Importance of CDD at Singapore Digital Banks for AML Compliance
Singapore's digital banking industry has been booming in recent years, with the Monetary Authority of Singapore (MAS) granting licenses to several digital banks to operate in the country. However, with the rise of digital banking, the risk of financial crimes such as money laundering has also increased. According to a Monetary Authority of Singapore (MAS) report, customer onboarding has been identified as one of the most significant risk factors in money laundering and terrorist financing. In order to mitigate the risks associated with money laundering, financial institutions, including digital banks, must implement customer due diligence (CDD) procedures. This article will explain why CDD is important for digital banks in Singapore in the fight against money laundering, and how modern technology can enable effective customer due diligence programs.
What is Customer Due Diligence?
CDD is the process of verifying the identity of customers and assessing the risks associated with conducting business with them.
It is a key part of AML efforts and is designed to prevent financial institutions from being used for money laundering. As part of their CDD procedures, financial institutions must collect, verify and maintain customer identification information. This includes collecting personal data such as name, address, date of birth and contact details. Financial institutions must also assess the risk associated with each customer and determine the level of due diligence that should be applied.
Below is a graphic representation of the CDD process.

Digital banks in Singapore must perform CDD before entering into business relationships with customers to detect potential bad actors early in the process. By doing so, they can create barriers to prevent financial criminals from accessing accounts on their system and avoid questionable activities before they can even begin. They must collect more detailed customer data, such as name, date of birth, address and contact information. Additionally, digital banks must also verify customer identity documents, such as passport, national identity card or driver’s license.
Why is Customer Due Diligence Necessary for Digital Banks in Singapore?
Digital banks in Singapore face unique challenges when it comes to money laundering prevention. A recent survey of digital banks in Singapore showed that almost 60% of respondents had identified cases of money laundering in the past year. This demonstrates the need for digital banks to have effective customer due diligence procedures in place in order to identify and mitigate money laundering risks.
In 2020, a Singaporean digital bank was fined for failing to perform proper customer due diligence on a suspicious transaction. The bank was found to have failed to carry out appropriate customer risk assessments, and had even approved transactions without identifying the customer’s source of funds.
In addition, the Singaporean banking authority, the Monetary Authority of Singapore (MAS), recently introduced new regulations to tighten customer due diligence at digital banks. This includes the requirement for digital banks to have a know-your-customer (KYC) process in place and to perform ongoing monitoring of customers’ transactions.
What Are the Benefits of Customer Due Diligence for Digital Banks in Singapore?
Customer due diligence is an essential tool for digital banks in Singapore to protect against money laundering. By implementing effective CDD procedures and monitoring customer activities, digital banks can detect suspicious activity and take action to prevent losses. This can help protect digital banks from financial, legal and reputational damage as a result of money laundering.
At the same time, CDD can also help digital banks build trust with customers. Lengthy onboarding process can deter potential customers and may result in lost business opportunities. By ensuring that customers are who they say they are and that their activities are legitimate, digital banks can provide a safe and secure banking experience for their customers. Thus, digital banks must streamline their onboarding process with technologies that can accurately identify bad actors and ease the onboarding journey for legitimate customers.
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CDD Solutions from Tookitaki
Successful CDD processes rely on a combination of technology and expertise. When risk profiles and criminal threats change, financial institutions must be as agile and creative in their approach to CDD as they are in any other aspect of their AML strategy. As regulators are becoming more stringent globally around AML compliance, strengthening the AML systems continues to remain among the top priorities. Tookitaki’s AML solutions such as Smart Screening and Customer Risk Scoring enable improved effectiveness of CDD and ongoing diligence with fewer resources.
The Smart Screening module of the Tookitaki Anti-Money Laundering Suite (AMLS) is designed to detect potential matches against sanctions lists, PEPs, and other watchlists. It includes 50+ name-matching techniques and supports multiple attributes such as name, address, gender, date of birth, and date of incorporation. It covers 20+ languages and 10 different scripts and includes a built-in transliteration engine for effective cross-lingual matching. This module is highly configurable, allowing it to be tailored to the specific prospect, customer and counterparty screening needs of each financial institution.
Meanwhile, the Customer Risk Scoring solution is a flexible and scalable customer risk ranking program that adapts to changing customer behaviour and compliance requirements. This module creates a dynamic, 360-degree risk profile of customers, helping determine the level of CDD processes required. It not only enables financial institutions to uncover hidden risks but also opens up new business opportunities.
The AMLS also has a Transaction Monitoring module, which is designed to detect suspicious patterns of financial transactions that may indicate money laundering or other financial crimes. It utilizes powerful simulation modes for automated threshold tuning, which allows AML teams to focus on the most relevant alerts and improve their overall efficiency. The module also includes a built-in sandbox environment, which allows financial institutions to test and deploy new typologies in a matter of minutes.
Stay Ahead of the Curve with Next-Gen CDD Processes
Digital banks must be vigilant in verifying customer identity information and using the latest technology to detect suspicious activities. By adhering to the proper CDD process, digital banks in Singapore can ensure compliance with AML regulations and protect their customers from financial crime.
Tookitaki's CDD solutions have been designed to provide a comprehensive and agile approach to AML compliance that can adapt to changing risk profiles and criminal threats. With Tookitaki's Smart Screening and Customer Risk Scoring modules, financial institutions can improve the effectiveness of their CDD and ongoing diligence with fewer resources. To learn more about how Tookitaki's solutions can support your business, book a demo today.
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Top AML Scenarios in ASEAN

The Role of AML Software in Compliance

The Role of AML Software in Compliance


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Our Thought Leadership Guides
AI vs Rule-Based Transaction Monitoring for Banks in Malaysia
In Malaysia’s real-time banking environment, the difference between AI and rule-based transaction monitoring is no longer theoretical. It is operational.
The Debate Is No Longer Academic
For years, banks treated transaction monitoring as a compliance checkbox. Rule engines were configured, thresholds were set, alerts were generated, and investigations followed.
That model worked when payments were slower, fraud was simpler, and laundering patterns were predictable.
Malaysia no longer fits that environment.
Instant transfers via DuitNow, rapid onboarding, digital wallets, cross-border flows, and scam-driven mule networks have fundamentally changed the speed and structure of financial crime.
The question facing Malaysian banks today is no longer whether transaction monitoring is required.
The question is whether rule-based monitoring is still sufficient.

