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Trade Based Money Laundering Explained

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Tookitaki
9 min
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Trade Based Money Laundering (TBML) is a sophisticated method used by criminals to disguise illicit funds by manipulating international trade transactions. This article provides a comprehensive understanding of the basics, techniques, red flags, global impact, and prevention measures associated with TBML. Additionally, it highlights the role of financial institutions and the use of technology in detecting TBML, along with future trends and challenges in combating this form of money laundering.

Understanding the Basics of Trade Based Money Laundering

Trade Based Money Laundering involves exploiting the complexities of international trade to hide the origins of illicit funds and integrate them into the global financial system. Criminals use legitimate trade transactions to move money across borders disguised as legitimate businesses, making it difficult for authorities to trace the illicit funds.

One common method in TBML involves over-invoicing or under-invoicing goods, where the value of the goods in a trade transaction is manipulated to facilitate the movement of funds. For example, criminals may overstate the value of imported goods to transfer excess funds, or they may understate the value of exported goods to repatriate funds. By manipulating the prices of goods, criminals can launder money without raising suspicion.

Another technique used in TBML is the use of false documentation and multiple layers of trade intermediaries. This creates a complex network of transactions that further obscures the origins of illicit funds. Criminals may establish front companies, shell companies, or use collusive traders to create fictitious transactions and invoices.

Moreover, in the realm of Trade Based Money Laundering, criminals often exploit the time lag between the shipment of goods and the payment for those goods. This time gap provides an opportunity for illicit actors to manipulate documents and transfer funds discreetly. By delaying the payment or receipt of payment for goods, criminals can obscure the true nature of their financial activities, complicating the tracking process for law enforcement agencies.

Additionally, the use of trade finance instruments, such as letters of credit and trade loans, can be abused in TBML schemes. Criminals may misuse these financial tools to facilitate the movement of illicit funds under the guise of legitimate trade transactions. By leveraging the complexity of trade finance mechanisms, perpetrators of TBML can further obfuscate the money trail and evade detection.

Common Techniques Used in Trade Based Money Laundering

In addition to over-invoicing and under-invoicing, criminals employ various other techniques in TBML. These include:

  1. Phantom Shipments: Criminals create fake shipments that do not involve the actual movement of goods. In this scheme, invoices, bills of lading, and other shipping documents are falsified to create the appearance of a legitimate trade transaction.
  2. Multiple Invoicing: Criminals generate multiple invoices for the same transaction, making it difficult to track the movement of funds. This technique involves creating several invoices with varying values for the same goods.
  3. Black Market Currency Exchange: Criminals exploit the differences in foreign exchange rates to launder money. They manipulate the exchange of currencies in unofficial or unregulated markets, enabling them to convert illicit funds into legitimate currencies.
  4. Bulk Cash Smuggling: Criminals physically transport large sums of cash across borders, bypassing detection by authorities. This method is commonly used in conjunction with trade transactions to legitimize the illicit funds.

Another technique frequently used in Trade Based Money Laundering is Trade Mispricing. This method involves deliberately misrepresenting the price, quantity, or quality of goods on trade documents. By manipulating these details, criminals can disguise the true value of the goods being traded, allowing them to move illicit funds across borders without raising suspicion.

Shell Company Transactions are also a common tactic employed in TBML. Criminals set up shell companies with no legitimate business activities to facilitate money laundering. These companies engage in fake trade transactions, issuing false invoices and receipts to create the illusion of legitimate commerce. The complexity of the corporate structure and the use of multiple jurisdictions make it challenging for authorities to trace the illicit funds back to their source.

Red Flags of Trade Based Money Laundering

Identifying potential instances of TBML involves recognizing certain red flags. Some indicators of TBML include:

  • Unusual Trade Patterns: Frequent changes in trading partners, sudden shifts in product lines, or high-value transactions without a justified business purpose can be signs of TBML.
  • Overlapping Trade Routes: Suspicion arises when trade transactions involve countries known for money laundering activities or if trade routes deviate from usual patterns.
  • Unrelated Financial Flows: When the financial flows associated with a trade transaction do not correspond to the actual goods traded, it suggests potential TBML.
  • High-Risk Products: Certain industries, such as the precious metals and gemstones trade, have higher risks of TBML due to their high value and lack of standardized pricing.

