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What are the US anti-money laundering laws?

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Tookitaki
19 May 2021
6 min
read

Money laundering is a heinous crime affecting millions of lives every year. It is the process of incorporating illegally obtained money into the legitimate financial system using various techniques. According to UN estimates, the size of money laundering every year is equivalent to 2-5% of global annual gross domestic product (GDP), translating to about US$800 billion to US$2 trillion per year.

In order to counter money laundering, governments and intergovernmental agencies have formulated certain rules, recommendations and procedures for subject entities and individuals. These together form anti-money laundering (AML) frameworks for regions and countries. AML frameworks are necessary for the safety of economies and societies, as they work as guidelines for detecting and preventing money laundering and related crimes.

Nations across the globe have come up with various legislations to counter money laundering. In general, these legislations define how financial institutions within a country will work with government agencies to protect clients, societies and the country. Some examples of these legislations include the Bank Secrecy Act (BSA) in the US, the USA Patriot Act, the Anti-money Laundering Directives (AMLDs) in Europe, the Sanctions and Anti-Money Laundering Act (SAMLA) in the UK and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) in Canada.

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Anti-Money Laundering (AML) Laws in the US

Being an economically developed country, the US finds money laundering as a serious problem affecting its financial system. It is estimated that about half of the money being laundered across the globe is done via financial institutions in the US. The country is among the first in the world to formulate effective laws to counter money laundering. It enacted the BSA in 1970 and the act has become one of the most important tools in the fight against money laundering. Since then, numerous other laws have enhanced and amended the BSA to provide law enforcement and regulatory agencies with the most effective tools to combat money laundering. Given below are the important AML laws in the US.

Learn More: Layering in Money Laundering

Bank Secrecy Act (BSA) 1970

The Bank Secrecy Act (BSA) was introduced in the US in 1970 and is still the country’s most important anti-money laundering law. Administered by the Financial Crimes Enforcement Network (FinCEN), the BSA was formed to ensure that financial institutions in the US do not facilitate money laundering. It is the main authority that is entrusted with the formulation of regulations and policies to combat financial crime in the country. The major provisions of the BSA are the following:

  • Recordkeeping and reporting requirements by private individuals, banks and other financial institutions
  • Measures to identify the source, volume, and movement of currency and other monetary instruments transported or transmitted into or out of the US or deposited in financial institutions
  • Requirements for banks to (1) report cash transactions over $10,000 using the Currency Transaction Report (CTR); (2) properly identify persons conducting transactions; and (3) maintain a paper trail by keeping appropriate records of financial transactions

Money Laundering Control Act 1986

The Money Laundering Control Act of 1986 designated money laundering as a federal crime and prohibited structuring transactions to evade CTR filings. The act also introduced civil and criminal forfeiture for BSA violations. Further, it directed banks to establish and maintain proper AML procedures to ensure and monitor compliance with the reporting and recordkeeping requirements of the BSA.

Learn More: Understanding Money Laundering

Anti-Drug Abuse Act of 1988

The Anti-Drug Abuse Act of 1988 expanded the definition of a financial institution to include businesses such as car dealers and real estate closing personnel and required them to file reports on large currency transactions. It also required the verification of the identity of purchasers of monetary instruments over $3,000.

Annunzio-Wylie Anti-Money Laundering Act 1992

The Annunzio-Wylie Anti-Money Laundering Act of 1992 strengthened the sanctions for BSA violations and required Suspicious Activity Reports (SARs) and eliminated previously used Criminal Referral Forms (CRFs). The act also required from financial institutions verification and recordkeeping for wire transfers. It further established the Bank Secrecy Act Advisory Group (BSAAG).

