Operational Resilience in AML Systems: Preparing for APRA CPS 230
As APRA’s CPS 230 standard takes effect, Australian banks must prove that their AML and fraud systems can withstand disruption, maintain compliance, and protect customer trust in real time.
Introduction
The financial world is becoming faster, riskier, and more connected than ever. From instant payments to AI-driven monitoring, compliance systems are now the central nervous system of modern banking.
But what happens when that system fails?
Australia’s banking regulator, the Australian Prudential Regulation Authority (APRA), has made its position clear: operational resilience is no longer optional. With CPS 230 coming into force, every financial institution must ensure that its critical operations — especially AML and financial crime prevention — can continue through any disruption.

Understanding APRA CPS 230
CPS 230: Operational Risk Management is APRA’s new prudential standard aimed at strengthening how financial institutions identify, manage, and recover from operational disruptions.
For compliance teams, it sets out explicit requirements to:
- Identify critical operations and supporting systems.
- Establish tolerance levels for disruption.
- Build robust business-continuity and recovery capabilities.
- Ensure accountability across management and board levels.
AML and financial crime prevention fall squarely within these “critical operations”. A monitoring outage or data-feed failure can expose banks to severe regulatory and reputational consequences.
Why Operational Resilience Matters in AML
1. Compliance Interruptions Create Risk
Even short outages in transaction monitoring can lead to missed suspicious-activity alerts and late reporting to AUSTRAC, breaching the AML/CTF Act.
2. Fraud Moves in Real Time
In the age of NPP and PayTo, criminals exploit milliseconds. Resilient systems must maintain uptime and speed, even under stress.
3. Regulatory Accountability
CPS 230 shifts responsibility to the board. Senior leaders must show not only that they have controls, but that those controls work when tested.
4. Customer Trust
Failures in compliance systems directly erode trust. Resilient infrastructure reassures customers their transactions are protected 24 hours a day.
Core Elements of Operational Resilience in AML Systems
1. System Availability
High-availability architectures, automated fail-over mechanisms, and cloud-native deployment keep monitoring engines running without interruption.
2. Data Integrity
Resilience depends on the ability to restore accurate data. Immutable logs and near-real-time replication protect audit trails.
3. Model Continuity
AI and detection models must remain functional after upgrades or incidents. Version control and rollback mechanisms are essential.
4. Governance and Accountability
Clear ownership of each AML process — from detection to reporting — ensures timely escalation and recovery.
5. Vendor Resilience
Third-party RegTech partners form part of the operational chain. CPS 230 requires that their reliability and recovery capabilities meet bank standards.
Lessons from AUSTRAC Enforcement Actions
Several AUSTRAC actions in recent years revealed systemic weaknesses in transaction-monitoring continuity. Delayed Suspicious Matter Reports and data-quality lapses cost major banks hundreds of millions in penalties.
These cases highlight that operational resilience is not merely a technology issue — it is a compliance obligation.
How AI Enhances Resilience
1. Predictive Monitoring
AI can detect early warning signs of model drift, latency, or data gaps before they cause outages.
2. Self-Healing Infrastructure
Modern systems can automatically reroute workloads or restart failing processes to maintain uptime.
3. Continuous Learning
Machine-learning models update incrementally, maintaining performance even as typologies evolve.
4. Explainable Recovery
Governed AI ensures that recovery actions remain auditable and regulator-friendly.
APRA CPS 230 and Third-Party Risk
The new framework expands scrutiny over outsourcing. Banks must assess whether their vendors:
- Have robust continuity and incident-response plans.
- Conduct regular stress tests.
- Provide transparent recovery metrics.
- Support data portability in case of termination.
In the AML domain, that means RegTech providers must demonstrate governed AI, fault-tolerant infrastructure, and full auditability.
Case Example: Regional Australia Bank
Regional Australia Bank, a community-owned institution, demonstrates how resilience can coexist with agility.
