Compliance Hub

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

Site Logo
Tookitaki
5 min
read

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.

{{cta-ebook}}

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.

By submitting the form, you agree that your personal data will be processed to provide the requested content (and for the purposes you agreed to above) in accordance with the Privacy Notice

success icon

We’ve received your details and our team will be in touch shortly.

In the meantime, explore how Tookitaki is transforming financial crime prevention.
Learn More About Us
Oops! Something went wrong while submitting the form.

Ready to Streamline Your Anti-Financial Crime Compliance?

Our Thought Leadership Guides

Blogs
06 Feb 2026
6 min
read

Machine Learning in Transaction Fraud Detection for Banks in Australia

In modern banking, fraud is no longer hidden in anomalies. It is hidden in behaviour that looks normal until it is too late.

Introduction

Transaction fraud has changed shape.

For years, banks relied on rules to identify suspicious activity. Threshold breaches. Velocity checks. Blacklisted destinations. These controls worked when fraud followed predictable patterns and payments moved slowly.

In Australia today, fraud looks very different. Real-time payments settle instantly. Scams manipulate customers into authorising transactions themselves. Fraudsters test limits in small increments before escalating. Many transactions that later prove fraudulent look perfectly legitimate in isolation.

This is why machine learning in transaction fraud detection has become essential for banks in Australia.

Not as a replacement for rules, and not as a black box, but as a way to understand behaviour at scale and act within shrinking decision windows.

This blog examines how machine learning is used in transaction fraud detection, where it delivers real value, where it must be applied carefully, and what Australian banks should realistically expect from ML-driven fraud systems.

Talk to an Expert

Why Traditional Fraud Detection Struggles in Australia

Australian banks operate in one of the fastest and most customer-centric payment environments in the world.

Several structural shifts have fundamentally changed fraud risk.

Speed of payments

Real-time payment rails leave little or no recovery window. Detection must occur before or during the transaction, not after settlement.

Authorised fraud

Many modern fraud cases involve customers who willingly initiate transactions after being manipulated. Rules designed to catch unauthorised access often fail in these scenarios.

Behavioural camouflage

Fraudsters increasingly mimic normal customer behaviour. Transactions remain within typical amounts, timings, and channels until the final moment.

High transaction volumes

Volume creates noise. Static rules struggle to separate meaningful signals from routine activity at scale.

Together, these conditions expose the limits of purely rule-based fraud detection.

What Machine Learning Changes in Transaction Fraud Detection

Machine learning does not simply automate existing checks. It changes how risk is evaluated.

Instead of asking whether a transaction breaks a predefined rule, machine learning asks whether behaviour is shifting in a way that increases risk.

From individual transactions to behavioural patterns

Machine learning models analyse patterns across:

  • Transaction sequences
  • Frequency and timing
  • Counterparties and destinations
  • Channel usage
  • Historical customer behaviour

Fraud often emerges through gradual behavioural change rather than a single obvious anomaly.

Context-aware risk assessment

Machine learning evaluates transactions in context.

A transaction that appears harmless for one customer may be highly suspicious for another. ML models learn these differences and dynamically adjust risk scoring.

This context sensitivity is critical for reducing false positives without suppressing genuine threats.

Continuous learning

Fraud tactics evolve quickly. Static rules require constant manual updates.

Machine learning models improve by learning from outcomes, allowing fraud controls to adapt faster and with less manual intervention.

Where Machine Learning Adds the Most Value

Machine learning delivers the greatest impact when applied to the right stages of fraud detection.

Real-time transaction monitoring

ML models identify subtle behavioural signals that appear just before fraudulent activity occurs.

This is particularly valuable in real-time payment environments, where decisions must be made in seconds.

Risk-based alert prioritisation

Machine learning helps rank alerts by risk rather than volume.

This ensures investigative effort is directed toward cases that matter most, improving both efficiency and effectiveness.

False positive reduction

By learning which patterns consistently lead to legitimate outcomes, ML models can deprioritise noise without lowering detection sensitivity.

This reduces operational fatigue while preserving risk coverage.

Scam-related behavioural signals

Machine learning can detect behavioural indicators linked to scams, such as unusual urgency, first-time payment behaviour, or sudden changes in transaction destinations.

These signals are difficult to encode reliably using rules alone.

What Machine Learning Does Not Replace

Despite its strengths, machine learning is not a silver bullet.

Human judgement

Fraud decisions often require interpretation, contextual awareness, and customer interaction. Human judgement remains essential.

Explainability

Banks must be able to explain why transactions were flagged, delayed, or blocked.

