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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
15 Oct 2025
6 min
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Smarter, Faster, Fairer: How Agentic AI is Powering the Next Generation of AML Investigation Software in the Philippines

In the Philippines, compliance teams are trading routine for intelligence — and Agentic AI is leading the charge.

The financial crime landscape in the Philippines has grown more complex than ever. From money mule networks and investment scams to online fraud syndicates, criminals are exploiting digital channels at unprecedented speed. Traditional compliance systems — reliant on static rules and manual reviews — are struggling to keep up.

This is where AML investigation software steps in. Powered by Agentic AI, these solutions are transforming how banks and fintechs detect, analyse, and respond to suspicious activity. In a region where regulatory scrutiny is tightening and financial innovation is accelerating, the Philippines stands at the front line of this transformation.

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The Growing Burden on Compliance Teams

Financial institutions across the Philippines face increasing pressure to balance growth with risk management. The Anti-Money Laundering Council (AMLC) and the Bangko Sentral ng Pilipinas (BSP) have rolled out new regulations that demand stronger customer due diligence, more granular monitoring, and faster suspicious transaction reporting.

At the same time, the ecosystem has become more complex:

  • Digital payment growth has created new entry points for fraud.
  • Investment scams and online lending abuse continue to rise.
  • Cross-border flows have made tracing illicit money trails harder.

These developments have turned compliance operations into a high-stakes race against time. Analysts often sift through thousands of alerts daily, many of which turn out to be false positives. What used to be an investigation problem is now an efficiency and accuracy problem — and the solution lies in intelligence, not just automation.

What AML Investigation Software Really Does

Modern AML investigation software isn’t just a case management tool. It’s a system designed to connect the dots across fragmented data, spot suspicious relationships, and guide investigators toward the right conclusions — faster.

Key Functions:

  • Alert triage: Prioritising alerts based on risk, behaviour, and contextual intelligence.
  • Entity resolution: Linking related accounts and transactions to reveal hidden networks.
  • Case investigation: Collating customer data, transaction histories, and red flags into a single view.
  • Workflow automation: Streamlining escalation, documentation, and reporting for regulatory compliance.

But the real leap forward comes with Agentic AI — a new generation of artificial intelligence that doesn’t just analyse data, but actively assists investigators in reasoning, decision-making, and collaboration.

Agentic AI: The New Brain Behind AML Investigations

Traditional AI systems rely on predefined rules and pattern matching. Agentic AI, on the other hand, is dynamic, goal-driven, and context-aware. It can reason through complex cases, adapt to new risks, and even communicate with investigators using natural language.

In AML investigations, this means:

  • Adaptive Learning: The system refines its understanding with every case it processes.
  • Natural Language Queries: Investigators can ask the system questions — “Show me all linked accounts with unusual foreign remittances” — and get instant, contextual insights.
  • Proactive Suggestions: Instead of waiting for input, the AI can surface leads or inconsistencies based on evolving risk patterns.

For Philippine banks facing talent shortages and rising compliance workloads, this is a game changer. Agentic AI augments human intelligence — it doesn’t replace it — by taking on the repetitive tasks and surfacing what truly matters.

How Philippine Banks Are Embracing Intelligent Investigations

The Philippines’ financial sector is undergoing rapid digital transformation. With over 30% of adults now transacting through e-wallets, and a growing cross-border payments ecosystem, compliance complexity is only deepening.

Forward-looking banks and fintechs have begun integrating AML investigation software with Agentic AI capabilities to strengthen investigative accuracy and reduce turnaround times.

Adoption Drivers:

  1. Regulatory alignment: AMLC’s focus on data-driven risk management is pushing institutions toward AI-enabled investigation workflows.
  2. Operational efficiency: Reducing false positives and manual intervention helps cut compliance costs.
  3. Fraud convergence: As fraud and AML risks increasingly overlap, unified intelligence is now essential.

Tookitaki has been at the forefront of this change — helping financial institutions in the Philippines and across ASEAN shift from rule-based monitoring to adaptive, intelligence-led investigation.

Key Features to Look for in AML Investigation Software

Choosing the right AML investigation software goes beyond automation. Financial institutions should look for capabilities that blend accuracy, explainability, and collaboration.