Money Laundering Suppression Act 1994

The Money Laundering Suppression Act of 1994 required banking agencies to review and enhance training and develop anti-money laundering examination procedures. The act also required banking agencies to review and enhance procedures for referring cases to appropriate law enforcement agencies. Other major provisions of the act include:

  • Streamlined CTR exemption process
  • Registration requirements for each Money Services Business (MSB) by an owner or controlling person
  • Requirements for every MSB to maintain a list of businesses authorized to act as agents in connection with the financial services offered by the MSB
  • Operating an unregistered MSB became a federal crime

Money Laundering and Financial Crimes Strategy Act 1998

The Money Laundering and Financial Crimes Strategy Act of 1998 required banking agencies to develop AML training for examiners. The act also required the Department of the Treasury and other agencies to develop a National Money Laundering Strategy. It further created the High-Intensity Money Laundering and Related Financial Crime Area (HIFCA) Task Forces to concentrate law enforcement efforts at the federal, state and local levels in zones where money laundering is prevalent. HIFCAs may be defined geographically or they can also be created to address money laundering in an industry sector, a financial institution, or a group of financial institutions.

USA PATRIOT Act 2001

After the September 11, 2001 attacks, the US revamped the BSA and introduced the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act) that requires all financial institutions to establish their own AML programs. Title III of the act is referred to as the International Money Laundering Abatement and Financial Anti-Terrorism Act of 2001. The act criminalized the financing of terrorism and augmented the existing BSA framework by strengthening customer identification procedures. It also prohibited financial institutions from engaging in business with foreign shell banks. Other provisions of the act include:

  • Requirements for financial institutions to have due diligence procedures and enhanced due diligence procedures for foreign correspondent and private banking accounts
  • Improved information sharing between financial institutions and the US government by requiring government-institution information sharing and voluntary information sharing among financial institutions
  • Expansion of the anti-money laundering program requirements to all financial institutions
  • Higher civil and criminal penalties for money laundering
  • Authorization for the Secretary of the Treasury to impose "special measures" on jurisdictions, institutions, or transactions that are of "primary money laundering concern"
  • Requirement for banks to respond to regulatory requests for information within 120 hours
  • Federal banking agencies started considering a bank's AML record when reviewing bank mergers, acquisitions, and other applications for business combinations

Intelligence Reform & Terrorism Prevention Act 2004

The Intelligence Reform & Terrorism Prevention Act of 2004 amended the BSA to require the Secretary of the Treasury to prescribe regulations requiring certain financial institutions to report cross-border electronic transmittals of funds.

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Anti-Money Laundering Act (AMLA) 2020

The US Senate passed the National Defense Authorization Act (NDAA) 2021 on January 1, 2021. As part of the NDAA, the Anti-Money Laundering Act of 2020 (AML Act) is poised to amend the Bank Secrecy Act (BSA) for the first time since 2001. The AML Act will modernize the BSA. Specifically, it is intended to prevent money launderers from using shell companies to evade detection. Further, the Act will address emerging financial threats, encourage coordination and information sharing, and promote technological innovation. The AML Act provisions the creation of an Ultimate Beneficial Ownership (UBO) register and strengthens the enforcement’s ability to seek foreign bank records.

The PATRIOT Act and the Bank Secrecy Act provide a layer of protection to the USA’s economy and financial institutions against money laundering and other financial crimes. These laws encompass the procedure to recognize suspicious activity, flag off concerned authorities, and trigger the necessary legal action required to charge the criminals. These laws have the power to have suspicious financial institutions investigated by the Federal Reserve and the Office of the Comptroller of Currency. Financial institutions in the US should proper AML compliance programs to ensure compliance with these laws.

Tookitaki’s modern AML solutions help financial institutions build futuristic compliance programs adhering to local laws and regulations. Contact us for a demo if you want to learn more.

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Blogs
24 Nov 2025
6 min
read

Singapore’s Secret Weapon Against Dirty Money? Smarter AML Investigation Tools

In the fight against financial crime, investigation tools can make or break your compliance operations.

With Singapore facing growing threats from money mule syndicates, trade-based laundering, and cyber-enabled fraud, the need for precise and efficient anti-money laundering (AML) investigations has never been more urgent. In this blog, we explore how AML investigation tools are evolving to help compliance teams in Singapore accelerate detection, reduce false positives, and stay audit-ready.

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What Are AML Investigation Tools?

AML investigation tools are technology solutions that assist compliance teams in detecting, analysing, documenting, and reporting suspicious financial activity. These tools bridge the gap between alert generation and action — providing context, workflow, and intelligence to identify real risk from noise.