Machine learning models used in fraud detection must produce interpretable outputs that support customer communication and regulatory review.

Governance and oversight

Models require monitoring, validation, and accountability. Machine learning increases the importance of governance rather than reducing it.

Australia-Specific Considerations

Machine learning in transaction fraud detection must align with Australia’s regulatory and operational realities.

Customer trust

Blocking legitimate payments damages trust. ML-driven decisions must be proportionate, explainable, and defensible at the point of interaction.

Regulatory expectations

Australian regulators expect risk-based controls supported by clear rationale, not opaque automation. Fraud systems must demonstrate consistency, traceability, and accountability.

Lean operational teams

Many Australian banks operate with compact fraud teams. Machine learning must reduce investigative burden and alert noise rather than introduce additional complexity.

For Australian banks more broadly, the value of machine learning lies in improving decision quality without compromising transparency or customer confidence.

Common Pitfalls in ML-Driven Fraud Detection

Banks often encounter predictable challenges when adopting machine learning.

Overly complex models

Highly opaque models can undermine trust, slow decision making, and complicate governance.

Isolated deployment

Machine learning deployed without integration into alert management and case workflows limits its real-world impact.

Weak data foundations

Machine learning reflects the quality of the data it is trained on. Poor data leads to inconsistent outcomes.

Treating ML as a feature

Machine learning delivers value only when embedded into end-to-end fraud operations, not when treated as a standalone capability.

ChatGPT Image Feb 5, 2026, 05_14_46 PM

How Machine Learning Fits into End-to-End Fraud Operations

High-performing fraud programmes integrate machine learning across the full lifecycle.

  • Detection surfaces behavioural risk early
  • Prioritisation directs attention intelligently
  • Case workflows enforce consistency
  • Outcomes feed back into model learning

This closed loop ensures continuous improvement rather than static performance.

Where Tookitaki Fits

Tookitaki applies machine learning in transaction fraud detection as an intelligence layer that enhances decision quality rather than replacing human judgement.

Within the FinCense platform:

  • Behavioural anomalies are detected using ML models
  • Alerts are prioritised based on risk and historical outcomes
  • Fraud signals align with broader financial crime monitoring
  • Decisions remain explainable, auditable, and regulator-ready

This approach enables faster action without sacrificing control or transparency.

The Future of Transaction Fraud Detection in Australia

As payment speed increases and scams become more sophisticated, transaction fraud detection will continue to evolve.

Key trends include:

  • Greater reliance on behavioural intelligence
  • Closer alignment between fraud and AML controls
  • Faster, more proportionate decisioning
  • Stronger learning loops from investigation outcomes
  • Increased focus on explainability

Machine learning will remain central, but only when applied with discipline and operational clarity.

Conclusion

Machine learning has become a critical capability in transaction fraud detection for banks in Australia because fraud itself has become behavioural, fast, and adaptive.

Used well, machine learning helps banks detect subtle risk signals earlier, prioritise attention intelligently, and reduce unnecessary friction for customers. Used poorly, it creates opacity and operational risk.

The difference lies not in the technology, but in how it is embedded into workflows, governed, and aligned with human judgement.

In Australian banking, effective fraud detection is no longer about catching anomalies.
It is about understanding behaviour before damage is done.

Machine Learning in Transaction Fraud Detection for Banks in Australia
Blogs
06 Feb 2026
6 min
read

PEP Screening Software for Banks in Singapore: Staying Ahead of Risk with Smarter Workflows

PEPs don’t carry a sign on their backs—but for banks, spotting one before a scandal breaks is everything.

Singapore’s rise as a global financial hub has come with heightened regulatory scrutiny around Politically Exposed Persons (PEPs). With MAS tightening expectations and the FATF pushing for robust controls, banks in Singapore can no longer afford to rely on static screening. They need software that evolves with customer profiles, watchlist changes, and compliance expectations—in real time.

This blog breaks down how PEP screening software is transforming in Singapore, what banks should look for, and why Tookitaki’s AI-powered approach stands apart.

Talk to an Expert

What Is a PEP and Why It Matters

A Politically Exposed Person (PEP) refers to an individual who holds a prominent public position, or is closely associated with someone who does—such as heads of state, senior politicians, judicial officials, military leaders, or their immediate family members and close associates. Due to their influence and access to public funds, PEPs pose a heightened risk of involvement in bribery, corruption, and money laundering.

While not all PEPs are bad actors, the risks associated with their transactions demand extra vigilance. Regulators like MAS and FATF recommend enhanced due diligence (EDD) for these individuals, including proactive screening and continuous monitoring throughout the customer lifecycle.