Furthermore, it is essential for financial institutions and regulatory bodies to stay vigilant and updated on the evolving tactics used in TBML. One emerging trend is the utilization of shell companies in trade transactions to obscure the true origins and beneficiaries of funds. These shell companies often have complex ownership structures, making it challenging to trace the ultimate beneficial owners.

Another red flag to watch out for is the use of trade invoices with vague or incomplete descriptions of goods being traded. This lack of transparency can be a tactic used to disguise illicit activities within legitimate trade flows. Additionally, discrepancies between the stated value of goods on trade documents and their market prices can indicate potential TBML schemes, especially in industries where prices are volatile or difficult to determine accurately.

Global Impact of Trade Based Money Laundering on Economies

TBML poses significant risks to both developed and emerging economies. The extensive use of TBML not only facilitates money laundering but also undermines legitimate trade and distorts economic data. The infusion of illicit funds into the global financial system can damage economic stability, promote corruption, and hinder sustainable development.

Additionally, TBML creates unfair competition by enabling criminals to offer lower prices, undercutting legitimate businesses. This can lead to job losses, reduced tax revenues, and imbalances in trade balances.

Furthermore, the complex nature of TBML schemes makes them difficult to detect and investigate, allowing criminal organizations to exploit loopholes in regulatory systems. This not only weakens the integrity of financial institutions but also erodes public trust in the global financial system.

Moreover, the interconnected nature of international trade means that the repercussions of TBML extend beyond individual economies, affecting global supply chains and market dynamics. The increased use of TBML techniques poses a systemic risk to the international financial system, requiring coordinated efforts from governments, financial institutions, and regulatory bodies to combat effectively.

The Role of Financial Institutions in Preventing Trade Based Money Laundering

Financial institutions play a crucial role in identifying and preventing TBML. They are responsible for conducting enhanced due diligence on their customers, monitoring trade transactions, and reporting suspicious activities to the appropriate authorities.

To effectively combat TBML, financial institutions should establish robust Know Your Customer (KYC) procedures to ensure the legitimacy of their clients' trade activities. They should also implement transaction monitoring systems to detect unusual patterns, conduct periodic risk assessments, and provide comprehensive training to their employees.

Furthermore, financial institutions need to stay abreast of the latest trends and techniques used by money launderers to exploit trade transactions. This includes understanding the complexities of international trade finance, such as the use of shell companies, trade mispricing, and the manipulation of invoices to disguise illicit funds.

Collaboration between financial institutions, regulatory bodies, and law enforcement agencies is essential in the fight against TBML. Information sharing and coordination can help in identifying and disrupting money laundering activities effectively. Financial institutions should actively participate in public-private partnerships and industry forums to exchange best practices and strengthen their anti-money laundering efforts.

How to Prevent Trade Based Money Laundering?

Preventing TBML requires a comprehensive approach involving collaboration between governments, financial institutions, and other stakeholders. Some key measures to prevent TBML include:

  1. Enhanced Regulatory Frameworks: Governments should enact and enforce stringent legislation targeting TBML, imposing penalties for non-compliance and providing adequate resources for law enforcement agencies.
  2. International Cooperation: Countries must collaborate by sharing information and intelligence to track illicit flows and disrupt TBML networks that operate across borders.
  3. Technological Solutions: Utilizing advanced analytics, artificial intelligence, and machine learning can enhance the detection and prevention capabilities of financial institutions in identifying TBML.
  4. Public Awareness: Creating awareness campaigns and educating businesses about the risks and indicators of TBML can empower them to identify and report suspicious activities.

Moreover, it is essential for financial institutions to conduct thorough due diligence on their customers and counterparties to ensure they are not unwittingly facilitating TBML. This includes verifying the legitimacy of transactions, understanding the underlying economic substance of trade deals, and monitoring for any unusual patterns or red flags that may indicate potential money laundering activities.