These tools can be:

  • Standalone modules within AML software
  • Integrated into broader case management systems
  • Powered by AI, machine learning, or rules-based engines

Why They Matter in the Singapore Context

Singapore’s financial services sector faces increasing pressure from regulators, counterparties, and the public to uphold world-class compliance standards. Investigation tools help institutions:

  • Quickly triage and resolve alerts from transaction monitoring or screening systems
  • Understand customer behaviour and transactional context
  • Collaborate across teams for efficient case resolution
  • Document decisions in a regulator-ready audit trail

Key Capabilities of Modern AML Investigation Tools

1. Alert Contextualisation

Investigators need context around each alert:

  • Who is the customer?
  • What’s their risk rating?
  • Has this activity occurred before?
  • What other products do they use?

Good tools aggregate this data into a single view to save time and prevent errors.

2. Visualisation of Transaction Patterns

Network graphs and timelines show links between accounts, beneficiaries, and geographies. These help spot circular payments, layering, or collusion.

3. Narrative Generation

AI-generated case narratives can summarise key findings and explain the decision to escalate or dismiss an alert. This saves time and ensures consistency in reporting.

4. Investigator Workflow

Assign tasks, track time-to-resolution, and route high-risk alerts to senior reviewers — all within the system.

5. Integration with STR Filing

Once an alert is confirmed as suspicious, the system should auto-fill suspicious transaction report (STR) templates for MAS submission.

Common Challenges Without Proper Tools

Many institutions still struggle with manual or legacy investigation processes:

  • Copy-pasting between systems and spreadsheets
  • Investigating the same customer multiple times due to siloed alerts
  • Missing deadlines for STR filing
  • Poor audit trails, leading to compliance risk

In high-volume environments like Singapore’s fintech hubs or retail banks, these inefficiencies create operational drag.

Real-World Example: Account Takeover Fraud via Fintech Wallets

An e-wallet provider in Singapore noticed a spike in high-value foreign exchange transactions.

Upon investigation, the team found:

  • Victim accounts were accessed via compromised emails
  • Wallet balances were converted into EUR/GBP instantly
  • Funds were moved to mule accounts and out to crypto exchanges

Using an investigation tool with network mapping and device fingerprinting, the compliance team:

  • Identified shared mule accounts across multiple victims
  • Escalated the case to the regulator within 24 hours
  • Blocked future similar transactions using rule updates
ChatGPT Image Nov 24, 2025, 10_00_56 AM

Tookitaki’s FinCense: Investigation Reinvented

Tookitaki’s FinCense platform provides end-to-end investigation capabilities designed for Singapore’s regulatory and operational needs.

Features That Matter:

  • FinMate: An AI copilot that analyses alerts, recommends actions, and drafts case narratives
  • Smart Disposition: Automatically generates case summaries and flags key findings
  • Unified Case Management: Investigators work from a single dashboard that integrates monitoring, screening, and risk scoring
  • MAS-Ready Reporting: Customisable templates for local regulatory formats
  • Federated Intelligence: Access 1,200+ community-driven typologies from the AFC Ecosystem to cross-check against ongoing cases

Results From Tookitaki Clients:

  • 72% fewer false positives
  • 3.5× faster resolution times
  • STR submission cycles shortened by 60%

Regulatory Expectations from MAS

Under MAS guidelines, financial institutions must:

  • Have effective alert management processes
  • Ensure timely investigation and STR submission
  • Maintain records of all investigations and decisions
  • Demonstrate scenario tuning and effectiveness reviews

A modern AML investigation tool supports all these requirements, reducing operational and audit burden.

AML Investigation and Emerging Threats

1. Deepfake-Fuelled Impersonation

Tools must validate biometric data and voiceprints to flag synthetic identities.

2. Crypto Layering

Graph-based tracing of wallet addresses is increasingly vital as laundering moves to decentralised finance.

3. Mule Account Clusters

AI-based clustering tools can identify unusual movement patterns across otherwise low-risk individuals.

4. Instant Payments Risk

Real-time investigation support is needed for PayNow, FAST, and other instant channels.