In short: failing to identify a PEP relationship in time could mean reputational damage, regulatory penalties, and even a loss of banking licence.

The Compliance Challenge in Singapore

Singapore’s regulatory expectations have grown stricter over the years. MAS has made it clear that screening should go beyond one-time onboarding. Banks are expected to identify PEP relationships not just at the point of entry but across the entire duration of the customer relationship.

Several challenges make this difficult:

  • High volumes of customer data to screen continuously.
  • Frequent changes in customer profiles, e.g., new employment, marital status, or residence.
  • Evolving watchlists with updated PEP information from global sources.
  • Manual or delayed re-screening processes that can miss critical changes.
  • False positives that waste compliance teams’ time.

To meet these demands, Singapore banks need PEP screening software that’s smarter, faster, and built for ongoing change.

Key Features of a Modern PEP Screening Solution

1. Continuous Monitoring, Not One-Time Checks

Modern compliance means never taking your eye off the ball. Static, once-at-onboarding screening is no longer enough. The best PEP screening software today enables continuous monitoring—tracking changes in both customer profiles and watchlists, triggering automated re-screening when needed.

2. Delta Screening Capabilities

Delta screening refers to the practice of screening only the deltas—the changes—rather than re-processing the entire database each time.

  • When a customer updates their address or job title, the system should re-screen that profile.
  • When a watchlist is updated with new names or aliases, only impacted customers are re-screened.

This targeted, intelligent approach reduces processing time, improves accuracy, and ensures compliance in near real time.

3. Trigger-Based Workflows

Effective PEP screening software incorporates three key triggers:

  • Customer Onboarding: New customers are screened across global and regional watchlists.
  • Customer Profile Changes: KYC updates (e.g., name, job title, residency) automatically trigger re-screening.
  • Watchlist Updates: When new names or categories are added to lists, relevant customer profiles are flagged and re-evaluated.

This triad ensures that no material change goes unnoticed.

4. Granular Risk Categorisation

Not all PEPs present the same level of risk. Sophisticated solutions can classify PEPs as Domestic, Foreign, or International Organisation PEPs, and further distinguish between primary and secondary associations. This enables more tailored risk assessments and avoids blanket de-risking.

5. AI-Powered Name Matching and Fuzzy Logic

Due to transliterations, nicknames, and data inconsistencies, exact-match screening is prone to failure. Leading tools employ fuzzy matching powered by AI, which can catch near-matches without flooding teams with irrelevant alerts.

6. Audit Trails and Case Management Integration

Every alert and screening decision must be traceable. The best systems integrate directly with case management modules, enabling investigators to drill down, annotate, and close cases efficiently, while maintaining clear audit trails for regulators.

The Cost of Getting It Wrong

Regulators around the world have handed out billions in penalties to banks for PEP screening failures. Even in Singapore, where regulatory enforcement is more targeted, MAS has issued heavy penalties and public reprimands for AML control failures, especially in cases involving foreign PEPs and money laundering through shell firms.

Here are a few consequences of subpar PEP screening:

  • Regulatory fines and enforcement action
  • Increased scrutiny during inspections
  • Reputational damage and customer distrust
  • Loss of banking licences or correspondent banking relationships

For a global hub like Singapore, where cross-border relationships are essential, proactive compliance is not optional—it’s strategic.

How Tookitaki Helps Banks in Singapore Stay Compliant

Tookitaki’s FinCense platform is built for exactly this challenge. Here’s how its PEP screening module raises the bar:

✅ Continuous Delta Screening

Tookitaki combines watchlist delta screening (for list changes) and customer delta screening (for profile updates). This ensures that:

  • Screening happens only when necessary, saving time and resources.
  • Alerts are contextual and prioritised, reducing false positives.
  • The system automatically re-evaluates profiles without manual intervention.

✅ Real-Time Triggering at All Key Touchpoints

Whether it's onboarding, customer updates, or watchlist additions, Tookitaki's screening engine fires in real time—keeping compliance teams ahead of evolving risks.

✅ Scenario-Based Screening Intelligence

Tookitaki's AFC Ecosystem provides a library of risk scenarios contributed by compliance experts globally. These scenarios act as intelligence blueprints, enhancing the screening engine’s ability to flag real risk, not just name similarity.

✅ Seamless Case Management and Reporting

Integrated case management lets investigators trace, review, and report every screening outcome with ease—ensuring internal consistency and regulatory alignment.