What Rule-Based Transaction Monitoring Really Does
Rule-based systems operate on predefined logic.
Examples include:
- Flag transactions above a certain threshold
- Trigger alerts for high-risk geographies
- Monitor rapid movement of funds within fixed time windows
- Detect unusual increases in transaction frequency
- Identify repeated structuring behaviour
These rules are manually configured and tuned over time.
They offer clarity.
They offer predictability.
They are easy to explain.
But they also rely on one assumption:
That risk patterns are known in advance.
In Malaysia’s current financial crime environment, that assumption is increasingly fragile.
Where Rule-Based Monitoring Breaks Down in Malaysia
Rule-based systems struggle in five key areas.
1. Speed
With instant payment rails, funds can move across multiple accounts in minutes. Rules often detect risk after thresholds are breached. By then, the money may already be gone.
2. Fragmented Behaviour
Mule networks split funds across many accounts. Each transaction remains below alert thresholds. The system sees low risk fragments instead of coordinated activity.
3. Static Threshold Gaming
Criminal networks understand how thresholds work. They deliberately structure transactions to avoid triggering fixed limits.
4. False Positives
Rule systems often generate high alert volumes. Investigators spend time reviewing low-risk alerts, creating operational drag.
5. Limited Network Awareness
Rules evaluate transactions in isolation. They do not naturally understand behavioural similarity across unrelated accounts.
The result is a system that produces volume, not intelligence.
What AI-Based Transaction Monitoring Changes
AI-based transaction monitoring shifts from static rules to dynamic behavioural modelling.
Instead of asking whether a transaction crosses a threshold, AI asks whether behaviour deviates from expected norms.
Instead of monitoring accounts individually, AI evaluates relationships and patterns across the network.
AI-driven monitoring introduces several critical capabilities.
Behavioural Baselines
Each customer develops a behavioural profile. Deviations trigger alerts, even if amounts remain small.
Network Detection
Machine learning models identify clusters of accounts behaving similarly, revealing mule networks early.
Adaptive Risk Scoring
Risk models update continuously as new patterns emerge.
Reduced False Positives
Contextual analysis lowers unnecessary alerts, allowing investigators to focus on high-quality cases.
Predictive Detection
AI can identify early signals of laundering before large volumes accumulate.
In a real-time banking ecosystem, these differences are material.
Why Malaysia’s Banking Environment Accelerates the Shift to AI
Malaysia’s regulatory and payment landscape increases the urgency of AI adoption.
Real-Time Infrastructure
DuitNow and instant transfers compress detection windows. Systems must respond at transaction speed.
Scam-Driven Laundering
Many laundering cases originate from fraud. AI helps bridge fraud and AML detection in a unified approach.
High Digital Adoption
Mobile-first banking increases transaction velocity and behavioural complexity.
Regional Connectivity
Cross-border risk flows require pattern recognition beyond domestic thresholds.
Regulatory Scrutiny
Bank Negara Malaysia expects effective risk-based monitoring, not rule adherence alone.
AI supports risk-based supervision more effectively than static systems.
The Operational Difference: Alert Quality vs Alert Quantity
The most visible difference between AI and rule-based systems is operational.
Rule-based engines often produce large alert volumes. Investigators triage and close a significant portion as false positives.
AI-native platforms aim to reverse this ratio.
A well-calibrated AI-driven system can:
- Reduce false positives significantly
- Prioritise high-risk cases
- Shorten alert disposition time
- Consolidate related alerts into single cases
- Provide investigation-ready narratives
Operational efficiency becomes measurable, not aspirational.
Explainability: The Common Objection to AI
One common concern among Malaysian banks is explainability.
Rules are easy to justify. AI can appear opaque.
However, modern AI-native AML platforms are built with explainability by design.
They provide:
- Clear identification of risk drivers
- Transparent feature contributions
- Behavioural deviation summaries
- Traceable model decisions
Explainability is not optional. It is mandatory for regulatory confidence.
AI is not replacing governance. It is strengthening it.

Why Hybrid Models Are Transitional, Not Final
Some banks attempt hybrid approaches by layering AI on top of rule engines.
While this can improve performance temporarily, it often results in architectural complexity.
Disconnected modules create:
- Duplicate alerts
- Conflicting risk scores
- Manual reconciliation
- Operational inefficiency
True transformation requires AI-native architecture, not rule augmentation.
Tookitaki’s FinCense: An AI-Native Transaction Monitoring Platform
Tookitaki’s FinCense was built as an AI-native platform rather than a rule-based system with machine learning add-ons.
FinCense integrates:
- Real-time transaction monitoring
- Fraud and AML convergence
- Behavioural modelling
- Network intelligence
- Agentic AI investigation support
- Federated typology intelligence
- Integrated case management
This unified architecture enables banks to move from reactive threshold monitoring to proactive network detection.
Agentic AI in Action
FinCense uses Agentic AI to:
- Correlate related alerts across accounts
- Identify network-level laundering behaviour
- Generate structured investigation summaries
- Recommend next steps
Instead of producing fragmented alerts, the system produces contextual cases.
Federated Intelligence Across ASEAN
Through the Anti-Financial Crime Ecosystem, FinCense incorporates emerging typologies observed regionally.
This enables early identification of:
- Mule network structures
- Scam-driven transaction flows
- Cross-border laundering routes
Malaysian banks benefit from shared intelligence without exposing sensitive data.
Measurable Operational Outcomes
AI-native architecture enables quantifiable improvements.
Banks can achieve:
- Significant reduction in false positives
- Faster alert disposition
- Higher precision detection
- Lower operational burden
- Stronger audit readiness
Efficiency becomes a structural outcome, not a tuning exercise.
A Practical Scenario: Rule vs AI
Consider a mule network distributing funds across multiple accounts.
Under rule-based monitoring:
- Each transfer is below threshold
- Alerts may not trigger
- Detection happens only after pattern escalation
Under AI-driven monitoring:
- Behavioural similarity across accounts is detected
- Pass-through velocity is flagged
- Network clustering links accounts
- Transactions are escalated before consolidation
The difference is not incremental. It is structural.
The Strategic Question for Malaysian Banks
The debate is no longer AI versus rules in theory.
The real question is this:
Can rule-based systems keep pace with real-time financial crime in Malaysia?
If the answer is uncertain, the monitoring architecture must evolve.
AI-native platforms do not eliminate rules entirely. They embed them within a broader intelligence framework.
Rules become guardrails.
AI becomes the engine.
The Future of Transaction Monitoring in Malaysia
Transaction monitoring will increasingly rely on:
- Real-time AI-driven detection
- Network-level intelligence
- Fraud and AML convergence
- Federated typology sharing
- Explainable machine learning
- AI-assisted investigations
Malaysia’s digital maturity makes it one of the most compelling markets for this transformation.
The shift is not optional. It is inevitable.
Conclusion
Rule-based transaction monitoring built the foundation of AML compliance. But Malaysia’s real-time financial environment demands more than static thresholds.
AI-native transaction monitoring provides behavioural intelligence, network visibility, operational efficiency, and regulatory transparency.
The difference between AI and rule-based systems is no longer philosophical. It is measurable in speed, accuracy, and resilience.
For Malaysian banks seeking to protect trust in a digital-first economy, transaction monitoring must evolve from rules to intelligence.
And intelligence must operate at the speed of money.

