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Managing Politically Exposed Person Risks: Insights from FATF Guidance

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Jerin Mathew
10 min
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Managing the risks associated with Politically Exposed Persons (PEPs) is a critical aspect of Anti-Money Laundering (AML) compliance for financial institutions. PEPs, by virtue of their influential positions, pose unique risks for money laundering, corruption, and terrorist financing. Given the significant potential for abuse, effective PEP management is essential to safeguard the integrity of financial systems worldwide.

The Financial Action Task Force (FATF) has established comprehensive guidelines to address these risks, particularly through Recommendations 12 and 22. These recommendations provide a framework for identifying, monitoring, and managing PEPs to prevent the misuse of financial systems. This blog explores the challenges and solutions in managing PEP risks, offering insights based on FATF guidance to help AML compliance professionals navigate this complex landscape.

Understanding PEP Risks

Definition and Categories of PEPs

A Politically Exposed Person (PEP) is an individual who holds, or has held, a prominent public function. The FATF classifies PEPs into three main categories:

  • Foreign PEPs: Individuals who hold or have held significant public positions in foreign governments, such as heads of state, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations, and important political party officials.
  • Domestic PEPs: Individuals who hold or have held significant public positions within their own country, similar to the roles described for foreign PEPs.
  • International Organization PEPs: Individuals who hold or have held prominent roles in international organizations, including senior management positions such as directors, deputy directors, and members of the board.
HOW FATF CLASSIFIES PEPs

The Unique Risks PEPs Pose

PEPs are inherently risky for financial institutions due to their potential involvement in corruption, bribery, and money laundering. Their access to state resources and decision-making power increases the likelihood that they could misuse their positions for personal gain or to facilitate illicit activities. These risks are further compounded by the potential for PEPs to engage in terrorist financing, making robust PEP management a cornerstone of effective AML compliance.

Overview of FATF Recommendations 12 and 22

FATF Recommendation 12 mandates that financial institutions implement measures to identify and manage risks associated with PEPs. This includes:

  • Establishing appropriate risk management systems to determine whether a customer or beneficial owner is a PEP.
  • Obtaining senior management approval before establishing or continuing business relationships with PEPs.
  • Taking reasonable measures to establish the source of wealth and source of funds for PEPs.
  • Conducting enhanced ongoing monitoring of business relationships with PEPs.

Recommendation 22 extends these requirements to designated non-financial businesses and professions (DNFBPs), ensuring comprehensive coverage across various sectors.

By adhering to these recommendations, financial institutions can better mitigate the risks posed by PEPs, protecting their operations and contributing to the broader goal of financial system integrity.

Common Challenges in Managing PEP Risks

Identifying PEPs

Difficulty in Determining PEP Status Due to Variations in Definitions and Lists

One of the primary challenges in managing PEP risks is the variability in definitions and lists of PEPs across different jurisdictions. While the FATF provides a standardized definition, the implementation and interpretation can vary significantly. For instance, some countries might include middle-ranking officials or those in specific sectors, while others may have more restrictive criteria. This inconsistency complicates the identification process for financial institutions operating globally, as they must navigate a patchwork of definitions and maintain compliance across multiple jurisdictions.

Challenges with Identifying Family Members and Close Associates

Another layer of complexity arises from the need to identify not only the PEPs themselves but also their family members and close associates. These individuals can also be conduits for illicit activities, leveraging their relationship with the PEP to facilitate money laundering or corruption. However, determining who qualifies as a family member or close associate is not always straightforward. Cultural differences can influence the breadth of familial ties, and information on close associates may not be readily available or easily verifiable, adding to the difficulty.

Dealing with Incomplete or Outdated Information

Limitations of Commercial Databases and Government-Issued PEP Lists

Financial institutions often rely on commercial databases and government-issued PEP lists to identify PEPs. While these resources are valuable, they come with limitations. Commercial databases may not always be comprehensive or up-to-date, leading to potential gaps in information. Government-issued lists can also be problematic as they may not cover all relevant individuals or may quickly become outdated due to frequent changes in public officeholders. Additionally, these lists might not include family members and close associates, further complicating the identification process.

Issues with Maintaining Up-to-Date Client Information and Monitoring Changes in PEP Status

Keeping client information current is a continuous challenge. Clients may not proactively update their status, and changes in PEP status can occur frequently due to elections, appointments, or other political shifts. Financial institutions must implement robust systems to regularly review and update client information. This requires significant resources and effective monitoring tools to ensure timely identification of any changes in PEP status.