ChatGPT Image Feb 5, 2026, 03_43_09 PM

PEP Screening in the MAS Playbook

The Monetary Authority of Singapore (MAS) expects financial institutions to implement risk-based screening practices for identifying PEPs. Some of its key expectations include:

  • Enhanced Due Diligence: Particularly for high-risk foreign PEPs.
  • Ongoing Monitoring: Regular updates to customer risk profiles, including re-screening upon any material change.
  • Independent Audit and Validation: Institutions should regularly test and validate their screening systems.

MAS has also signalled a move towards more data-driven supervision, meaning banks must be able to demonstrate how their systems make decisions—and how alerts are resolved.

Tookitaki’s transparent, auditable approach aligns directly with these expectations.

What to Look for in a PEP Screening Vendor

When evaluating PEP screening software in Singapore, banks should ask the following:

  • Does the software support real-time, trigger-based workflows?
  • Can it conduct delta screening for both customers and watchlists?
  • Is the system integrated with case management and regulatory reporting?
  • Does it provide granular PEP classification and risk scoring?
  • Can it adapt to changing regulations and global watchlists with ease?

Tookitaki answers “yes” to each of these, with deployments across multiple APAC markets and strong validation from partners and clients.

The Future of PEP Screening: Real-Time, Intelligent, Adaptive

As Singapore continues to lead the region in digital finance and cross-border banking, compliance demands will only intensify. PEP screening must move from being a reactive, periodic function to a real-time, dynamic control—one that protects not just against risk, but against irrelevance.

Tookitaki’s vision of collaborative compliance—where real-world intelligence is constantly fed into smarter systems—offers a blueprint for this future. Screening software must not only keep pace with regulatory change, but also help institutions anticipate it.

Final Thoughts

For banks in Singapore, PEP screening isn’t just about ticking regulatory boxes. It’s about upholding trust in a fast-moving, high-stakes environment. With global PEP networks expanding and compliance expectations tightening, only software that is real-time, intelligent, and audit-ready can help banks stay compliant and competitive.

Tookitaki offers just that—an industry-leading AML platform that turns screening into a strategic advantage.

PEP Screening Software for Banks in Singapore: Staying Ahead of Risk with Smarter Workflows
Blogs
05 Feb 2026
6 min
read

From Alert to Closure: AML Case Management Workflows in Australia

AML effectiveness is not defined by how many alerts you generate, but by how cleanly you take one customer from suspicion to resolution.

Introduction

Australian banks do not struggle with a lack of alerts. They struggle with what happens after alerts appear.

Transaction monitoring systems, screening engines, and risk models all generate signals. Individually, these signals may be valid. Collectively, they often overwhelm compliance teams. Analysts spend more time navigating alerts than investigating risk. Supervisors spend more time managing queues than reviewing decisions. Regulators see volume, but question consistency.

This is why AML case management workflows matter more than detection logic alone.

Case management is where alerts are consolidated, prioritised, investigated, escalated, documented, and closed. It is the layer where operational efficiency is created or destroyed, and where regulatory defensibility is ultimately decided.

This blog examines how modern AML case management workflows operate in Australia, why fragmented approaches fail, and how centralised, intelligence-driven workflows take institutions from alert to closure with confidence.

Talk to an Expert

Why Alerts Alone Do Not Create Control

Most AML stacks generate alerts across multiple modules:

  • Transaction monitoring
  • Name screening
  • Risk profiling

Individually, each module may function well. The problem begins when alerts remain siloed.

Without centralised case management:

  • The same customer generates multiple alerts across systems
  • Analysts investigate fragments instead of full risk pictures
  • Decisions vary depending on which alert is reviewed first
  • Supervisors lose visibility into true risk exposure

Control does not come from alerts. It comes from how alerts are organised into cases.

The Shift from Alerts to Customers

One of the most important design principles in modern AML case management is simple:

One customer. One consolidated case.

Instead of investigating alerts, analysts investigate customers.

This shift immediately changes outcomes:

  • Duplicate alerts collapse into a single investigation
  • Context from multiple systems is visible together
  • Decisions are made holistically rather than reactively

The result is not just fewer cases, but better cases.

How Centralised Case Management Changes the Workflow

The attachment makes the workflow explicit. Let us walk through it from start to finish.

1. Alert Consolidation Across Modules

Alerts from:

  • Fraud and AML detection
  • Screening
  • Customer risk scoring

Flow into a single Case Manager.

This consolidation achieves two critical things:

  • It reduces alert volume through aggregation
  • It creates a unified view of customer risk

Policies such as “1 customer, 1 alert” are only possible when case management sits above individual detection engines.

This is where the first major efficiency gain occurs.