How AML Case Management Improves Investigator Productivity in Australia
Investigator productivity is not about working faster. It is about removing friction from every decision.
Introduction
Australian compliance teams are not short on talent. They are short on time.
Across banks and financial institutions, investigators face mounting alert volumes, increasingly complex financial crime typologies, and growing regulatory expectations. Real-time payments, cross-border flows, and digital onboarding have accelerated transaction activity. Meanwhile, investigation workflows often remain fragmented.
The result is predictable. Skilled investigators spend too much time navigating systems, reconciling alerts, duplicating documentation, and preparing reports. Productivity suffers not because investigators lack expertise, but because the operating model works against them.
This is where AML case management becomes transformational.
Done correctly, AML case management does more than store alerts. It orchestrates detection, prioritisation, investigation, and reporting into a single, structured decision framework. In Australia’s compliance environment, that orchestration is becoming essential for sustainable productivity.

The Hidden Productivity Drain in Traditional Investigation Models
Most AML systems were built in modules.
Transaction monitoring generates alerts. Screening generates alerts. Risk profiling generates alerts. Each module operates with its own logic and outputs.
Investigators then inherit this fragmentation.
Multiple alerts for the same customer
A single customer can generate alerts across different systems for related behaviour. Analysts must manually reconcile context, increasing review time.
Manual triage
First-level review often relies on human sorting of low-risk alerts. This consumes valuable capacity that could be focused on higher-risk investigations.
Duplicate documentation
Case notes, attachments, and decision rationales are frequently recorded across disconnected systems, creating audit complexity.
Reporting friction
STR workflows may require manual compilation of investigation findings into regulatory reports, increasing administrative burden.
These structural inefficiencies accumulate. Productivity is lost in small increments across thousands of alerts.
What Modern AML Case Management Should Actually Do
True AML case management is not just a ticketing system.
It should act as the central decision layer that:
- Consolidates alerts across modules
- Applies intelligent prioritisation
- Structures investigations
- Enables consistent documentation
- Automates regulatory reporting workflows
- Creates feedback loops into detection models
When implemented as an orchestration layer rather than a storage tool, case management directly improves investigator productivity.
Consolidation: From Alert Overload to Unified Context
One of the most powerful productivity levers is consolidation.
Instead of reviewing multiple alerts per customer, modern case management frameworks adopt a 1 Customer 1 Alert policy.
This means:
- Related alerts are consolidated at the customer level
- Context from transaction monitoring, screening, and risk scoring is unified
- Investigators see a holistic risk view rather than isolated signals
This consolidation can reduce alert volumes by up to ten times, depending on architecture. More importantly, it reduces cognitive load. Analysts assess risk narratives rather than fragments.
Intelligent Prioritisation: Directing Attention Where It Matters
Not all alerts carry equal risk.
Traditional workflows often treat alerts sequentially, resulting in time spent on low-risk cases before high-risk ones are addressed.
Modern AML case management integrates:
- Automated L1 triage
- Machine learning-driven prioritisation
- Risk scoring across behavioural dimensions
This ensures that high-risk cases are surfaced first.
By sequencing attention intelligently, institutions can achieve up to 70 percent improvement in operational efficiency. Investigators spend their time applying judgement where it adds value.
Structured Investigation Workflows
Productivity improves when workflows are structured and consistent.
Modern case management systems enable:
- Defined investigation stages
- Automated case creation and assignment
- Role-based access controls
- Standardised note-taking and attachment management
This structure reduces variability and improves accountability.
Investigators no longer need to interpret process steps individually. The workflow guides them through review, escalation, supervisor approval, and final disposition.
Consistency accelerates decision-making without compromising quality.
Automated STR Reporting
One of the most time-consuming aspects of AML investigation in Australia is preparing suspicious transaction reports.
Traditional models require manual collation of investigation findings, transaction details, and narrative summaries.
Integrated case management introduces:
- Pre-built and customisable reporting pipelines
- Automated extraction of case data
- Embedded edit, approval, and audit trails
This reduces reporting time significantly and improves regulatory defensibility.
Investigators focus on analysis rather than document assembly.

