transaction history, or related activity across accounts. This leads to fragmented analysis and inconsistent decision-making.

Finally, many older systems operate in batch mode rather than real time. In an era of instant payments, delayed detection significantly increases exposure.

These limitations highlight the need for a new generation of transaction monitoring systems designed for today’s risk environment.

What Defines a Modern Transaction Monitoring System

Modern transaction monitoring systems are built with scale, intelligence, and adaptability in mind. They are designed to handle large transaction volumes while delivering meaningful insights rather than noise.

Behaviour-Driven Monitoring

Instead of relying solely on static thresholds, modern systems learn how customers typically behave. They analyse transaction frequency, value, counterparties, channels, and timing to establish behavioural baselines. Deviations from these baselines are treated as potential risk signals.

This approach allows institutions to detect subtle changes that may indicate emerging financial crime.

Advanced Analytics and Machine Learning

Machine learning models analyse vast datasets to identify patterns that rules alone cannot detect. These models continuously refine themselves as new data becomes available, improving accuracy over time.

Importantly, modern systems ensure that these models remain explainable, allowing institutions to understand and justify why alerts are generated.

Network and Relationship Analysis

Financial crime rarely occurs in isolation. Modern transaction monitoring systems analyse relationships between accounts, customers, and counterparties to identify networks of suspicious activity. This is particularly effective for detecting mule networks and organised schemes.

Real-Time or Near-Real-Time Processing

With instant payments now common, timing is critical. Modern systems process transactions in real time or near real time, enabling institutions to act quickly when high-risk activity is detected.

Risk-Based Alert Prioritisation

Rather than treating all alerts equally, modern systems assign risk scores based on multiple factors. This helps investigators focus on the most critical cases first and improves overall efficiency.

Transaction Monitoring in the Philippine Regulatory Context

Regulatory expectations in the Philippines place strong emphasis on effective transaction monitoring. Supervisors expect institutions to implement systems that are proportionate to their size, complexity, and risk profile.

Institutions are expected to demonstrate that their monitoring scenarios reflect current risks, that thresholds are calibrated appropriately, and that alerts are investigated consistently. Regulators also expect clear documentation of how monitoring decisions are made and how systems are governed.

As financial crime typologies evolve, institutions must show that their transaction monitoring systems are updated accordingly. Static configurations that remain unchanged for long periods are increasingly viewed as a red flag.

Modern systems help institutions meet these expectations by providing transparency, adaptability, and strong governance controls.

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How Tookitaki Approaches Transaction Monitoring

Tookitaki approaches transaction monitoring as an intelligence-driven capability rather than a rule-checking exercise.

At the core is FinCense, an end-to-end compliance platform that includes advanced transaction monitoring designed for banks and financial institutions operating at scale. FinCense analyses transaction data using a combination of rules, advanced analytics, and machine learning to deliver accurate and explainable alerts.

A key strength of FinCense is its ability to adapt. Scenarios and thresholds can be refined based on emerging patterns, ensuring that monitoring remains aligned with current risk realities rather than historical assumptions.

Tookitaki also introduces FinMate, an Agentic AI copilot that supports investigators during alert review. FinMate helps summarise transaction patterns, highlight key risk drivers, and provide contextual explanations, enabling faster and more consistent investigations.

Another differentiator is the AFC Ecosystem, a collaborative intelligence network where financial crime experts contribute real-world typologies and red flags. These insights continuously enrich FinCense, allowing institutions to benefit from collective intelligence without sharing sensitive data.

Together, these capabilities allow institutions to strengthen transaction monitoring while reducing operational burden.

A Practical Scenario: Improving Monitoring Outcomes

Consider a financial institution in the Philippines experiencing rising alert volumes due to increased digital transactions. Investigators are overwhelmed, and many alerts are closed as false positives after time-consuming reviews.

After modernising its transaction monitoring system, the institution introduces behavioural profiling and risk-based prioritisation. Alert volumes decrease significantly, but detection quality improves. Investigators receive clearer context for each alert, including transaction history and related account activity.

Management gains visibility through dashboards that show where risk is concentrated across products and customer segments. Regulatory reviews become more straightforward, as the institution can clearly explain how its monitoring system works and why specific alerts were generated.

The result is not only improved compliance, but also better use of resources and stronger confidence across the organisation.

Benefits of a Modern Transaction Monitoring System

A well-designed transaction monitoring system delivers benefits across multiple dimensions.

It improves detection accuracy by focusing on behaviour and patterns rather than static thresholds. It reduces false positives, freeing investigators to focus on meaningful risk. It enables faster response times, which is critical in real-time payment environments.

From a governance perspective, modern systems provide transparency and consistency, making it easier to demonstrate effectiveness to regulators and auditors. They also support scalability, allowing institutions to grow transaction volumes without proportionally increasing compliance costs.

Most importantly, effective transaction monitoring helps protect customer trust by reducing the likelihood of financial crime incidents that can damage reputation.

The Future of Transaction Monitoring Systems

Transaction monitoring will continue to evolve as financial systems become faster and more interconnected.

Future systems will place greater emphasis on predictive intelligence, identifying early indicators of risk before suspicious transactions occur. Integration between AML and fraud monitoring will deepen, enabling a more holistic view of financial crime.

Agentic AI will increasingly support investigators by interpreting patterns, summarising cases, and guiding decision-making. Collaborative intelligence models will allow institutions to learn from each other’s experiences while preserving data privacy.

Institutions that invest in modern transaction monitoring systems today will be better positioned to adapt to these changes and maintain resilience in a rapidly evolving landscape.

Conclusion

A transaction monitoring system is no longer just a regulatory control. It is a critical intelligence capability that shapes how effectively a financial institution can manage risk, respond to threats, and build trust.

Modern transaction monitoring systems move beyond static rules and fragmented analysis. They provide real-time insight, behavioural intelligence, and explainable outcomes that align with both operational needs and regulatory expectations.

With platforms like Tookitaki’s FinCense, supported by FinMate and enriched by the AFC Ecosystem, institutions can transform transaction monitoring from a source of operational strain into a strategic advantage.

In a world where financial crime moves quickly, the ability to see patterns clearly and act decisively is what sets resilient institutions apart.

Inside the Modern Transaction Monitoring System: How Banks Detect Risk in Real Time