1. Agentic AI Copilot

A key differentiator is whether the software includes an AI copilot — an embedded assistant that interacts with investigators in real time. Tookitaki’s FinMate, for example, is a local LLM-powered Agentic AI copilot designed specifically for AML and fraud teams. It helps analysts interpret cases, summarise findings, and suggest next steps — all while maintaining full auditability.

2. Collaborative Intelligence

The most advanced platforms integrate collective intelligence from communities like the AFC Ecosystem, giving investigators access to thousands of real-world scenarios and typologies. This empowers teams to recognise emerging risks — from mule networks to crypto layering — before they spread.

3. Federated Learning for Data Privacy

In jurisdictions like the Philippines, where data privacy regulations are strict, federated learning enables model training without centralising sensitive data. Each institution contributes insights without sharing raw data — strengthening collective defence while maintaining compliance.

4. Explainability and Trust

Every AI-generated recommendation should be explainable. Systems like Tookitaki’s FinCense prioritise transparent AI, ensuring investigators can trace every output to its underlying data, model, and reasoning logic — critical for audit and regulator confidence.

5. Seamless Integration

Integration with transaction monitoring, name screening, and case management systems allows investigators to move from detection to disposition without losing context — an essential requirement for fast-moving compliance teams.

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The Tookitaki Approach: Building the Trust Layer for Financial Crime Prevention

Tookitaki’s end-to-end compliance platform, FinCense, is designed to be the Trust Layer for financial institutions — combining collaborative intelligence, federated learning, and Agentic AI to make financial crime prevention smarter and more reliable.

Within FinCense, the FinMate AI Copilot acts as an investigation partner.

  • It summarises alert histories and previous investigations.
  • Provides contextual recommendations on next steps.
  • Offers case narratives ready for internal and regulatory reporting.
  • Learns from investigator feedback to continuously improve accuracy.

This human–AI collaboration is transforming investigation workflows. Philippine banks that once spent hours on case analysis now complete reviews in minutes, with greater precision and consistency.

Beyond efficiency, FinCense and FinMate align directly with the AMLC’s push toward explainable, risk-based approaches — helping compliance officers maintain trust with regulators, customers, and internal stakeholders.

Case Example: A Philippine Bank’s Digital Leap

A mid-sized bank in the Philippines, struggling with high alert volumes and limited investigation bandwidth, implemented Tookitaki’s AML investigation software as part of its broader FinCense deployment.

Within three months:

  • False positives dropped by over 80%.
  • Investigation time per case reduced by half.
  • Analyst productivity improved by 60%.

What made the difference was FinMate’s Agentic AI capability. The system didn’t just flag suspicious behaviour — it contextualised each alert, grouped related cases, and generated draft narratives for investigator review. The outcome was faster resolution, better accuracy, and renewed confidence in the compliance function.

The Future of AML Investigations in the Philippines

The next phase of compliance transformation in the Philippines will be shaped by Agentic AI and collaborative ecosystems. Here’s what lies ahead:

1. Human-AI Co-investigation

Investigators will work alongside AI copilots that understand intent, interpret complex relationships, and recommend actions in natural language.

2. Continuous Learning from the Ecosystem

Through federated networks like the AFC Ecosystem, models will learn from typologies shared across borders, enabling local institutions to anticipate new threats.

3. Regulatory Collaboration

As regulators like the AMLC adopt more advanced supervisory tools, banks will need AI systems that can demonstrate traceability, explainability, and governance — all of which Agentic AI can deliver.

The result will be a compliance environment that’s not just reactive but predictive, where financial institutions detect risk before it manifests and collaborate to protect the integrity of the system.

Conclusion: Intelligence, Trust, and the Next Chapter of Compliance

The evolution of AML investigation software marks a turning point for financial institutions in the Philippines. What began as a push for automation is now a movement toward intelligence — led by Agentic AI, grounded in collaboration, and governed by trust.

As Tookitaki’s FinCense and FinMate demonstrate, the path forward isn’t about replacing human judgment but amplifying it with smarter, context-aware systems. The future of AML investigations will belong to those who can combine human insight with machine precision, building a compliance function that’s not only faster but fairer — and trusted by all.

Smarter, Faster, Fairer: How Agentic AI is Powering the Next Generation of AML Investigation Software in the Philippines
Blogs
15 Oct 2025
6 min
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The Role of AI in Transaction Monitoring for Australian Banks

As financial crime grows more complex, Australian banks are turning to AI and now Agentic AI to revolutionise how transactions are monitored and risks detected.