Feedback Loops: Learning from Every Case
Productivity is not only about speed. It is also about reducing unnecessary future work.
Modern case management platforms close the loop by:
- Feeding investigation outcomes back into detection models
- Refining prioritisation logic
- Improving scenario calibration
When false positives are identified, that intelligence informs model adjustments. When genuine risks are confirmed, behavioural markers are reinforced.
Over time, this learning cycle reduces noise and enhances signal quality.
The Australian Context: Why This Matters Now
Australian financial institutions operate in an increasingly demanding environment.
Regulatory scrutiny
Regulators expect strong governance, documented rationale, and clear audit trails. Case management must support explainability and accountability.
Real-time payments
As payment velocity increases, investigation timelines shrink. Delays in case handling can expose institutions to higher risk.
Lean compliance teams
Many Australian banks operate with compact AML teams. Efficiency gains directly impact sustainability.
Increasing complexity
Financial crime typologies continue to evolve. Investigators require tools that support behavioural context, not just rule triggers.
Case management sits at the intersection of these pressures.
Productivity Is Not About Automation Alone
There is a misconception that productivity improvements come solely from automation.
Automation helps, particularly in triage and reporting. But true productivity gains come from:
- Intelligent orchestration
- Clear workflow design
- Alert consolidation
- Risk-based prioritisation
- Continuous learning
Automation without orchestration merely accelerates fragmentation.
Orchestration creates structure.
Where Tookitaki Fits
Tookitaki approaches AML case management as the central pillar of its Trust Layer.
Within the FinCense platform:
- Alerts from transaction monitoring, screening, and risk scoring are consolidated
- 1 Customer 1 Alert policy reduces noise
- Intelligent prioritisation sequences review
- Automated L1 triage filters low-risk activity
- Structured investigation workflows guide analysts
- Automated STR pipelines streamline reporting
- Investigation outcomes refine detection models
This architecture supports measurable results, including reductions in false positives and faster alert disposition times.
The goal is not just automation. It is sustained investigator effectiveness.
Measuring Investigator Productivity the Right Way
Productivity should be evaluated across multiple dimensions:
- Alert volume reduction
- Average time to disposition
- STR preparation time
- Analyst capacity utilisation
- Quality of investigation documentation
- Escalation accuracy
When case management is designed as an orchestration layer, improvements are visible across all these metrics.
The Future of AML Investigation in Australia
As financial crime grows more complex and transaction speeds increase, investigator productivity will define institutional resilience.
Future-ready AML case management will:
- Operate as a unified control centre
- Integrate AI prioritisation with human judgement
- Maintain full audit transparency
- Continuously learn from investigation outcomes
- Scale without proportionally increasing headcount
Institutions that treat case management as a strategic capability rather than a back-office tool will outperform in both compliance quality and operational sustainability.
Conclusion
Investigator productivity in Australia is not constrained by skill. It is constrained by system design.
AML case management improves productivity by consolidating alerts, prioritising intelligently, structuring workflows, automating reporting, and creating learning feedback loops.
When implemented as part of a cohesive Trust Layer, case management transforms compliance operations from reactive alert handling to structured, intelligence-driven investigation.
In an environment where risk moves quickly and scrutiny remains high, improving investigator productivity is not optional. It is foundational.

Scenario-Based Transaction Monitoring for Real-Time Payments in Australia
When money moves instantly, detection must think in scenarios, not thresholds.
Introduction
Real-time payments have changed what “too late” means.
In traditional payment systems, transaction monitoring had time on its side. Alerts could be reviewed after settlement. Suspicious patterns could be pieced together over hours or days. Interventions, while imperfect, were still possible.
In Australia’s real-time payments environment, that margin no longer exists.
Funds move in seconds. Customers expect immediate execution. Fraudsters exploit speed, social engineering, and behavioural blind spots. Many high-risk transactions look legitimate when viewed in isolation.
This is why scenario-based transaction monitoring has become critical for real-time payments in Australia.
Rules alone cannot keep pace. What institutions need is the ability to recognise patterns of behaviour unfolding in real time, guided by scenarios grounded in how financial crime actually happens.

Why Real-Time Payments Break Traditional Monitoring Models
Most transaction monitoring systems were designed for a slower world.
They rely heavily on:
- Static thresholds
- Single-transaction checks
- Retrospective pattern analysis
Real-time payments expose the limits of this approach.
Speed removes recovery windows
Once a real-time payment is executed, funds are often irretrievable. Detection must occur before or during execution, not after.
Fraud increasingly appears authorised
Many real-time payment fraud cases involve customers who initiate transactions themselves after being manipulated. Traditional red flags tied to unauthorised access often fail.
Transactions look normal in isolation
Amounts stay within typical ranges. Destinations are new but not obviously suspicious. Timing appears reasonable.
Risk only becomes visible when transactions are viewed as part of a broader behavioural narrative.
Volume amplifies noise
Real-time rails increase transaction volumes. Rule-based systems struggle to separate meaningful risk from routine activity without overwhelming operations.
Why Rules Alone Are Not Enough
Rules are still necessary. They provide guardrails and baseline coverage.
But in real-time payments, rules suffer from structural limitations.
- They react to known patterns
- They struggle with subtle behavioural change
- They generate high false positives when tuned aggressively
- They miss emerging fraud tactics until after damage occurs
Rules answer the question:
“Did this transaction breach a predefined condition?”
They do not answer:
“What story is unfolding right now?”
That is where scenarios come in.
What Scenario-Based Transaction Monitoring Really Means
Scenario-based monitoring is often misunderstood as simply grouping rules together.
In practice, it is much more than that.
A scenario represents a real-world risk narrative, capturing how fraud or laundering actually unfolds across time, accounts, and behaviours.
Scenarios focus on:
- Sequences, not single events
- Behavioural change, not static thresholds
- Context, not isolated attributes
In real-time payments, scenarios provide the structure needed to detect risk early without flooding systems with alerts.
How Scenario-Based Monitoring Works in Real Time
Scenario-based transaction monitoring shifts the unit of analysis from transactions to behaviour.
From transactions to sequences
Instead of evaluating transactions one by one, scenarios track:
- Rapid changes in transaction frequency
- First-time payment behaviour
- Sudden shifts in counterparties
- Escalation patterns following customer interactions
Fraud often reveals itself through how behaviour evolves, not through any single transaction.
Contextual evaluation
Scenarios evaluate transactions alongside:
- Customer risk profiles
- Historical transaction behaviour
- Channel usage patterns
- Time-based indicators
Context allows systems to distinguish between legitimate urgency and suspicious escalation.
Real-time decisioning
Scenarios are designed to surface risk early enough to:
- Pause transactions
- Trigger step-up controls
- Route cases for immediate review
This is essential in environments where seconds matter.