How to Evaluate a Vendor

Ask these questions:

  • Can your tool integrate with our current transaction monitoring system?
  • How do you handle false positive reduction?
  • Do you support scenario simulation and tuning?
  • Is your audit trail MAS-compliant?
  • Can we import scenarios from other institutions (e.g. AFC Ecosystem)?

Looking Ahead: The Future of AML Investigations

AML investigations are evolving from reactive tasks to intelligence-led workflows. Tools are getting:

  • Agentic AI: Copilots like FinMate suggest next steps, reducing guesswork
  • Community-Driven: Knowledge sharing through federated systems boosts preparedness
  • More Visual: Risk maps, entity graphs, and timelines help understand complex flows
  • Smarter Thresholds: ML-driven dynamic thresholds reduce alert fatigue

Conclusion: Investigation is Your Last Line of Defence

In an age of instant payments, cross-border fraud, and synthetic identities, the role of AML investigation tools is mission-critical. Compliance officers in Singapore must be equipped with solutions that go beyond flagging transactions — they must help resolve them fast and accurately.

Tookitaki’s FinCense, with its AI-first approach and regulatory alignment, is redefining how Singaporean institutions approach AML investigations. It’s not just about staying compliant. It’s about staying smart, swift, and one step ahead of financial crime.

Singapore’s Secret Weapon Against Dirty Money? Smarter AML Investigation Tools
Blogs
24 Nov 2025
6 min
read

Fraud Detection Software for Banks: Inside the Digital War Room

Every day in Australia, fraud teams fight a silent battle. This is the story of how they do it, and the software helping them win.

Prologue: The Alert That Shouldn’t Have Happened

It is 2:14 pm on a quiet Wednesday in Sydney.
A fraud investigator at a mid-sized Australian bank receives an alert:
Attempted transfer: 19,800 AUD — flagged as “possible mule routing”.

The transaction looks ordinary.
Local IP.
Registered device.
Customer active for years.

Nothing about it screams fraud.

But the software sees something the human eye cannot:
a subtle deviation in typing cadence, geolocation drift over the past month, and a behavioural mismatch in weekday spending patterns.

This is not the customer.
This is someone pretending to be them.

The transfer is blocked.
The account is frozen.
A customer is protected from losing their savings.

This is the new frontline of fraud detection in Australian banking.
A place where milliseconds matter.
Where algorithms, analysts, and behavioural intelligence work together in near real time.

And behind it all sits one critical layer: fraud detection software built for the world we live in now, not the world we used to live in.

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Chapter 1: Why Fraud Detection Has Become a War Room Operation

Fraud has always existed, but digital banking has changed its scale, speed, and sophistication.
Australian banks are facing:

  • Real-time scams through NPP
  • Deepfake-assisted social engineering
  • Mule networks recruiting on TikTok
  • Synthetic IDs built from fragments of real citizens
  • Remote access scams controlling customer devices
  • Cross-border laundering through fintech rails
  • Account takeover via phishing and malware

Fraud today is not one person trying their luck.
It is supply-chain crime.

And the only way banks can fight it is by transforming fraud detection into a dynamic, intelligence-led discipline supported by software that thinks, learns, adapts, and collaborates.

Chapter 2: What Modern Fraud Detection Software Really Does

Forget the outdated idea that fraud detection is simply about rules.

Modern software must:

  • Learn behaviour
  • Spot anomalies
  • Detect device manipulation
  • Understand transaction velocity
  • Identify network relationships
  • Analyse biometrics
  • Flag mule-like patterns
  • Predict risk, not just react to it

The best systems behave like digital detectives.

They observe.
They learn.
They connect dots humans cannot connect in real time.

Chapter 3: The Six Capabilities That Define Best-in-Class Fraud Detection Software

1. Behavioural Biometrics

Typing speed.
Mouse movement.
Pressure on mobile screens.
Session navigation patterns.

These signals reveal whether the person behind the device is the real customer or an impostor.

2. Device Intelligence

Device fingerprinting, jailbreak checks, emulator detection, and remote-access-trojan indicators now play a key role in catching account takeover attempts.

3. Network Link Analysis

Modern fraud does not occur in isolation.
Software must map:

  • Shared devices
  • Shared addresses
  • Linked mule accounts
  • Common beneficiaries
  • Suspicious payment clusters

This is how syndicates are caught.