Introduction

Australia’s financial landscape is evolving fast. The growth of real-time payments, digital banking, and cross-border transactions has made detecting financial crime more challenging than ever. Traditional rule-based transaction monitoring systems, designed for slower and simpler payment environments, are no longer enough.

In response, Australian banks are increasingly adopting artificial intelligence (AI) to enhance the accuracy, speed, and adaptability of their AML programs. But the latest evolution, Agentic AI, is taking compliance to an entirely new level.

This blog explores how AI, and particularly Agentic AI, is transforming transaction monitoring across Australia’s banking sector, enabling faster detection, smarter investigations, and stronger regulatory alignment with AUSTRAC.

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Why Transaction Monitoring Needs a New Approach

1. The Rise of Real-Time Payments

With the New Payments Platform (NPP) and PayTo, transactions clear in seconds. Fraudsters and launderers exploit this speed to move funds through multiple mule accounts before banks can react.

2. Sophisticated Criminal Tactics

Financial crime is no longer limited to simple structuring. Criminals use synthetic identities, cross-border layering, and digital assets to evade detection.

3. High False Positives

Rule-based systems trigger thousands of unnecessary alerts, overwhelming compliance teams and increasing costs.

4. AUSTRAC’s Evolving Standards

AUSTRAC expects continuous monitoring, explainability, and proactive detection. Banks must show they can identify suspicious activity before it spreads across the financial system.

5. Customer Experience Pressures

Delays or false flags impact legitimate customers. AI enables banks to balance security and service quality.

The Limitations of Traditional Monitoring

For years, transaction monitoring relied on static rules and thresholds — for example, flagging transactions over AUD 10,000 or rapid transfers to high-risk countries. While these methods catch known risks, they fail against sophisticated or adaptive schemes.

Limitations include:

  • Static logic: Can’t detect new or subtle behaviours.
  • Manual reviews: Investigators waste time on low-risk alerts.
  • No learning loop: Systems don’t improve automatically over time.
  • Fragmented data: Disconnected systems hinder visibility across channels.

In today’s fast-moving financial environment, static systems have become reactive rather than preventive.

How AI Transforms Transaction Monitoring

AI reshapes monitoring from a reactive process into a proactive intelligence system that continuously learns from data.

1. Machine Learning for Pattern Recognition

AI models analyse historical and real-time data to detect patterns that indicate suspicious activity — such as unusual fund flows, velocity changes, or repeated interactions with high-risk entities.

2. Behavioural Analytics

AI builds detailed customer profiles and detects deviations from normal behaviour, flagging potential risks that traditional systems miss.

3. Adaptive Thresholding

Instead of fixed thresholds, AI dynamically adjusts alert sensitivity based on risk context, reducing false positives.

4. Entity Resolution

AI connects fragmented data to identify relationships between customers, accounts, and devices — crucial for uncovering complex laundering networks.

5. Natural Language Processing (NLP)

AI interprets transaction narratives, case notes, and free-text fields, identifying hidden clues like invoice mismatches or unusual descriptions.

6. Continuous Learning

Every investigation outcome feeds back into the model, improving detection accuracy over time.

Agentic AI: The Next Frontier in Compliance

Agentic AI goes beyond traditional AI by combining autonomy, reasoning, and collaboration. Instead of just executing pre-trained models, Agentic AI acts as an intelligent assistant that can:

  • Analyse transactions and contextual data.
  • Generate risk summaries in natural language.
  • Recommend actions based on regulatory frameworks.
  • Learn from investigator feedback to improve continuously.

In compliance, this means faster decisions, fewer manual errors, and higher operational efficiency.

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How Agentic AI Works in Transaction Monitoring

1. Data Ingestion and Contextual Understanding

Agentic AI continuously consumes structured (transactions, KYC) and unstructured (case notes, communications) data to form a full risk picture.

2. Dynamic Risk Scoring

It assigns real-time risk scores to each transaction, considering behavioural patterns, customer history, and contextual anomalies.

3. Intelligent Narration

When a transaction is flagged, Agentic AI can summarise the alert — describing what happened, why it matters, and what actions are recommended — in clear, regulator-friendly language.

4. Self-Learning Capabilities

Each closed case improves its reasoning. Over time, the system develops institutional knowledge, adapting to new typologies without reprogramming.