Why Scenarios Reduce False Positives in Real-Time Payments
One of the biggest operational challenges in real-time monitoring is false positives.
Scenario-based monitoring addresses this at the design level.
Fewer isolated triggers
Scenarios do not react to single anomalies. They require patterns to emerge, reducing noise from benign one-off activity.
Risk is assessed holistically
A transaction that triggers a rule may not trigger a scenario if surrounding behaviour remains consistent and low risk.
Alerts are more meaningful
When a scenario triggers, it already reflects a narrative. Analysts receive alerts that explain why risk is emerging, not just that a rule fired.
This improves efficiency and decision quality simultaneously.
The Role of Scenarios in Detecting Modern Fraud Types
Scenario-based monitoring is particularly effective against fraud types common in real-time payments.
Social engineering and scam payments
Scenarios can detect:
- Sudden urgency following customer contact
- First-time high-risk payments
- Behavioural changes inconsistent with prior history
These signals are difficult to codify reliably using rules alone.
Mule-like behaviour
Scenario logic can identify:
- Rapid pass-through of funds
- New accounts receiving and dispersing payments quickly
- Structured activity across multiple transactions
Layered laundering patterns
Scenarios capture how funds move across accounts and time, even when individual transactions appear normal.
Why Scenarios Must Be Continuously Evolved
Fraud scenarios are not static.
New tactics emerge as criminals adapt to controls. This makes scenario governance critical.
Effective programmes:
- Continuously refine scenarios based on outcomes
- Incorporate insights from investigations
- Learn from industry-wide patterns rather than operating in isolation
This is where collaborative intelligence becomes valuable.
Scenarios as Part of a Trust Layer
Scenario-based monitoring delivers the most value when embedded into a broader Trust Layer.
In this model:
- Scenarios surface meaningful risk
- Customer risk scoring provides context
- Alert prioritisation sequences attention
- Case management enforces consistent investigation
- Outcomes feed back into scenario refinement
This closed loop ensures monitoring improves over time rather than stagnates.
Operational Challenges Institutions Still Face
Even with scenario-based approaches, challenges remain.
- Poorly defined scenarios that mimic rules
- Lack of explainability in why scenarios triggered
- Disconnected investigation workflows
- Failure to retire or update ineffective scenarios
Scenario quality matters more than scenario quantity.
Where Tookitaki Fits
Tookitaki approaches scenario-based transaction monitoring as a core capability of its Trust Layer.
Within the FinCense platform:
- Scenarios reflect real-world financial crime narratives
- Real-time transaction monitoring operates at scale
- Scenario intelligence is enriched by community insights
- Alerts are prioritised and consolidated at the customer level
- Investigations feed outcomes back into scenario learning
This enables financial institutions to manage real-time payment risk proactively rather than reactively.
Measuring Success in Scenario-Based Monitoring
Success should be measured beyond alert counts.
Key indicators include:
- Time to risk detection
- Reduction in false positives
- Analyst decision confidence
- Intervention effectiveness
- Regulatory defensibility
Strong scenarios improve outcomes across all five dimensions.
The Future of Transaction Monitoring for Real-Time Payments in Australia
As real-time payments continue to expand, transaction monitoring must evolve with them.
Future-ready monitoring will focus on:
- Behavioural intelligence over static thresholds
- Scenario-driven detection
- Faster, more proportionate intervention
- Continuous learning from outcomes
- Strong explainability
Scenarios will become the language through which risk is understood and managed in real time.
Conclusion
Real-time payments demand a new way of thinking about transaction monitoring.
Rules remain necessary, but they are no longer sufficient. Scenario-based transaction monitoring provides the structure needed to detect behavioural risk early, reduce noise, and act within shrinking decision windows.
For financial institutions in Australia, the shift to scenario-based monitoring is not optional. It is the foundation of effective, sustainable control in a real-time payments world.
When money moves instantly, monitoring must understand the story, not just the transaction.

AI vs Rule-Based Transaction Monitoring for Banks in Malaysia
In Malaysia’s real-time banking environment, the difference between AI and rule-based transaction monitoring is no longer theoretical. It is operational.
The Debate Is No Longer Academic
For years, banks treated transaction monitoring as a compliance checkbox. Rule engines were configured, thresholds were set, alerts were generated, and investigations followed.
That model worked when payments were slower, fraud was simpler, and laundering patterns were predictable.
Malaysia no longer fits that environment.
Instant transfers via DuitNow, rapid onboarding, digital wallets, cross-border flows, and scam-driven mule networks have fundamentally changed the speed and structure of financial crime.
The question facing Malaysian banks today is no longer whether transaction monitoring is required.
The question is whether rule-based monitoring is still sufficient.

What Rule-Based Transaction Monitoring Really Does
Rule-based systems operate on predefined logic.
Examples include:
- Flag transactions above a certain threshold
- Trigger alerts for high-risk geographies
- Monitor rapid movement of funds within fixed time windows
- Detect unusual increases in transaction frequency
- Identify repeated structuring behaviour
These rules are manually configured and tuned over time.
They offer clarity.
They offer predictability.
They are easy to explain.
But they also rely on one assumption:
That risk patterns are known in advance.
In Malaysia’s current financial crime environment, that assumption is increasingly fragile.
Where Rule-Based Monitoring Breaks Down in Malaysia
Rule-based systems struggle in five key areas.
1. Speed
With instant payment rails, funds can move across multiple accounts in minutes. Rules often detect risk after thresholds are breached. By then, the money may already be gone.
2. Fragmented Behaviour
Mule networks split funds across many accounts. Each transaction remains below alert thresholds. The system sees low risk fragments instead of coordinated activity.
3. Static Threshold Gaming
Criminal networks understand how thresholds work. They deliberately structure transactions to avoid triggering fixed limits.
4. False Positives
Rule systems often generate high alert volumes. Investigators spend time reviewing low-risk alerts, creating operational drag.
5. Limited Network Awareness
Rules evaluate transactions in isolation. They do not naturally understand behavioural similarity across unrelated accounts.
The result is a system that produces volume, not intelligence.
What AI-Based Transaction Monitoring Changes
AI-based transaction monitoring shifts from static rules to dynamic behavioural modelling.
Instead of asking whether a transaction crosses a threshold, AI asks whether behaviour deviates from expected norms.
Instead of monitoring accounts individually, AI evaluates relationships and patterns across the network.
AI-driven monitoring introduces several critical capabilities.
Behavioural Baselines
Each customer develops a behavioural profile. Deviations trigger alerts, even if amounts remain small.
Network Detection
Machine learning models identify clusters of accounts behaving similarly, revealing mule networks early.
Adaptive Risk Scoring
Risk models update continuously as new patterns emerge.
Reduced False Positives
Contextual analysis lowers unnecessary alerts, allowing investigators to focus on high-quality cases.
Predictive Detection
AI can identify early signals of laundering before large volumes accumulate.
In a real-time banking ecosystem, these differences are material.
Why Malaysia’s Banking Environment Accelerates the Shift to AI
Malaysia’s regulatory and payment landscape increases the urgency of AI adoption.
Real-Time Infrastructure
DuitNow and instant transfers compress detection windows. Systems must respond at transaction speed.
Scam-Driven Laundering
Many laundering cases originate from fraud. AI helps bridge fraud and AML detection in a unified approach.
High Digital Adoption
Mobile-first banking increases transaction velocity and behavioural complexity.
Regional Connectivity
Cross-border risk flows require pattern recognition beyond domestic thresholds.
Regulatory Scrutiny
Bank Negara Malaysia expects effective risk-based monitoring, not rule adherence alone.
AI supports risk-based supervision more effectively than static systems.
The Operational Difference: Alert Quality vs Alert Quantity
The most visible difference between AI and rule-based systems is operational.
Rule-based engines often produce large alert volumes. Investigators triage and close a significant portion as false positives.
AI-native platforms aim to reverse this ratio.
A well-calibrated AI-driven system can:
- Reduce false positives significantly
- Prioritise high-risk cases
- Shorten alert disposition time
- Consolidate related alerts into single cases
- Provide investigation-ready narratives
Operational efficiency becomes measurable, not aspirational.
Explainability: The Common Objection to AI
One common concern among Malaysian banks is explainability.
Rules are easy to justify. AI can appear opaque.
However, modern AI-native AML platforms are built with explainability by design.
They provide:
- Clear identification of risk drivers
- Transparent feature contributions
- Behavioural deviation summaries
- Traceable model decisions
Explainability is not optional. It is mandatory for regulatory confidence.
AI is not replacing governance. It is strengthening it.