4. Real-Time Risk Scoring

Fraud cannot wait for batch jobs.
Software must analyse patterns as they happen and block or challenge the transaction instantly.

5. Cross-Channel Visibility

Fraud moves across onboarding, transfers, cards, wallets, and payments.
Detection must be omnichannel, not siloed.

6. Analyst Assistance

The best software does not overwhelm investigators.
It assists them by:

  • Summarising evidence
  • Highlighting anomalies
  • Suggesting next steps
  • Reducing noise

Fraud teams fight harder when the software fights with them.

ChatGPT Image Nov 23, 2025, 07_23_27 PM

Chapter 4: Inside an Australian Bank’s Digital Fraud Team

Picture this scene.

A fraud operations centre in Melbourne.
Multiple screens.
Live dashboards.
Analysts monitoring spikes in activity.

Suddenly, the software detects something:
A cluster of small transfers moving rapidly into multiple new accounts.
Amounts just below reporting thresholds.
Accounts opened within the last three weeks.
Behaviour consistent with mule recruitment.

This is not random.
This is an organised ring.

The fraud team begins tracing the pattern using network graphs visualised by the software.
Connections emerge.
A clear structure forms.
Multiple accounts tied to the same device.
Shared IP addresses across suburbs.

Within minutes, the team has identified a mule network operating across three states.

They block the accounts.
Freeze the funds.
Notify the authorities.
Prevent a chain of victims.

This is fraud detection software at its best:
Augmenting human instinct with machine intelligence.

Chapter 5: The Weaknesses of Old Fraud Detection Systems

Some Australian banks still rely on systems that:

  • Use rigid rules
  • Miss behavioural patterns
  • Cannot detect deepfakes
  • Struggle with NPP velocity
  • Generate high false positives
  • Cannot identify linked accounts
  • Have no real-time capabilities
  • Lack explainability for AUSTRAC or internal audit

These systems were designed for a slower era, when payments were not instantaneous and criminals did not use automation.

Old systems do not fail because they are old.
They fail because the world has changed.

Chapter 6: What Australian Banks Should Look For in Fraud Detection Software (A Modern Checklist)

1. Real-Time Analysis for NPP

Detection must be instant.

2. Behavioural Intelligence

Software should learn how customers normally behave and identify anomalies.

3. Mule Detection Algorithms

Australia is experiencing a surge in mule recruitment.
This is now essential.

4. Explainability

Banks must be able to justify fraud decisions to regulators and customers.

5. Cross-Channel Intelligence

Transfers, cards, NPP, mobile apps, and online banking must speak to each other.

6. Noise Reduction

Software must reduce false positives, not amplify them.

7. Analyst Enablement

Investigators should receive context, not clutter.

8. Scalability for Peak Fraud Events

Fraud often surges during crises, holidays, and scams going viral.

9. Localisation

Australian fraud patterns differ from other regions.

10. Resilience

APRA CPS 230 demands operational continuity and strong third-party governance.

Fraud software is now part of a bank’s resilience framework, not just its compliance toolkit.

Chapter 7: How Tookitaki Approaches Fraud Detection

Tookitaki’s approach to fraud detection is built around one core idea:
fraudsters behave like networks, not individuals.

FinCense analyses risk across relationships, devices, behaviours, and transactions to detect patterns traditional systems miss.

What makes it different:

1. A Behaviour-First Model

Instead of relying on static rules, the system understands customer behaviour over time.
This helps identify anomalies that signal account takeover or mule activity.

2. Investigation Intelligence

Tookitaki supports analysts with enriched context, visual evidence, and prioritised risks, reducing decision fatigue.

3. Multi-Channel Detection

Fraud does not stay in one place, and neither does the software.
It connects signals across payments, wallets, online banking, and transfers.

4. Designed for Both Large and Community Banks

Institutions such as Regional Australia Bank benefit from accurate detection without operational complexity.

5. Built for Real-Time Environments

FinCense supports high-velocity payments, enabling institutions to detect risk at NPP speed.

Tookitaki is not designed to overwhelm banks with rules.
It is designed to give them a clear picture of risk in a world where fraud changes daily.