5. Investigator Collaboration

Acting as a compliance copilot, Agentic AI assists investigators in triaging alerts, finding linked accounts, and preparing Suspicious Matter Reports (SMRs).

Benefits of AI and Agentic AI for Australian Banks

  1. Significant False Positive Reduction: AI models prioritise relevant alerts, cutting investigation workload by up to 90 percent.
  2. Improved Accuracy: Continuous learning enhances detection of new typologies.
  3. Faster Investigations: Agentic AI copilots summarise and contextualise alerts in seconds.
  4. Regulatory Confidence: Explainable AI ensures transparency and auditability for AUSTRAC.
  5. Enhanced Customer Trust: Real-time, intelligent monitoring prevents fraud without disrupting legitimate transactions.
  6. Operational Efficiency: Reduced manual workload lowers compliance costs.

AUSTRAC’s View on AI in Compliance

AUSTRAC has encouraged innovation in RegTech and SupTech solutions that enhance financial integrity. Under the AML/CTF Act, AI-powered systems are acceptable if they:

  • Maintain auditability and explainability.
  • Apply risk-based controls.
  • Support timely and accurate reporting.
  • Are regularly validated and reviewed for bias and accuracy.

AUSTRAC’s collaboration with technology providers reflects a growing recognition that AI is essential to managing modern financial crime risks.

Case Example: Regional Australia Bank

Regional Australia Bank, a community-owned institution, has embraced AI-driven compliance to enhance its transaction monitoring capabilities. By leveraging intelligent analytics, the bank has reduced investigation time, improved accuracy, and strengthened its reporting processes — all while maintaining customer trust and transparency.

Its experience demonstrates that AI adoption is not limited to large institutions; even mid-sized banks can lead in compliance innovation.

Spotlight: Tookitaki’s FinCense and Agentic AI

FinCense, Tookitaki’s flagship compliance platform, integrates Agentic AI to redefine transaction monitoring for Australian banks.

  • Real-Time Monitoring: Analyses millions of transactions across NPP, PayTo, and international payments instantly.
  • Agentic AI Copilot (FinMate): Assists investigators by narrating alerts, identifying linked parties, and generating regulatory summaries.
  • Federated Intelligence: Utilises anonymised typologies contributed by the AFC Ecosystem to detect new risks collaboratively.
  • Explainable AI: Ensures every model decision is transparent, auditable, and regulator-ready.
  • End-to-End Case Management: Combines fraud, AML, and sanctions monitoring into a unified workflow.
  • AUSTRAC Alignment: Automates SMRs, TTRs, and IFTIs with full compliance assurance.

With Agentic AI at its core, FinCense transforms transaction monitoring from a static process into an intelligent, adaptive system that anticipates risk before it happens.

Implementing AI-Driven Monitoring: Best Practices

  1. Start with Clean Data: High-quality data ensures reliable model performance.
  2. Adopt Explainable Models: Regulators prioritise transparency in AI decision-making.
  3. Integrate AML and Fraud Operations: Unified systems enhance efficiency.
  4. Invest in Investigator Training: Equip teams to work alongside AI tools effectively.
  5. Validate Models Regularly: Continuous testing maintains fairness and accuracy.
  6. Collaborate through Federated Intelligence: Shared insights strengthen detection across institutions.

Future of Transaction Monitoring in Australia

  1. Predictive Compliance: Systems will forecast risks and block suspicious transactions before they occur.
  2. Hyper-Personalised Risk Scoring: AI will assess risk at the individual customer level in real time.
  3. Industry-Wide Collaboration: Federated learning will connect banks for collective intelligence.
  4. Agentic AI Investigators: Autonomous copilots will handle tier-one alerts end to end.
  5. RegTech-Regulator Integration: AUSTRAC will increasingly rely on direct system data feeds for oversight.

Conclusion

The future of transaction monitoring in Australia lies in intelligence, not volume.
AI enables banks to uncover complex, hidden risks that traditional systems miss, while Agentic AI brings a new level of automation, reasoning, and transparency to compliance operations.

Regional Australia Bank shows that innovation is achievable at any scale. With Tookitaki’s FinCense and its built-in Agentic AI, Australian banks can move beyond reactive monitoring to real-time, proactive financial crime prevention — strengthening both compliance and customer trust.