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Balancing Compliance with Customer Relationships

The Impact of Strict Compliance Measures on Customer Experience

Strict compliance measures, while necessary for managing PEP risks, can adversely impact customer experience. Rigorous due diligence processes and enhanced scrutiny can lead to delays, increased documentation requirements, and potential discomfort for clients. This can strain customer relationships, particularly if clients feel unduly burdened or stigmatized by the PEP designation. Financial institutions must balance the need for compliance with maintaining positive customer experiences, which is no small feat.

Potential Reputational Risks and Regulatory Penalties for Non-Compliance

Failure to manage PEP risks effectively can result in severe reputational damage and regulatory penalties. Non-compliance with AML regulations, including inadequate PEP management, can lead to hefty fines, legal actions, and loss of trust from stakeholders. Financial institutions must navigate these risks carefully, ensuring that their AML programs are robust and compliant with regulatory expectations while also managing the operational and reputational implications of their actions.

Solutions and Best Practices

Identifying PEPs

Implementing Robust Customer Due Diligence (CDD) Processes

To effectively identify PEPs, financial institutions must implement robust Customer Due Diligence (CDD) processes. This involves collecting comprehensive information at the onboarding stage, including details about the client's occupation, sources of income, and potential connections to PEPs. Enhanced due diligence should be applied to high-risk clients, requiring additional verification and scrutiny.

Utilizing Multiple Information Sources

Relying on a single source for PEP identification is inadequate. Financial institutions should utilize a combination of information sources to ensure comprehensive coverage:

  • Internet and Media Searches: Regular internet and media searches can provide up-to-date information on individuals' public roles and activities. Specialized search tools and databases focusing on AML can help streamline this process.
  • Asset Disclosure Systems: Accessing asset disclosure systems where available can provide valuable insights into a PEP's wealth and financial activities.
  • Commercial Databases: While not infallible, commercial databases are a useful tool for identifying PEPs and their associates. These should be used in conjunction with other sources to cross-verify information.
  • Government-Issued Lists: Keeping abreast of government-issued PEP lists can aid in the identification process, though these should be regularly updated and cross-referenced with other sources.

Regularly Updating and Cross-Referencing Client Information

Maintaining up-to-date client information is crucial. Financial institutions should establish protocols for regularly reviewing and updating client records, particularly for high-risk individuals. Automated monitoring systems can help track changes in PEP status, ensuring that institutions remain compliant with regulatory requirements. Regular audits and reviews of client information can identify discrepancies or outdated information that need to be addressed.

Enhancing Information Accuracy

Conducting Periodic Reviews and Updates of Client Information

Periodic reviews of client information are essential for ensuring accuracy and relevance. Financial institutions should establish a schedule for these reviews, focusing on high-risk clients and those with potential connections to PEPs. This proactive approach helps identify any changes in client status, such as new political appointments or changes in familial connections that might affect their risk profile.

Training Employees to Recognize and Report PEP-Related Red Flags

Effective PEP management requires well-trained staff who can recognize and respond to red flags associated with PEPs. Training programs should cover the identification of PEPs, understanding the associated risks, and the appropriate steps to take when a PEP is identified. Case studies and real-world examples can enhance understanding and provide practical insights into managing PEP risks.

Implementing Automated Monitoring Systems for Real-Time Updates

Leveraging technology for real-time monitoring is a best practice in PEP management. Automated systems can continuously scan for updates and changes in client information, flagging any new risks or changes in status. These systems can integrate with existing AML software, providing a seamless and efficient way to maintain up-to-date records and ensure compliance with regulatory requirements.

Balancing Compliance and Customer Relationships

Adopting a Risk-Based Approach to PEP Management

A risk-based approach to PEP management allows financial institutions to allocate resources effectively, focusing on the highest-risk individuals and transactions. This approach involves assessing the risk associated with each PEP relationship based on factors such as the individual's position, the country of origin, and the nature of the business relationship. By prioritizing high-risk clients, institutions can manage PEP risks more effectively without overburdening low-risk clients.

Communicating Clearly with Customers About Compliance Requirements

Transparent communication with clients about compliance requirements is essential. Financial institutions should explain the necessity of due diligence measures, the reasons for additional information requests, and the importance of compliance for both the institution and the client. Clear communication helps build trust and understanding, reducing the potential for frustration or resistance from clients.