Additionally, regulatory authorities can play a crucial role in combating TBML by conducting regular audits and assessments of financial institutions to evaluate their compliance with anti-money laundering regulations. By imposing strict reporting requirements and conducting on-site inspections, regulators can deter illicit activities and hold institutions accountable for any lapses in their anti-money laundering controls.

Technology and Innovation in Detecting Trade Based Money Laundering

Technological advancements play a pivotal role in enhancing the detection and prevention of TBML. Anti-money laundering (AML) software and data analysis tools can help financial institutions identify suspicious trade activities, analyze vast amounts of data, and detect patterns that would be difficult to identify manually.

Moreover, the use of blockchain technology, with its transparent and tamper-proof nature, holds potential in making trade transactions more secure and traceable, reducing the opportunities for TBML. Adopting these innovative solutions can significantly strengthen the efforts against TBML.

One of the key challenges in combating TBML is the constantly evolving nature of money laundering techniques. Criminals are adept at finding new ways to exploit vulnerabilities in the financial system, making it crucial for authorities to stay ahead of these tactics. This is where cutting-edge technologies such as artificial intelligence (AI) and machine learning come into play. By leveraging these tools, financial institutions can continuously adapt their detection methods to keep up with the changing landscape of financial crime.

Furthermore, collaboration between public and private sectors is essential in the fight against TBML. Information sharing and cooperation between financial institutions, regulatory bodies, and law enforcement agencies can lead to more effective detection and prosecution of money laundering activities. Technology serves as a catalyst for this collaboration, providing the necessary infrastructure for secure data exchange and communication.

Future Trends and Challenges in Trade Based Money Laundering

The fight against Trade Based Money Laundering (TBML) continues to evolve as criminals adapt their techniques to exploit vulnerabilities in the global trade system. Addressing the challenges associated with TBML requires constant vigilance and ongoing collaboration.

Future trends in combating TBML are likely to focus on the development of advanced technologies and data-sharing platforms that facilitate real-time information exchange among governments, financial institutions, and other stakeholders. These technologies will enable more efficient and effective detection of suspicious trade transactions, allowing authorities to take swift action to prevent money laundering.

One such technology that holds promise in the fight against TBML is artificial intelligence (AI). AI algorithms can analyze large volumes of trade data, including invoices, shipping documents, and financial records, to identify patterns and anomalies that may indicate illicit activity. By automating the analysis process, AI can significantly enhance the speed and accuracy of TBML detection, freeing up investigators to focus on more complex cases.

Another emerging technology that is expected to shape the future landscape of TBML prevention is blockchain. Blockchain is a decentralized and transparent ledger that records transactions in a secure and immutable manner. By leveraging blockchain technology, trade transactions can be recorded and verified in real-time, making it more difficult for criminals to manipulate trade documents and disguise illicit funds.

Moreover, regulatory bodies are expected to place a greater emphasis on enforcing strict compliance measures and holding financial institutions accountable for their anti-money laundering efforts. This includes conducting thorough due diligence on customers, implementing robust transaction monitoring systems, and reporting suspicious activities to the relevant authorities. By imposing stronger regulatory frameworks, governments can create a deterrent effect and ensure that financial institutions prioritize their anti-money laundering obligations.

Furthermore, international cooperation will play a crucial role in combating TBML. As money laundering knows no borders, sharing information and intelligence among countries is essential to identify and disrupt global money laundering networks. Inter-governmental organizations, such as the Financial Action Task Force (FATF), are working to enhance international cooperation and coordination in the fight against TBML.

Final Thoughts

In conclusion, TBML presents a significant challenge to the global financial system, posing threats to economic stability, fair trade, and the integrity of the financial sector. Understanding the basics, techniques, red flags, and prevention measures associated with TBML is vital in combating this complex form of money laundering. By leveraging technology, fostering international cooperation, and implementing robust regulatory frameworks, governments and financial institutions can make significant strides in preventing TBML and safeguarding the global economy.

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Blogs
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Top AML Software Vendors in Australia: What to Look For in 2025

With AUSTRAC raising the bar, choosing the right AML software vendor has never been more critical for Australian institutions.