Pro tip: The smartest transaction monitoring systems don’t just detect suspicious activity; they understand it, explain it, and learn from it.

The Role of AI in Transaction Monitoring for Australian Banks
Blogs
13 Oct 2025
6 min
read

Inside the Tech Battle Against Money Laundering: What’s Powering Singapore’s Defence

Money laundering is evolving. So is the technology built to stop it.

In Singapore, a financial hub with deep global links, criminals are using more advanced techniques to disguise illicit funds. From cross-border shell firms to digital platform abuse and real-time payment layering, the tactics are getting smarter. That’s why financial institutions are turning to next-generation money laundering technology — solutions that use AI, behavioural analytics, and collaborative intelligence to detect and disrupt suspicious activity before it causes damage.

This blog explores the key technologies powering AML efforts in Singapore, the gaps that still exist, and how institutions are building faster, smarter defences against financial crime.

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What Is Money Laundering Technology?

Money laundering technology refers to systems and tools designed to detect, investigate, and report suspicious financial activities that may involve the movement of illicit funds. These technologies go beyond basic rules engines or static filters. They are intelligent, adaptive, and often integrated with broader compliance ecosystems.

A typical tech stack may include:

  • Real-time transaction monitoring platforms
  • Customer due diligence and risk scoring engines
  • AI-powered anomaly detection
  • Sanctions and PEP screening tools
  • Suspicious transaction reporting (STR) modules
  • Investigation workflows and audit trails
  • Federated learning and typology sharing systems

Why Singapore Needs Advanced Money Laundering Technology

Singapore’s position as a regional financial centre attracts legitimate business and bad actors alike. In response, the Monetary Authority of Singapore (MAS) has built one of the most stringent AML regimes in the region. But regulations alone are not enough.

Current challenges include:

  • High-speed transactions via PayNow and FAST with little room for intervention
  • Cross-border trade misinvoicing and shell firm layering
  • Recruitment of money mules through scam job ads and phishing sites
  • Laundering of fraud proceeds through remittance and fintech apps
  • Growing sophistication in synthetic identities and deepfake impersonations

To address these, institutions need tech that is not only MAS-compliant but agile, explainable, and intelligence-driven.

The Technology Stack That Drives Modern AML Programs

Here are the core components of money laundering technology as used by leading institutions in Singapore.

1. Real-Time Transaction Monitoring Systems

These systems monitor financial activity across banking channels and flag suspicious behaviour as it happens. They detect:

  • Unusual transaction volumes
  • Sudden changes in customer behaviour
  • Transactions involving high-risk jurisdictions
  • Structuring or smurfing patterns

Advanced platforms use streaming data and in-memory analytics to process large volumes instantly.

2. Behavioural Analytics Engines

Instead of relying solely on thresholds, behavioural analytics builds a baseline for each customer’s typical activity. Alerts are raised when transactions deviate from established norms.

This is crucial for:

  • Spotting insider fraud
  • Detecting ATO (account takeover) attempts
  • Identifying use of dormant or inactive accounts for money movement

3. AI and Machine Learning Models

AI transforms detection by finding patterns too complex for humans or rules to catch. It adapts over time to recognise new laundering behaviours.

Use cases include:

  • Clustering similar fraud cases to spot mule networks
  • Predicting escalation likelihood of flagged alerts
  • Prioritising alerts based on risk and urgency
  • Generating contextual narratives for STRs

4. Typology-Based Scenario Detection

A strong AML system includes real-world typologies. These are predefined scenarios that mirror how money laundering actually happens in the wild.

Examples relevant to Singapore:

  • Layering through multiple fintech wallets
  • Use of nominee directors and shell companies in trade deals
  • Fraudulent remittance transactions disguised as payroll or aid
  • Utility payment platforms used for pass-through layering

These models help institutions move from rule-based detection to scenario-based insight.

5. Investigation Platforms with Smart Disposition Tools

Once an alert is triggered, investigators need tools to:

  • View full customer profiles and transaction history
  • Access relevant typology data
  • Log decisions and attach supporting documents
  • Generate STRs quickly and consistently

Smart disposition engines recommend next steps and help analysts close cases faster.

6. Sanctions and Watchlist Screening

Technology must screen customers and transactions against global and local watchlists:

  • UN, OFAC, EU, and MAS sanctions
  • PEP lists and high-risk individuals
  • Adverse media databases

Advanced platforms support fuzzy matching, multilingual aliases, and real-time updates to reduce risk and manual effort.