Why Hybrid Models Are Transitional, Not Final
Some banks attempt hybrid approaches by layering AI on top of rule engines.
While this can improve performance temporarily, it often results in architectural complexity.
Disconnected modules create:
- Duplicate alerts
- Conflicting risk scores
- Manual reconciliation
- Operational inefficiency
True transformation requires AI-native architecture, not rule augmentation.
Tookitaki’s FinCense: An AI-Native Transaction Monitoring Platform
Tookitaki’s FinCense was built as an AI-native platform rather than a rule-based system with machine learning add-ons.
FinCense integrates:
- Real-time transaction monitoring
- Fraud and AML convergence
- Behavioural modelling
- Network intelligence
- Agentic AI investigation support
- Federated typology intelligence
- Integrated case management
This unified architecture enables banks to move from reactive threshold monitoring to proactive network detection.
Agentic AI in Action
FinCense uses Agentic AI to:
- Correlate related alerts across accounts
- Identify network-level laundering behaviour
- Generate structured investigation summaries
- Recommend next steps
Instead of producing fragmented alerts, the system produces contextual cases.
Federated Intelligence Across ASEAN
Through the Anti-Financial Crime Ecosystem, FinCense incorporates emerging typologies observed regionally.
This enables early identification of:
- Mule network structures
- Scam-driven transaction flows
- Cross-border laundering routes
Malaysian banks benefit from shared intelligence without exposing sensitive data.
Measurable Operational Outcomes
AI-native architecture enables quantifiable improvements.
Banks can achieve:
- Significant reduction in false positives
- Faster alert disposition
- Higher precision detection
- Lower operational burden
- Stronger audit readiness
Efficiency becomes a structural outcome, not a tuning exercise.
A Practical Scenario: Rule vs AI
Consider a mule network distributing funds across multiple accounts.
Under rule-based monitoring:
- Each transfer is below threshold
- Alerts may not trigger
- Detection happens only after pattern escalation
Under AI-driven monitoring:
- Behavioural similarity across accounts is detected
- Pass-through velocity is flagged
- Network clustering links accounts
- Transactions are escalated before consolidation
The difference is not incremental. It is structural.
The Strategic Question for Malaysian Banks
The debate is no longer AI versus rules in theory.
The real question is this:
Can rule-based systems keep pace with real-time financial crime in Malaysia?
If the answer is uncertain, the monitoring architecture must evolve.
AI-native platforms do not eliminate rules entirely. They embed them within a broader intelligence framework.
Rules become guardrails.
AI becomes the engine.
The Future of Transaction Monitoring in Malaysia
Transaction monitoring will increasingly rely on:
- Real-time AI-driven detection
- Network-level intelligence
- Fraud and AML convergence
- Federated typology sharing
- Explainable machine learning
- AI-assisted investigations
Malaysia’s digital maturity makes it one of the most compelling markets for this transformation.
The shift is not optional. It is inevitable.
Conclusion
Rule-based transaction monitoring built the foundation of AML compliance. But Malaysia’s real-time financial environment demands more than static thresholds.
AI-native transaction monitoring provides behavioural intelligence, network visibility, operational efficiency, and regulatory transparency.
The difference between AI and rule-based systems is no longer philosophical. It is measurable in speed, accuracy, and resilience.
For Malaysian banks seeking to protect trust in a digital-first economy, transaction monitoring must evolve from rules to intelligence.
And intelligence must operate at the speed of money.

How AML Case Management Improves Investigator Productivity in Australia
Investigator productivity is not about working faster. It is about removing friction from every decision.
Introduction
Australian compliance teams are not short on talent. They are short on time.
Across banks and financial institutions, investigators face mounting alert volumes, increasingly complex financial crime typologies, and growing regulatory expectations. Real-time payments, cross-border flows, and digital onboarding have accelerated transaction activity. Meanwhile, investigation workflows often remain fragmented.
The result is predictable. Skilled investigators spend too much time navigating systems, reconciling alerts, duplicating documentation, and preparing reports. Productivity suffers not because investigators lack expertise, but because the operating model works against them.
This is where AML case management becomes transformational.
Done correctly, AML case management does more than store alerts. It orchestrates detection, prioritisation, investigation, and reporting into a single, structured decision framework. In Australia’s compliance environment, that orchestration is becoming essential for sustainable productivity.