As money laundering risks intensify and AUSTRAC tightens its enforcement grip, financial institutions across Australia are rethinking their compliance technology. But with so many AML software vendors in the market, how do you know which one truly delivers on detection, efficiency, and regulatory alignment? Choosing wisely isn’t just about avoiding penalties — it’s about building trust, cutting compliance costs, and staying one step ahead of criminals.

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Why Vendor Choice Matters More Than Ever in Australia

1. AUSTRAC’s No-Nonsense Approach

Record-breaking penalties against banks and casinos highlight the risks of weak AML controls. Regulators now expect proactive monitoring and transparent reporting.

2. Instant Payment Risks

With the New Payments Platform (NPP), funds move in seconds — and so can launderers. Vendors must support real-time transaction monitoring.

3. The Cost of Compliance

AML compliance spending in Australia is rising rapidly. Vendors must provide tools that reduce false positives and investigative workload.

4. Complex Laundering Typologies

From trade-based money laundering to digital mule networks, criminals are exploiting new channels. Vendors must offer adaptive, AI-powered solutions.

What to Look for in Top AML Software Vendors

1. Proven AUSTRAC Compliance

The vendor should align with Australian AML/CTF Act obligations, including support for:

  • Suspicious Matter Reports (SMRs)
  • Threshold Transaction Reports (TTRs)
  • Complete audit trails

2. Real-Time Transaction Monitoring

Vendors must provide millisecond-level detection for:

  • Instant payments (NPP)
  • Cross-border corridors
  • Crypto-to-fiat transfers

3. AI and Machine Learning Capabilities

The best vendors go beyond rules, offering:

  • Adaptive anomaly detection
  • False positive reduction
  • Continuous model learning

4. Flexibility and Scalability

Solutions should fit both Tier-1 banks and scaling fintechs. Cloud-ready platforms with modular features are a must.

5. Explainability and Transparency

Glass-box AI ensures regulators and internal teams understand why an alert was generated.

6. Strong Vendor Support

Top vendors provide implementation guidance, typology updates, and local compliance expertise — not just software.

Common Pitfalls When Choosing an AML Vendor

  • Focusing on cost alone: Cheaper vendors often lack the sophistication to detect modern threats.
  • Ignoring integration needs: Some platforms don’t work seamlessly with existing case management systems.
  • Overlooking updates: Vendors that don’t regularly refresh typologies leave institutions vulnerable.
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Trends Among Top AML Vendors in 2025

Federated Intelligence

Leading vendors now share anonymised typologies across institutions to detect emerging risks faster.

Agentic AI

Adaptive agents that handle specific compliance tasks, from risk scoring to case narration.

Simulation Engines

The ability to test new detection scenarios before live deployment.

Cross-Channel Visibility

Unified monitoring across core banking, remittance, wallets, cards, and crypto.

Spotlight: Tookitaki’s FinCense

Among the top AML software vendors, Tookitaki is recognised for reimagining compliance through FinCense, its end-to-end AML and fraud prevention platform.

  • Agentic AI: Detects evolving threats in real time with minimal false positives.
  • Federated Learning: Accesses insights from the AFC Ecosystem — a global compliance network.
  • FinMate AI Copilot: Helps investigators summarise cases, suggest next steps, and generate regulator-ready reports.
  • Full AUSTRAC Compliance: Covers SMRs, TTRs, and explainable audit trails.
  • Real-World Typologies: Continuously updated from actual laundering and fraud scenarios worldwide.

FinCense helps Australian banks, fintechs, and remittance providers meet AUSTRAC’s standards while operating more efficiently and transparently.

Conclusion: Vendor Choice = Competitive Advantage

In Australia, AML software is no longer just about compliance — it’s about resilience, trust, and future-readiness. Choosing from the top AML software vendors means prioritising real-time detection, AI adaptability, and regulatory transparency.

Pro tip: Don’t just buy software. Invest in a vendor that evolves with you — and with the criminals you’re fighting.

Top AML Software Vendors in Australia: What to Look For in 2025
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AML Compliance for Banks in Hong Kong: Challenges & How Tookitaki Can Help

AML compliance in Hong Kong has become a top priority as financial institutions face growing regulatory pressure and increasingly complex financial crime threats.

