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Beneficial Ownership: A Deep Dive into FATF's Recommendation 24

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Tookitaki
5 min
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In the complex world of global finance, the Financial Action Task Force (FATF) plays a pivotal role in maintaining security and integrity. Established in 1989 by the G7 Summit in Paris, the FATF is an inter-governmental body dedicated to setting standards and promoting effective implementation of legal, regulatory, and operational measures for combating money laundering, terrorist financing, and other related threats to the integrity of the international financial system. With 39 members comprising 37 member jurisdictions and 2 regional organisations, the FATF's influence extends far beyond its member base, impacting global financial practices and policies.

One of the key concepts at the heart of the FATF's mission is that of 'beneficial ownership'. In the simplest terms, a beneficial owner is the real person who ultimately owns, controls, or reaps the benefits from a company or a legal arrangement, such as a trust. This contrasts with legal ownership, where a company or person is registered as the owner but does not necessarily reap the benefits or exercise control.

The importance of beneficial ownership in financial transparency cannot be overstated. By identifying the real individuals behind companies and legal arrangements, authorities can prevent and detect financial crimes such as money laundering, corruption, and tax evasion. This transparency is crucial for maintaining the integrity of business transactions and the financial system as a whole.

In the following sections, we will delve deeper into the FATF's Recommendation 24, a key standard aimed at enhancing transparency and understanding of beneficial ownership. Stay tuned as we unpack the complexities of this recommendation and its implications for global financial security.

Understanding Recommendation 24

Recommendation 24, as set forth by the Financial Action Task Force (FATF), is a cornerstone in the fight against illicit financial activities. It applies to all legal persons, with the requirements described primarily with reference to companies. However, similar requirements should also be applied to other types of legal persons, taking into account their different forms and structures.

The purpose of Recommendation 24 is to ensure transparency of legal persons. This transparency is crucial in preventing and detecting financial crimes such as money laundering and terrorist financing. Measures implementing this recommendation can apply to both natural and legal persons. For legal certainty, it is important to set out clear rules on the obligations of legal persons.

Over the years, the FATF has made revisions to Recommendation 24 to enhance its effectiveness. For instance, the FATF developed a guidance in 2014, as well as a best practice paper to assist countries in their implementation of Recommendation 24, and also Recommendation 1 as it relates to understanding the ML/TF risks of legal persons and legal arrangements.

One of the key revisions made to Recommendation 24 pertains to the use of nominees. The FATF has outlined specific requirements for dealing with nominees under Recommendation 24, including professional nominee arrangements offered by corporate service providers, professional nominee director and nominee shareholder services offered by corporate service providers, and power of attorney arrangements used in concert with nominee arrangements.

These revisions reflect the FATF's commitment to continually improving and adapting its standards to meet the evolving challenges of financial crime.

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The Importance of Recommendation 24

Recommendation 24 is a crucial tool in the fight against financial crime. It provides a framework for countries to ensure transparency in the ownership and control of legal persons, which is a key feature of national systems' efforts to combat money laundering and terrorist financing. By setting out clear rules on the obligations of legal persons, Recommendation 24 helps to create a level playing field and promotes legal certainty.

The importance of Recommendation 24 becomes even more apparent when we consider real-world examples of financial misconduct resulting from a lack of transparency in beneficial ownership. For instance, opaque ownership structures can be used to hide illicit funds, evade taxes, or facilitate corruption. By requiring countries to maintain accurate and up-to-date information on beneficial ownership, Recommendation 24 helps to close these loopholes and makes it harder for criminals to abuse the financial system.

Moreover, the FATF has taken measures to ensure the effective implementation of Recommendation 24. For example, countries are expected to start making the necessary legislative/administrative changes following the adoption of revised Recommendation 24, and they will be assessed against the new standards from the next (fifth) round of mutual evaluations.

In addition, the FATF provides guidance on how to mitigate the risks of misuse of nominees under Recommendation 24. This includes arrangements mandating acting on behalf of another person. These examples highlight the practical applications of the recommendation and its role in enhancing financial transparency and integrity.

Implementing Recommendation 24

The implementation of Recommendation 24 varies across different countries, reflecting the diversity of legal systems and practices around the world. However, the core principle remains the same: ensuring that basic information and beneficial ownership information is adequate. This involves not only information provided to the company registry but also any available information referred to in paragraph 7 of the Interpretive Note to Recommendation 24.

Countries are expected to start making the necessary legislative/administrative changes following the adoption of revised Recommendation 24. They will be assessed against the new standards from the next (fifth) round of mutual evaluations. This process ensures that countries are held accountable for implementing the recommendations and that they receive feedback on their progress.

However, implementing Recommendation 24 is not without challenges. Countries may face difficulties in collecting and maintaining up-to-date information on beneficial ownership, especially in cases where ownership structures are complex or where owners are based overseas. Moreover, the requirements of Recommendation 24 apply to all legal persons, which means that countries must adapt these requirements to different types of legal persons, taking into account their different forms and structures.

To overcome these challenges, countries may need to strengthen their legal and regulatory frameworks, improve their data collection mechanisms, and enhance cooperation between different authorities. The FATF provides guidance and support to countries in this regard, helping them to implement Recommendation 24 effectively and to address any challenges they may face.

 

The Role of Legal Persons in Recommendation 24

Legal persons play a crucial role in the implementation of Recommendation 24. The requirements of this recommendation apply to all legal persons, and it's important to set out clear rules on their obligations. These obligations are not limited to companies but extend to other types of legal persons, taking into account their different forms and structures.

One of the key obligations of legal persons under Recommendation 24 is to maintain adequate and up-to-date information on beneficial ownership. This information is essential for preventing and detecting financial crimes such as money laundering and terrorist financing. Legal persons are also required to facilitate access by foreign competent authorities to this information, further enhancing international cooperation in the fight against financial crime.

Moreover, the FATF has developed guidance and best practice papers to assist countries and legal persons in their implementation of Recommendation 24. This includes understanding the money laundering and terrorist financing risks of legal persons and legal arrangements. It's important to note that this guidance is non-binding and does not override the purview of national authorities.

In conclusion, legal persons have a significant role and responsibility in ensuring the transparency of beneficial ownership, which is at the heart of Recommendation 24. By fulfilling their obligations under this recommendation, legal persons can contribute to the integrity and stability of the global financial system.

Final Thoughts

Understanding and implementing Recommendation 24 is of paramount importance in the global fight against financial crime. By promoting transparency in the ownership and control of legal persons, this recommendation helps to prevent and detect illicit activities such as money laundering and terrorist financing. It sets clear obligations for legal persons and provides a framework for countries to enhance their legal and regulatory systems.

However, the world of finance is dynamic and ever-evolving, and so are the challenges we face. Therefore, it is crucial to stay informed about the latest updates to the FATF recommendations and other developments in the field of financial security. We encourage you to delve deeper into this topic and to keep abreast of new insights and best practices. Remember, every step we take towards greater transparency and integrity in finance is a step towards a more secure and prosperous world.

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Blogs
16 Feb 2026
6 min
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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.

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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.

ChatGPT Image Feb 16, 2026, 09_23_01 AM

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.

AI vs Rule-Based Transaction Monitoring for Banks in Malaysia
Blogs
16 Feb 2026
6 min
read

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.

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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.

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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.

How AML Case Management Improves Investigator Productivity in Australia
Blogs
10 Feb 2026
6 min
read

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.

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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.

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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.

Scenario-Based Transaction Monitoring for Real-Time Payments in Australia