2. Case Creation and Assignment

Once alerts are consolidated, cases are:

  • Created automatically or manually
  • Assigned based on investigator role, workload, or expertise

Supervisors retain control without manual routing.

This prevents:

  • Ad hoc case ownership
  • Bottlenecks caused by manual handoffs
  • Inconsistent investigation depth

Workflow discipline starts here.

3. Automated Triage and Prioritisation

Not all cases deserve equal attention.

Effective AML case management workflows apply:

  • Automated alert triaging at L1
  • Risk-based prioritisation using historical outcomes
  • Customer risk context

This ensures:

  • High-risk cases surface immediately
  • Low-risk cases do not clog investigator queues
  • Analysts focus on judgement, not sorting

Alert prioritisation is not about ignoring risk. It is about sequencing attention correctly.

4. Structured Case Investigation

Investigators work within a structured workflow that supports, rather than restricts, judgement.

Key characteristics include:

  • Single view of alerts, transactions, and customer profile
  • Ability to add notes and attachments throughout the investigation
  • Clear visibility into prior alerts and historical outcomes

This structure ensures:

  • Investigations are consistent across teams
  • Evidence is captured progressively
  • Decisions are easier to explain later

Good investigations are built step by step, not reconstructed at the end.

5. Progressive Narrative Building

One of the most common weaknesses in AML operations is late narrative creation.

When narratives are written only at closure:

  • Reasoning is incomplete
  • Context is forgotten
  • Regulatory review becomes painful

Modern case management workflows embed narrative building into the investigation itself.

Notes, attachments, and observations feed directly into the final case record. By the time a case is ready for disposition, the story already exists.

6. STR Workflow Integration

When escalation is required, case management becomes even more critical.

Effective workflows support:

  • STR drafting within the case
  • Edit, approval, and audit stages
  • Clear supervisor oversight

Automated STR report generation reduces:

  • Manual errors
  • Rework
  • Delays in regulatory reporting

Most importantly, the STR is directly linked to the investigation that justified it.

7. Case Review, Approval, and Disposition

Supervisors review cases within the same system, with full visibility into:

  • Investigation steps taken
  • Evidence reviewed
  • Rationale for decisions

Case disposition is not just a status update. It is the moment where accountability is formalised.

A well-designed workflow ensures:

  • Clear approvals
  • Defensible closure
  • Complete audit trails

This is where institutions stand up to regulatory scrutiny.

8. Reporting and Feedback Loops

Once cases are closed, outcomes should not disappear into archives.

Strong AML case management workflows feed outcomes into:

  • Dashboards
  • Management reporting
  • Alert prioritisation models
  • Detection tuning

This creates a feedback loop where:

  • Repeat false positives decline
  • Prioritisation improves
  • Operational efficiency compounds over time

This is how institutions achieve 70 percent or higher operational efficiency gains, not through headcount reduction, but through workflow intelligence.

ChatGPT Image Feb 4, 2026, 01_34_59 PM

Why This Matters in the Australian Context

Australian institutions face specific pressures:

  • Strong expectations from AUSTRAC on decision quality
  • Lean compliance teams
  • Increasing focus on scam-related activity
  • Heightened scrutiny of investigation consistency

For community-owned banks, efficient and defensible workflows are essential to sustaining compliance without eroding customer trust.

Centralised case management allows these institutions to scale judgement, not just systems.

Where Tookitaki Fits

Within the FinCense platform, AML case management functions as the orchestration layer of Tookitaki’s Trust Layer.

It enables:

  • Consolidation of alerts across AML, screening, and risk profiling
  • Automated triage and intelligent prioritisation
  • Structured investigations with progressive narratives
  • Integrated STR workflows
  • Centralised reporting and dashboards

Most importantly, it transforms AML operations from alert-driven chaos into customer-centric, decision-led workflows.

How Success Should Be Measured

Effective AML case management should be measured by:

  • Reduction in duplicate alerts
  • Time spent per high-risk case
  • Consistency of decisions across investigators
  • Quality of STR narratives
  • Audit and regulatory outcomes

Speed alone is not success. Controlled, explainable closure is success.

Conclusion

AML programmes do not fail because they miss alerts. They fail because they cannot turn alerts into consistent, defensible decisions.

In Australia’s regulatory environment, AML case management workflows are the backbone of compliance. Centralised case management, intelligent triage, structured investigation, and integrated reporting are no longer optional.

From alert to closure, every step matters.
Because in AML, how a case is handled matters far more than how it was triggered.

From Alert to Closure: AML Case Management Workflows in Australia