The Hong Kong Monetary Authority (HKMA), in alignment with FATF standards, continues to tighten anti-money laundering (AML) expectations—pushing banks to adopt stronger, more adaptive compliance frameworks. Yet, many institutions still grapple with key challenges: high volumes of false positives, outdated monitoring systems, and the rapid evolution of money laundering techniques.

This blog explores the most pressing AML compliance challenges facing banks in Hong Kong today and how Tookitaki’s AI-powered AML solutions offer a smarter path forward—reducing operational costs, boosting detection accuracy, and future-proofing compliance.

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AML Compliance for Banks in Hong Kong

AML Compliance Challenges for Banks in Hong Kong

1️⃣ Increasing Regulatory Pressure & Evolving Compliance Standards
The HKMA and FATF continue to tighten AML compliance requirements, with banks expected to enhance due diligence, adopt a risk-based approach, and report suspicious activities with greater accuracy. Failure to comply results in severe penalties and reputational damage.

2️⃣ High False Positives & Compliance Costs
Traditional rules-based AML systems generate excessive false positives, leading to inefficient case handling and higher compliance costs. Banks must shift toward AI-powered AML compliance solutions to reduce manual workload and improve detection accuracy.

3️⃣ Cross-Border Transaction Risks & Trade-Based Money Laundering (TBML)
Hong Kong’s status as a global financial hub makes it a prime target for cross-border money laundering networks. Banks must enhance real-time transaction monitoring to detect complex trade-based money laundering (TBML) schemes and prevent illicit financial flows.

4️⃣ Adapting to Digital Banking & Virtual Assets
With the rise of virtual banks, fintechs, and cryptocurrency transactions, banks need scalable AML compliance frameworks that integrate seamlessly with digital banking systems and virtual asset service providers (VASPs).

5️⃣ Emerging Financial Crime Scenarios
Money launderers continuously evolve their tactics, using shell companies, multi-layered transactions, and AI-driven fraud techniques. Banks must deploy AML solutions that can adapt in real-time to emerging threats.

How Tookitaki Helps Banks Strengthen AML Compliance

Tookitaki’s AI-powered AML compliance solutions provide Hong Kong banks with a future-ready approach to financial crime prevention.

Comprehensive AML Transaction Monitoring
✔️ Real-time monitoring of billions of transactions to detect money laundering risks.
✔️ AI-driven anomaly detection to reduce false positives by up to 90%.
✔️ Automated sandbox testing to fine-tune detection models for better regulatory alignment.

Smart Screening for Sanctions & PEP Compliance
✔️ Identify high-risk entities with real-time screening against global sanctions & PEP lists.
✔️ Reduce false alerts using 50+ advanced AI name-matching techniques across 25+ languages.

AI-Driven Customer Risk Scoring
✔️ Generate 360-degree customer risk profiles based on transactions, counterparty data, and behaviour analytics.
✔️ Detect hidden financial crime networks with graph-based risk visualization.

Smart Alert Management & Case Handling
✔️ Reduce false positives by up to 70% using self-learning AI models.
✔️ Automate Suspicious Transaction Report (STR) generation for faster compliance reporting.

AFC Ecosystem: A Collaborative AML Compliance Solution
Tookitaki’s AFC (Anti-Financial Crime) Ecosystem enables banks to:
✔️ Access 100% risk coverage with community-driven AML scenarios.
✔️ Utilize a global scenario repository, constantly updated with real-world financial crime scenarios.

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Why Banks in Hong Kong Choose Tookitaki for AML Compliance

With Tookitaki’s AI-powered AML compliance platform FinCense, banks in Hong Kong can:
✅ Meet HKMA and FATF compliance requirements effortlessly.
✅ Reduce compliance costs by 50% through automated risk detection.
✅ Enhance fraud detection with 90%+ accuracy in identifying suspicious activities.

AML Compliance for Banks in Hong Kong: Challenges & How Tookitaki Can Help
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Smarter Investigations: The Rise of AML Investigation Tools in Australia

In the battle against financial crime, the right AML investigation tools turn data overload into actionable intelligence.