Chapter 8: The Future of Fraud Detection in Australian Banking

1. Deepfake-Resistant Identity Verification

Banks will need technology that can detect video, voice, and biometric spoofing.

2. Agentic AI Assistants for Investigators

Fraud teams will have copilots that surface insights, summarise cases, and provide investigative recommendations.

3. Network-Wide Intelligence Sharing

Banks will fight fraud together, not alone, through federated learning and shared typology networks.

4. Real-Time Customer Protection

Banks will block suspicious payments before they leave the customer’s account.

5. Predictive Fraud Prevention

Systems will identify potential mule behaviour before the account becomes active.

Fraud detection will become proactive, not reactive.

Conclusion

Fraud detection software is no longer a technical add-on.
It is the digital armour protecting customers, banks, and the integrity of the financial system.

The frontline has shifted.
Criminals operate as organised networks, use automation, manipulate devices, and exploit real-time payments.
Banks need software built for this reality, not yesterday’s.

The right fraud detection solution gives banks something they cannot afford to lose:
time, clarity, and confidence.

Because in today’s Australian financial landscape, fraud moves fast.
Your software must move faster.

Fraud Detection Software for Banks: Inside the Digital War Room
Blogs
21 Nov 2025
6 min
read

AML Software in Australia: The 7 Big Questions Every Bank Should Be Asking in 2025

Choosing AML software used to be a technical decision. In 2025, it has become one of the most strategic choices a bank can make.

Introduction

Australia’s financial sector is entering a defining moment. Instant payments, cross-border digital crime, APRA’s tightening expectations, AUSTRAC’s data scrutiny, and the rise of AI are forcing banks to rethink their entire compliance tech stack.

At the centre of this shift sits one critical question: what should AML software actually do in 2025?

This blog does not give you a shopping list or a vendor comparison.
Instead, it explores the seven big questions every Australian bank, neobank, and community-owned institution should be asking when evaluating AML software. These are the questions that uncover risk, expose limitations, and reveal whether a solution is built for the next decade, not the last.

Let’s get into them.

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Question 1: Does the AML Software Understand Risk the Way Australia Defines It?

Most AML systems were designed with global rule sets that do not map neatly to Australian realities.

Australia has:

  • Distinct PEP classifications
  • Localised money mule typologies
  • Syndicated fraud patterns unique to the region
  • NPP-driven velocity in payment behaviour
  • AUSTRAC expectations around ongoing due diligence
  • APRA’s new focus on operational resilience

AML software must be calibrated to Australian behaviours, not anchored to American or European assumptions.

What to look for

  • Localised risk models trained on Australian financial behaviour
  • Models that recognise local account structures and payment patterns
  • Typologies relevant to the region
  • Adaptability to NPP and emerging scams affecting Australians
  • Configurable rule logic for Australia’s regulatory environment

If software treats all markets the same, its risk understanding will always be one step behind Australian criminals.

Question 2: Can the Software Move at the Speed of NPP?

The New Payments Platform changed everything.
What used to be processed in hours is now settled in seconds.

This means:

  • Risk scoring must be real time
  • Monitoring must be continuous
  • Alerts must be triggered instantly
  • Investigators need immediate context, not post-fact analysis

Legacy systems built for batch processing simply cannot keep up with the velocity or volatility of NPP transactions.

What to look for

  • True real-time screening and monitoring
  • Sub-second scoring
  • Architecture built for high-volume environments
  • Scalability without performance drops
  • Real-time alert triaging

If AML software cannot respond before a payment settles, it is already too late.

Question 3: Does the Software Reduce False Positives in a Meaningful Way?

Every vendor claims they reduce false positives.
The real question is how and by how much.

In Australia, many banks spend up to 80 percent of their AML effort investigating low-value alerts. This creates fatigue, delays, and inconsistent decisions.

Modern AML software must:

  • Prioritise alerts based on true behavioural risk
  • Provide contextual information alongside flags
  • Reduce noise without reducing sensitivity
  • Identify relationships, patterns, and anomalies that rules alone miss

What to look for

  • Documented false positive reduction numbers
  • Behavioural analytics that distinguish typical from atypical activity
  • Human-in-the-loop learning
  • Explainable scoring logic
  • Tiered risk categorisation

False positives drain resources.
Reducing them responsibly is a competitive advantage.