Implementing Policies that Balance Regulatory Obligations with Customer Service

Policies should be designed to meet regulatory obligations while maintaining a high standard of customer service. This includes streamlining compliance processes to minimize delays, providing clear instructions and assistance to clients, and ensuring that staff are trained to handle PEP-related inquiries with professionalism and sensitivity. By balancing these elements, financial institutions can achieve compliance without compromising on customer satisfaction.

Leveraging Technology for Effective PEP Management

Overview of Advanced AML Software Solutions and Their Benefits

The rapid advancement of technology has significantly enhanced the ability of financial institutions to manage PEP risks effectively. Advanced AML software solutions offer a range of benefits, including improved accuracy, efficiency, and compliance. These solutions typically incorporate machine learning and artificial intelligence to automate and streamline the PEP screening and monitoring process.

Key Benefits of Advanced AML Software:

  • Enhanced Accuracy: By leveraging AI and machine learning, AML software can more accurately identify PEPs and related risks. These technologies can analyze vast amounts of data quickly, reducing the likelihood of human error and ensuring more precise identification of PEPs.
  • Increased Efficiency: Automation reduces the manual workload for compliance teams, allowing them to focus on higher-level analysis and decision-making. This leads to faster processing times and more efficient resource allocation.
  • Real-Time Monitoring: Advanced AML systems provide real-time monitoring capabilities, ensuring that any changes in PEP status are detected immediately. This continuous vigilance is crucial for maintaining up-to-date client information and mitigating risks promptly.
  • Comprehensive Data Integration: These systems can integrate data from multiple sources, including commercial databases, government lists, and internal records. This comprehensive approach ensures that institutions have access to the most complete and current information available.
  • Regulatory Compliance: By automating compliance processes and maintaining thorough records, AML software helps institutions meet regulatory requirements more effectively. This reduces the risk of non-compliance and associated penalties.

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How Technology Can Streamline PEP Identification, Monitoring, and Reporting

PEP Identification

Advanced AML software solutions enhance the identification of PEPs by employing sophisticated algorithms that cross-reference multiple data points. These systems can:

  • Analyze Structured and Unstructured Data: AML software can process both structured data (e.g., government lists, commercial databases) and unstructured data (e.g., news articles, social media posts) to identify potential PEPs.
  • Pattern Recognition: Machine learning algorithms can identify patterns and anomalies that may indicate a PEP, even if the individual is not explicitly listed in databases. This includes identifying indirect connections through family members and close associates.
  • Global Reach: Technology enables institutions to access global data sources, ensuring comprehensive coverage of PEPs from different jurisdictions.

PEP Monitoring

Once PEPs are identified, continuous monitoring is essential to detect any changes in their status or activities. Technology facilitates this through:

  • Automated Alerts: AML systems can generate real-time alerts for any significant changes in a PEP’s profile, such as new political appointments, changes in financial behavior, or public allegations of corruption.
  • Behavioral Analysis: Advanced analytics can monitor transaction patterns and flag unusual activities that may indicate potential money laundering or other illicit activities.
  • Risk Scoring: Systems can assign risk scores to PEPs based on various factors, allowing institutions to prioritize monitoring efforts on high-risk individuals.

PEP Reporting

Effective reporting is crucial for regulatory compliance and internal decision-making. AML software enhances reporting capabilities by:

  • Automated Report Generation: Systems can automatically generate detailed reports on PEP-related activities, ensuring consistency and accuracy. These reports can be customized to meet regulatory requirements and internal standards.
  • Data Visualization: Advanced tools provide data visualization options, making it easier for compliance teams to interpret complex data and identify trends or anomalies.
  • Audit Trails: Comprehensive audit trails ensure that all actions and decisions related to PEP management are documented, providing transparency and accountability.

Effectively Manage PEP Risks

Managing PEP risks is a complex but essential component of AML compliance. PEPs, by virtue of their positions and influence, pose significant risks related to money laundering, corruption, and terrorist financing. Understanding and addressing these risks is crucial for financial institutions to maintain the integrity of their operations and comply with regulatory requirements.

In addition, leveraging advanced AML software solutions can streamline the identification, monitoring, and reporting processes. These technologies enhance accuracy, efficiency, and compliance, providing real-time monitoring and comprehensive data integration. A case study of a global bank demonstrated the transformative impact of implementing a tech-driven PEP management system, highlighting the benefits of increased accuracy, enhanced efficiency, real-time monitoring, and regulatory compliance.

For financial institutions looking to enhance their AML compliance and PEP management, Tookitaki's Smart Screening solution offers a comprehensive and effective approach. By talking to Tookitaki's experts, institutions can learn more about how this innovative solution can help them navigate the complexities of PEP management and achieve their compliance goals.