The Hidden Productivity Drain in Traditional Investigation Models
Most AML systems were built in modules.
Transaction monitoring generates alerts. Screening generates alerts. Risk profiling generates alerts. Each module operates with its own logic and outputs.
Investigators then inherit this fragmentation.
Multiple alerts for the same customer
A single customer can generate alerts across different systems for related behaviour. Analysts must manually reconcile context, increasing review time.
Manual triage
First-level review often relies on human sorting of low-risk alerts. This consumes valuable capacity that could be focused on higher-risk investigations.
Duplicate documentation
Case notes, attachments, and decision rationales are frequently recorded across disconnected systems, creating audit complexity.
Reporting friction
STR workflows may require manual compilation of investigation findings into regulatory reports, increasing administrative burden.
These structural inefficiencies accumulate. Productivity is lost in small increments across thousands of alerts.
What Modern AML Case Management Should Actually Do
True AML case management is not just a ticketing system.
It should act as the central decision layer that:
- Consolidates alerts across modules
- Applies intelligent prioritisation
- Structures investigations
- Enables consistent documentation
- Automates regulatory reporting workflows
- Creates feedback loops into detection models
When implemented as an orchestration layer rather than a storage tool, case management directly improves investigator productivity.
Consolidation: From Alert Overload to Unified Context
One of the most powerful productivity levers is consolidation.
Instead of reviewing multiple alerts per customer, modern case management frameworks adopt a 1 Customer 1 Alert policy.
This means:
- Related alerts are consolidated at the customer level
- Context from transaction monitoring, screening, and risk scoring is unified
- Investigators see a holistic risk view rather than isolated signals
This consolidation can reduce alert volumes by up to ten times, depending on architecture. More importantly, it reduces cognitive load. Analysts assess risk narratives rather than fragments.
Intelligent Prioritisation: Directing Attention Where It Matters
Not all alerts carry equal risk.
Traditional workflows often treat alerts sequentially, resulting in time spent on low-risk cases before high-risk ones are addressed.
Modern AML case management integrates:
- Automated L1 triage
- Machine learning-driven prioritisation
- Risk scoring across behavioural dimensions
This ensures that high-risk cases are surfaced first.
By sequencing attention intelligently, institutions can achieve up to 70 percent improvement in operational efficiency. Investigators spend their time applying judgement where it adds value.
Structured Investigation Workflows
Productivity improves when workflows are structured and consistent.
Modern case management systems enable:
- Defined investigation stages
- Automated case creation and assignment
- Role-based access controls
- Standardised note-taking and attachment management
This structure reduces variability and improves accountability.
Investigators no longer need to interpret process steps individually. The workflow guides them through review, escalation, supervisor approval, and final disposition.
Consistency accelerates decision-making without compromising quality.
Automated STR Reporting
One of the most time-consuming aspects of AML investigation in Australia is preparing suspicious transaction reports.
Traditional models require manual collation of investigation findings, transaction details, and narrative summaries.
Integrated case management introduces:
- Pre-built and customisable reporting pipelines
- Automated extraction of case data
- Embedded edit, approval, and audit trails
This reduces reporting time significantly and improves regulatory defensibility.
Investigators focus on analysis rather than document assembly.

Feedback Loops: Learning from Every Case
Productivity is not only about speed. It is also about reducing unnecessary future work.
Modern case management platforms close the loop by:
- Feeding investigation outcomes back into detection models
- Refining prioritisation logic
- Improving scenario calibration
When false positives are identified, that intelligence informs model adjustments. When genuine risks are confirmed, behavioural markers are reinforced.
Over time, this learning cycle reduces noise and enhances signal quality.
The Australian Context: Why This Matters Now
Australian financial institutions operate in an increasingly demanding environment.
Regulatory scrutiny
Regulators expect strong governance, documented rationale, and clear audit trails. Case management must support explainability and accountability.
Real-time payments
As payment velocity increases, investigation timelines shrink. Delays in case handling can expose institutions to higher risk.
Lean compliance teams
Many Australian banks operate with compact AML teams. Efficiency gains directly impact sustainability.
Increasing complexity
Financial crime typologies continue to evolve. Investigators require tools that support behavioural context, not just rule triggers.
Case management sits at the intersection of these pressures.
Productivity Is Not About Automation Alone
There is a misconception that productivity improvements come solely from automation.
Automation helps, particularly in triage and reporting. But true productivity gains come from:
- Intelligent orchestration
- Clear workflow design
- Alert consolidation
- Risk-based prioritisation
- Continuous learning
Automation without orchestration merely accelerates fragmentation.
Orchestration creates structure.
Where Tookitaki Fits
Tookitaki approaches AML case management as the central pillar of its Trust Layer.
Within the FinCense platform:
- Alerts from transaction monitoring, screening, and risk scoring are consolidated
- 1 Customer 1 Alert policy reduces noise
- Intelligent prioritisation sequences review
- Automated L1 triage filters low-risk activity
- Structured investigation workflows guide analysts
- Automated STR pipelines streamline reporting
- Investigation outcomes refine detection models
This architecture supports measurable results, including reductions in false positives and faster alert disposition times.
The goal is not just automation. It is sustained investigator effectiveness.
Measuring Investigator Productivity the Right Way
Productivity should be evaluated across multiple dimensions:
- Alert volume reduction
- Average time to disposition
- STR preparation time
- Analyst capacity utilisation
- Quality of investigation documentation
- Escalation accuracy
When case management is designed as an orchestration layer, improvements are visible across all these metrics.
The Future of AML Investigation in Australia
As financial crime grows more complex and transaction speeds increase, investigator productivity will define institutional resilience.
Future-ready AML case management will:
- Operate as a unified control centre
- Integrate AI prioritisation with human judgement
- Maintain full audit transparency
- Continuously learn from investigation outcomes
- Scale without proportionally increasing headcount
Institutions that treat case management as a strategic capability rather than a back-office tool will outperform in both compliance quality and operational sustainability.
Conclusion
Investigator productivity in Australia is not constrained by skill. It is constrained by system design.
AML case management improves productivity by consolidating alerts, prioritising intelligently, structuring workflows, automating reporting, and creating learning feedback loops.
When implemented as part of a cohesive Trust Layer, case management transforms compliance operations from reactive alert handling to structured, intelligence-driven investigation.
In an environment where risk moves quickly and scrutiny remains high, improving investigator productivity is not optional. It is foundational.

Scenario-Based Transaction Monitoring for Real-Time Payments in Australia
When money moves instantly, detection must think in scenarios, not thresholds.
Introduction
Real-time payments have changed what “too late” means.
In traditional payment systems, transaction monitoring had time on its side. Alerts could be reviewed after settlement. Suspicious patterns could be pieced together over hours or days. Interventions, while imperfect, were still possible.
In Australia’s real-time payments environment, that margin no longer exists.
Funds move in seconds. Customers expect immediate execution. Fraudsters exploit speed, social engineering, and behavioural blind spots. Many high-risk transactions look legitimate when viewed in isolation.
This is why scenario-based transaction monitoring has become critical for real-time payments in Australia.
Rules alone cannot keep pace. What institutions need is the ability to recognise patterns of behaviour unfolding in real time, guided by scenarios grounded in how financial crime actually happens.