Australian compliance teams face a constant challenge — growing transaction volumes, increasingly sophisticated money laundering techniques, and tighter AUSTRAC scrutiny. In this environment, AML investigation tools aren’t just nice-to-have — they’re essential for turning endless alerts into fast, confident decisions.

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Why AML Investigations Are Getting Harder in Australia

1. Explosion of Transaction Data

With the New Payments Platform (NPP) and cross-border corridors, institutions must monitor millions of transactions daily.

2. More Complex Typologies

From mule networks to shell companies, layering techniques are harder to detect with static rules alone.

3. Regulatory Expectations

AUSTRAC demands timely and accurate Suspicious Matter Reports (SMRs). Delays or incomplete investigations can lead to penalties and reputational damage.

4. Resource Constraints

Skilled AML investigators are in short supply. Teams must do more with fewer people — making efficiency critical.

What Are AML Investigation Tools?

AML investigation tools are specialised software platforms that help compliance teams analyse suspicious activity, prioritise cases, and document findings for regulators.

They typically include features such as:

  • Alert triage and prioritisation
  • Transaction visualisation
  • Entity and relationship mapping
  • Case management workflows
  • Automated reporting capabilities

Key Features of Effective AML Investigation Tools

1. Integrated Case Management

Centralise all alerts, documents, and investigator notes in one platform.

2. Entity Resolution & Network Analysis

Link accounts, devices, and counterparties to uncover hidden connections in laundering networks.

3. Transaction Visualisation

Graph-based displays make it easier to trace fund flows and identify suspicious patterns.

4. AI-Powered Insights

Machine learning models suggest likely outcomes, surface overlooked anomalies, and flag high-risk entities faster.

5. Workflow Automation

Automate repetitive steps like KYC refresh requests, sanctions re-checks, and document retrieval.

6. Regulator-Ready Reporting

Generate Suspicious Matter Reports (SMRs) and audit logs that meet AUSTRAC’s requirements.

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Why These Tools Matter in Australia’s Compliance Landscape

  • Speed: Fraud and laundering through NPP happen in seconds — investigations need to move just as fast.
  • Accuracy: AI-driven tools reduce false positives, ensuring analysts focus on real threats.
  • Compliance Assurance: Detailed audit trails prove that due diligence was carried out thoroughly.

Use Cases in Australia

Case 1: Cross-Border Layering Detection

An Australian bank flagged multiple small transfers to different ASEAN countries. The AML investigation tool mapped the network, revealing links to a known mule syndicate.

Case 2: Crypto Exchange Investigations

AML tools traced a high-value Bitcoin-to-fiat conversion back to an account flagged in a sanctions database, enabling rapid SMR submission.

Advanced Capabilities to Look For

Federated Intelligence

Access anonymised typologies and red flags from a network of institutions to spot emerging threats faster.

Embedded AI Copilot

Assist investigators in summarising cases, recommending next steps, and even drafting SMRs.

Scenario Simulation

Test detection scenarios against historical data before deploying them live.

Spotlight: Tookitaki’s FinCense and FinMate

FinCense integrates investigation workflows directly into its AML platform, while FinMate, Tookitaki’s AI investigation copilot, supercharges analyst productivity.

  • Automated Summaries: Generates natural language case narratives for internal and regulatory reporting.
  • Risk Prioritisation: Highlights the highest-risk cases first.
  • Real-Time Intelligence: Pulls in global typology updates from the AFC Ecosystem.
  • Full Transparency: Glass-box AI explains every decision, satisfying AUSTRAC’s audit requirements.

With FinCense and FinMate, Australian institutions can cut investigation times by up to 50% — without compromising quality.

Conclusion: From Data to Decisions — Faster

The volume and complexity of alerts in modern AML programmes make manual investigation unsustainable. The right AML investigation tools transform scattered data into actionable insights, helping compliance teams stay ahead of both criminals and regulators.

Pro tip: Choose tools that not only investigate faster, but also learn from every case — making your compliance programme smarter over time.

Smarter Investigations: The Rise of AML Investigation Tools in Australia