By modernising its compliance architecture and adopting intelligent automation, the bank has improved system uptime, reduced manual dependencies, and strengthened reporting accuracy — ensuring continuous alignment with both APRA and AUSTRAC expectations.
Spotlight: Tookitaki FinCense — Resilience by Design
Tookitaki’s FinCense platform was engineered around resilience principles that directly support CPS 230 compliance:
- Cloud-Native Deployment: Scales horizontally and offers automatic fail-over to maintain uptime.
- Distributed Processing: Prevents single points of failure in transaction monitoring.
- Modular Architecture: AML, fraud, and sanctions modules can operate independently during partial outages.
- AI Governance Layer: Detects model drift and performance degradation in real time.
- Audit and Replay Capability: Every decision is logged for forensic reconstruction.
- Agentic AI Copilot (FinMate): Supports investigators during high-volume spikes, sustaining investigation throughput.
- Federated Learning: Enables intelligence sharing without compromising data privacy, strengthening system robustness collectively.
Together, these features create a self-learning, self-healing compliance ecosystem — a hallmark of operational resilience.
Key Metrics for Measuring AML Resilience
- System Uptime: Target at least 99.99 percent availability.
- Alert Processing Latency: Maintain consistent turnaround even under peak loads.
- Recovery Time Objective (RTO): Maximum acceptable downtime after an incident.
- Data Recovery Point (RPO): Maximum tolerable data loss measured in minutes.
- Model Drift Rate: Percentage deviation from baseline accuracy.
- False-Positive Ratio: Stability over time indicates operational consistency.
Tracking these metrics helps banks demonstrate CPS 230 alignment with quantifiable evidence.

The Link Between CPS 230 and Sustainable Compliance
Operational resilience and sustainable compliance share the same DNA — efficiency, governance, and trust.
Sustainable systems conserve resources through automation. Resilient systems ensure those resources keep working under pressure. Together they create the conditions for reliable, ethical, and future-ready compliance.
Challenges in Achieving AML Resilience
- Legacy Systems: Outdated architectures limit redundancy.
- Data Silos: Fragmented sources hinder recovery.
- Manual Processes: Paper-based procedures collapse during disruption.
- Vendor Dependency: Over-reliance on single suppliers creates risk.
- Limited Testing: Institutions rarely simulate real-world failure scenarios.
Overcoming these barriers requires investment, collaboration, and cultural change.
A Roadmap for Compliance Leaders
- Map Critical Processes: Identify AML workflows essential for business continuity.
- Stress-Test Systems: Conduct controlled outage simulations and measure recovery.
- Standardise Documentation: Maintain unified recovery playbooks.
- Integrate AI Monitoring: Automate system-health alerts and model checks.
- Enhance Third-Party Due Diligence: Request resilience certifications from vendors.
- Engage the Board: Elevate resilience metrics to board-level dashboards.
- Collaborate with Regulators: Align testing and reporting expectations proactively.
Future Trends in AML Resilience
- Resilience as a Service: Cloud providers will offer dedicated resilience layers for compliance workloads.
- AI-Driven Incident Prediction: Systems will forecast disruptions based on anomaly patterns.
- Regulatory Resilience Audits: APRA may introduce periodic independent validations.
- Cross-Industry Coordination: Banks will share anonymised outage data to improve sector resilience.
- Unified Risk Dashboards: AI copilots will surface resilience metrics in real time.
Conclusion
Operational resilience is now a defining benchmark of compliance maturity. As APRA’s CPS 230 takes hold, banks must move beyond static risk frameworks to dynamic, adaptive systems that ensure uninterrupted AML performance.
Regional Australia Bank proves that even community-owned institutions can achieve enterprise-grade resilience through smart automation and sound governance.
With Tookitaki’s FinCense and FinMate, Australian banks can build compliance infrastructures that not only meet CPS 230 requirements but also deliver enduring trust.
Pro tip: True resilience is not the absence of disruption — it is the ability to detect, adapt, and recover without losing integrity.
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