Question 4: How Does the Software Support Investigator Decision-Making?

Analysts are the heart of AML operations.
Software should not just alert them. It should empower them.

The most advanced AML platforms are moving toward investigator-centric design, helping analysts work faster, more consistently, and with greater clarity.

What to look for

  • Clear narratives attached to alerts
  • Visual network link analysis
  • Relationship mapping
  • Easy access to KYC, transaction history, and behaviour insights
  • Tools that surface relevant context without manual digging

If AML software only generates alerts but does not explain them, it is not modern software. It is a data dump.

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Question 5: Is the AML Software Explainable Enough for AUSTRAC?

AUSTRAC’s reviews increasingly require banks to justify their risk models and demonstrate why a decision was made.

AML software must show:

  • Why an alert was generated
  • What data was used
  • What behavioural markers contributed
  • How the system ranked or prioritised risk
  • How changes over time affected decision logic

Explainability is now a regulatory requirement, not a bonus feature.

What to look for

  • Decision logs
  • Visual explanations
  • Feature attribution for risk scoring
  • Scenario narratives
  • Governance dashboards

Opaque systems that cannot justify their reasoning leave institutions vulnerable during audits.

Question 6: How Well Does the AML Software Align With APRA’s CPS 230 Expectations?

Operational resilience is now a board-level mandate.
AML software sits inside the cluster of critical systems APRA expects institutions to govern closely.

This includes:

  • Third-party risk oversight
  • Business continuity
  • Incident management
  • Data quality controls
  • Outsourcing governance

AML software is no longer evaluated only by compliance teams.
It must satisfy risk, technology, audit, and resilience requirements too.

What to look for

  • Strong uptime track record
  • Clear incident response procedures
  • Transparent service level reporting
  • Secure and compliant hosting
  • Tested business continuity measures
  • Clear vendor accountability and control frameworks

If AML software cannot meet CPS 230 expectations, it cannot meet modern banking expectations.

Question 7: Will the Software Still Be Relevant Five Years From Now?

This is the question few institutions ask, but the one that matters most.
AML software is not a one-year decision. It is a multi-year partnership.

To future-proof compliance, banks must look beyond features and evaluate adaptability.

What to look for

  • A roadmap that includes new crime types
  • AI models that learn responsibly
  • Agentic support tools that help investigators
  • Continuous updates without major uplift projects
  • Collaborative intelligence capabilities
  • Strong alignment with emerging AML trends in Australia

This is where vendors differentiate themselves.
Some provide tools.
A few provide evolution.

A Fresh Look at Tookitaki

Tookitaki has emerged as a preferred AML technology partner among several banks across Asia-Pacific, including institutions in Australia, because it focuses less on building features and more on building confidence.

Confidence that alerts are meaningful.
Confidence that the system is explainable.
Confidence that operations remain stable.
Confidence that investigators have support.
Confidence that intelligence keeps evolving.

Rather than positioning AML as a fixed set of rules, Tookitaki approaches it as a learning discipline.

Its platform, FinCense, helps Australian institutions strengthen:

  • Real time monitoring capability
  • Consistency in analyst decisions
  • Model transparency for AUSTRAC
  • Operational resilience for APRA expectations
  • Adaptability to emerging typologies
  • Scalability for both large and community institutions like Regional Australia Bank

This is AML software designed not only to detect crime, but to grow with the institution.

Conclusion

AML software in Australia is at a crossroads.
The era of legacy rules, static scenarios, and batch processing is ending.
Banks now face a new set of expectations driven by speed, transparency, resilience, and intelligence.

The seven questions in this guide cut through the noise. They help institutions evaluate AML software not as a product, but as a long-term strategic partner for risk management.

Australia’s financial sector is changing quickly.
The right AML software will help banks move confidently into that future.
The wrong one will hold them back.

Pro tip: The strongest AML systems are not just built on good software. They are built on systems that understand the world they operate in, and evolve alongside it.

AML Software in Australia: The 7 Big Questions Every Bank Should Be Asking in 2025