7. GoAML-Compatible STR Filing Modules

In Singapore, all suspicious transaction reports must be filed through the GoAML system. The right technology will:

  • Populate STRs with investigation data
  • Include attached evidence
  • Support internal approval workflows
  • Ensure audit-ready submission logs

This reduces submission time and improves reporting quality.

8. Federated Learning and Community Intelligence

Leading platforms now allow financial institutions to share risk scenarios and typologies without exposing customer data. This collaborative approach improves detection and keeps systems updated against evolving regional risks.

Tookitaki’s AFC Ecosystem is one such example — connecting banks across Asia to share anonymised typologies, red flags, and fraud patterns.

What’s Still Missing in Most Money Laundering Tech Setups

Despite having systems in place, many organisations still struggle with:

❌ Alert Fatigue

Too many false positives clog up resources and delay action on real risks.

❌ Fragmented Systems

AML tools that don’t integrate well create data silos and limit insight.

❌ Inflexible Rules

Static thresholds can’t keep up with fast-changing laundering techniques.

❌ Manual STR Workflows

Investigators still spend hours manually compiling reports.

❌ Weak Localisation

Some systems lack support for typologies and threats specific to Southeast Asia.

These gaps increase operational costs, frustrate teams, and put institutions at risk during audits or inspections.

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How Tookitaki’s FinCense Leads the Way in Money Laundering Technology

FinCense by Tookitaki is a next-generation AML platform designed specifically for the Asia-Pacific region. It combines AI, community intelligence, and explainable automation into one modular platform.

Here’s what makes it stand out in Singapore:

1. Agentic AI Framework

FinCense uses specialised AI agents for each part of the AML lifecycle — detection, investigation, reporting, and more. Each module is lightweight, scalable, and independently optimised.

2. Scenario-Based Detection with AFC Ecosystem Integration

FinCense detects using expert-curated typologies contributed by the AFC community. These include:

  • Shell firm layering
  • QR code-enabled laundering
  • Investment scam fund flows
  • Deepfake-enabled CEO fraud

This keeps detection models locally relevant and constantly refreshed.

3. FinMate: AI Copilot for Investigations

FinMate helps analysts by:

  • Surfacing key transactions
  • Linking related alerts
  • Suggesting likely typologies
  • Auto-generating STR summaries

This dramatically reduces investigation time and improves STR quality.

4. Simulation and Threshold Tuning

Before deploying a new detection rule or scenario, FinCense lets compliance teams simulate impact, test alert volumes, and adjust sensitivity for better control.

5. MAS-Ready Compliance and Audit Logs

Every alert, investigation step, and STR submission is fully logged and traceable — helping banks stay prepared for MAS audits and risk assessments.

Case Results: What Singapore Institutions Are Achieving with FinCense

Financial institutions using FinCense report:

  • 60 to 70 percent reduction in false positives
  • 3x faster average investigation closure time
  • Stronger alignment with MAS expectations
  • Higher STR accuracy and submission rates
  • Improved team morale and reduced compliance fatigue

By combining smart detection with smarter investigation, FinCense improves every part of the AML workflow.

Checklist: Is Your AML Technology Where It Needs to Be?

Ask your team:

  • Can your system detect typologies unique to Southeast Asia?
  • How many alerts are false positives?
  • Can you trace every step of an investigation for audit?
  • How long does it take to file an STR?
  • Are your detection thresholds adaptive or fixed?
  • Is your technology continuously learning and improving?

If your answers raise concerns, it may be time to evaluate a more advanced solution.

Conclusion: Technology Is Now the Strongest Line of Defence

The fight against money laundering has reached a tipping point. Old systems and slow processes can no longer keep up with the scale and speed of financial crime.

In Singapore, where regulatory standards are high and criminal tactics are sophisticated, the need for intelligent, integrated, and locally relevant technology is greater than ever.

Tookitaki’s FinCense shows what money laundering technology should look like in 2025 — agile, explainable, scenario-driven, and backed by community intelligence.

The future of AML is not just about compliance. It’s about building trust, protecting reputation, and staying one step ahead of those who exploit the financial system.

Inside the Tech Battle Against Money Laundering: What’s Powering Singapore’s Defence