Why Real-Time Payments Break Traditional Monitoring Models
Most transaction monitoring systems were designed for a slower world.
They rely heavily on:
- Static thresholds
- Single-transaction checks
- Retrospective pattern analysis
Real-time payments expose the limits of this approach.
Speed removes recovery windows
Once a real-time payment is executed, funds are often irretrievable. Detection must occur before or during execution, not after.
Fraud increasingly appears authorised
Many real-time payment fraud cases involve customers who initiate transactions themselves after being manipulated. Traditional red flags tied to unauthorised access often fail.
Transactions look normal in isolation
Amounts stay within typical ranges. Destinations are new but not obviously suspicious. Timing appears reasonable.
Risk only becomes visible when transactions are viewed as part of a broader behavioural narrative.
Volume amplifies noise
Real-time rails increase transaction volumes. Rule-based systems struggle to separate meaningful risk from routine activity without overwhelming operations.
Why Rules Alone Are Not Enough
Rules are still necessary. They provide guardrails and baseline coverage.
But in real-time payments, rules suffer from structural limitations.
- They react to known patterns
- They struggle with subtle behavioural change
- They generate high false positives when tuned aggressively
- They miss emerging fraud tactics until after damage occurs
Rules answer the question:
“Did this transaction breach a predefined condition?”
They do not answer:
“What story is unfolding right now?”
That is where scenarios come in.
What Scenario-Based Transaction Monitoring Really Means
Scenario-based monitoring is often misunderstood as simply grouping rules together.
In practice, it is much more than that.
A scenario represents a real-world risk narrative, capturing how fraud or laundering actually unfolds across time, accounts, and behaviours.
Scenarios focus on:
- Sequences, not single events
- Behavioural change, not static thresholds
- Context, not isolated attributes
In real-time payments, scenarios provide the structure needed to detect risk early without flooding systems with alerts.
How Scenario-Based Monitoring Works in Real Time
Scenario-based transaction monitoring shifts the unit of analysis from transactions to behaviour.
From transactions to sequences
Instead of evaluating transactions one by one, scenarios track:
- Rapid changes in transaction frequency
- First-time payment behaviour
- Sudden shifts in counterparties
- Escalation patterns following customer interactions
Fraud often reveals itself through how behaviour evolves, not through any single transaction.
Contextual evaluation
Scenarios evaluate transactions alongside:
- Customer risk profiles
- Historical transaction behaviour
- Channel usage patterns
- Time-based indicators
Context allows systems to distinguish between legitimate urgency and suspicious escalation.
Real-time decisioning
Scenarios are designed to surface risk early enough to:
- Pause transactions
- Trigger step-up controls
- Route cases for immediate review
This is essential in environments where seconds matter.

Why Scenarios Reduce False Positives in Real-Time Payments
One of the biggest operational challenges in real-time monitoring is false positives.
Scenario-based monitoring addresses this at the design level.
Fewer isolated triggers
Scenarios do not react to single anomalies. They require patterns to emerge, reducing noise from benign one-off activity.
Risk is assessed holistically
A transaction that triggers a rule may not trigger a scenario if surrounding behaviour remains consistent and low risk.
Alerts are more meaningful
When a scenario triggers, it already reflects a narrative. Analysts receive alerts that explain why risk is emerging, not just that a rule fired.
This improves efficiency and decision quality simultaneously.
The Role of Scenarios in Detecting Modern Fraud Types
Scenario-based monitoring is particularly effective against fraud types common in real-time payments.
Social engineering and scam payments
Scenarios can detect:
- Sudden urgency following customer contact
- First-time high-risk payments
- Behavioural changes inconsistent with prior history
These signals are difficult to codify reliably using rules alone.
Mule-like behaviour
Scenario logic can identify:
- Rapid pass-through of funds
- New accounts receiving and dispersing payments quickly
- Structured activity across multiple transactions
Layered laundering patterns
Scenarios capture how funds move across accounts and time, even when individual transactions appear normal.
Why Scenarios Must Be Continuously Evolved
Fraud scenarios are not static.
New tactics emerge as criminals adapt to controls. This makes scenario governance critical.
Effective programmes:
- Continuously refine scenarios based on outcomes
- Incorporate insights from investigations
- Learn from industry-wide patterns rather than operating in isolation
This is where collaborative intelligence becomes valuable.
Scenarios as Part of a Trust Layer
Scenario-based monitoring delivers the most value when embedded into a broader Trust Layer.
In this model:
- Scenarios surface meaningful risk
- Customer risk scoring provides context
- Alert prioritisation sequences attention
- Case management enforces consistent investigation
- Outcomes feed back into scenario refinement
This closed loop ensures monitoring improves over time rather than stagnates.
Operational Challenges Institutions Still Face
Even with scenario-based approaches, challenges remain.
- Poorly defined scenarios that mimic rules
- Lack of explainability in why scenarios triggered
- Disconnected investigation workflows
- Failure to retire or update ineffective scenarios
Scenario quality matters more than scenario quantity.
Where Tookitaki Fits
Tookitaki approaches scenario-based transaction monitoring as a core capability of its Trust Layer.
Within the FinCense platform:
- Scenarios reflect real-world financial crime narratives
- Real-time transaction monitoring operates at scale
- Scenario intelligence is enriched by community insights
- Alerts are prioritised and consolidated at the customer level
- Investigations feed outcomes back into scenario learning
This enables financial institutions to manage real-time payment risk proactively rather than reactively.
Measuring Success in Scenario-Based Monitoring
Success should be measured beyond alert counts.
Key indicators include:
- Time to risk detection
- Reduction in false positives
- Analyst decision confidence
- Intervention effectiveness
- Regulatory defensibility
Strong scenarios improve outcomes across all five dimensions.
The Future of Transaction Monitoring for Real-Time Payments in Australia
As real-time payments continue to expand, transaction monitoring must evolve with them.
Future-ready monitoring will focus on:
- Behavioural intelligence over static thresholds
- Scenario-driven detection
- Faster, more proportionate intervention
- Continuous learning from outcomes
- Strong explainability
Scenarios will become the language through which risk is understood and managed in real time.
Conclusion
Real-time payments demand a new way of thinking about transaction monitoring.
Rules remain necessary, but they are no longer sufficient. Scenario-based transaction monitoring provides the structure needed to detect behavioural risk early, reduce noise, and act within shrinking decision windows.
For financial institutions in Australia, the shift to scenario-based monitoring is not optional. It is the foundation of effective, sustainable control in a real-time payments world.
When money moves instantly, monitoring must understand the story, not just the transaction.