By understanding the challenges and implementing these best practices and solutions, AML compliance professionals can better manage PEP risks, protect their institutions, and contribute to the broader goal of financial system integrity.

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Blogs
24 Nov 2025
6 min
read

Singapore’s Secret Weapon Against Dirty Money? Smarter AML Investigation Tools

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

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

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What Are AML Investigation Tools?

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

These tools can be:

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

Why They Matter in the Singapore Context

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

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

Key Capabilities of Modern AML Investigation Tools

1. Alert Contextualisation

Investigators need context around each alert:

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

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

2. Visualisation of Transaction Patterns

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

3. Narrative Generation

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

4. Investigator Workflow

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

5. Integration with STR Filing

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

Common Challenges Without Proper Tools

Many institutions still struggle with manual or legacy investigation processes:

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

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

Real-World Example: Account Takeover Fraud via Fintech Wallets

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

Upon investigation, the team found:

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

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

  • Identified shared mule accounts across multiple victims
  • Escalated the case to the regulator within 24 hours
  • Blocked future similar transactions using rule updates
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Tookitaki’s FinCense: Investigation Reinvented

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

Features That Matter:

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

Results From Tookitaki Clients:

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

Regulatory Expectations from MAS

Under MAS guidelines, financial institutions must:

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

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

AML Investigation and Emerging Threats

1. Deepfake-Fuelled Impersonation

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

2. Crypto Layering

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

3. Mule Account Clusters

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

4. Instant Payments Risk

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

How to Evaluate a Vendor

Ask these questions:

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

Looking Ahead: The Future of AML Investigations

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

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

Conclusion: Investigation is Your Last Line of Defence

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

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

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

Fraud Detection Software for Banks: Inside the Digital War Room

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

Prologue: The Alert That Shouldn’t Have Happened

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

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

Nothing about it screams fraud.

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

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

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

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

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

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

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

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

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

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

Chapter 2: What Modern Fraud Detection Software Really Does

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

Modern software must:

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

The best systems behave like digital detectives.

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

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

1. Behavioural Biometrics

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

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

2. Device Intelligence

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

3. Network Link Analysis

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

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

This is how syndicates are caught.

4. Real-Time Risk Scoring

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

5. Cross-Channel Visibility

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

6. Analyst Assistance

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

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

Fraud teams fight harder when the software fights with them.

ChatGPT Image Nov 23, 2025, 07_23_27 PM

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

Picture this scene.

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

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

This is not random.
This is an organised ring.

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

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

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

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

Chapter 5: The Weaknesses of Old Fraud Detection Systems

Some Australian banks still rely on systems that:

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

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

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

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

1. Real-Time Analysis for NPP

Detection must be instant.

2. Behavioural Intelligence

Software should learn how customers normally behave and identify anomalies.

3. Mule Detection Algorithms

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

4. Explainability

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

5. Cross-Channel Intelligence

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

6. Noise Reduction

Software must reduce false positives, not amplify them.

7. Analyst Enablement

Investigators should receive context, not clutter.

8. Scalability for Peak Fraud Events

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

9. Localisation

Australian fraud patterns differ from other regions.

10. Resilience

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

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

Chapter 7: How Tookitaki Approaches Fraud Detection

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

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

What makes it different:

1. A Behaviour-First Model

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

2. Investigation Intelligence

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

3. Multi-Channel Detection

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

4. Designed for Both Large and Community Banks

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

5. Built for Real-Time Environments

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

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

Chapter 8: The Future of Fraud Detection in Australian Banking

1. Deepfake-Resistant Identity Verification

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

2. Agentic AI Assistants for Investigators

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

3. Network-Wide Intelligence Sharing

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

4. Real-Time Customer Protection

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

5. Predictive Fraud Prevention

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

Fraud detection will become proactive, not reactive.

Conclusion

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

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

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

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

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

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

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

Introduction

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

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

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

Let’s get into them.

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

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

Australia has:

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

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

What to look for

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

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

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

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

This means:

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

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

What to look for

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

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

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

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

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

Modern AML software must:

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

What to look for

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

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

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

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

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

What to look for

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

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

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

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

AML software must show:

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

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

What to look for

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

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

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

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

This includes:

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

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

What to look for

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

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

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

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

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

What to look for

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

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

A Fresh Look at Tookitaki

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

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

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

Its platform, FinCense, helps Australian institutions strengthen:

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

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

Conclusion

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

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

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

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

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