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Understanding PEPs: Definition, Types & Risk Levels According to FATF

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Tookitaki
12 Oct 2021
7 min
read

The term "Politically Exposed Person" or PEP often comes up in conversations around anti-money laundering and combating the financing of terrorism (AML/CFT). But what exactly does it mean, and why should you care? When it comes to understanding what is a pep, it is essential to comprehend that these individuals possess great power, influence, and consequently, a higher propensity to engage in illicit activities such as bribery or money laundering

In this comprehensive guide, we'll explore the intricate world of PEPs, as outlined by the Financial Action Task Force (FATF), the global money laundering and terrorist financing watchdog, and shed light on the significance of PEP screening in financial institutions.

What is a PEP and PEP according to FATF

A Politically Exposed Person (PEP) is an individual who has been entrusted with a prominent public function, either domestically or internationally. Due to their position and influence, PEPs are at a higher risk of being involved in bribery, corruption, or money laundering. The Financial Action Task Force (FATF) provides a detailed framework to understand the definition and types of PEPs, which serves as a global standard for nations and organizations alike.

Examples of PEP

PEPs are not just confined to politicians. They can also include senior government officials, judicial authorities, military officers, and even high-ranking members of state-owned enterprises. For instance, a mayor of a large city, a general in the army, or a CEO of a government-owned oil company could all be considered PEPs.

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PEPs, as per the FATF classification, embody individuals who currently serve or previously held a significant public function in a country. The high-risk nature of these roles is often associated with an enhanced likelihood of their involvement in financial crimes. This susceptibility stems from their ability to influence decisions and control resources, which can potentially be exploited for personal gains. The following categories encapsulate the diverse roles that a PEP may hold:

  • Government Roles: High-ranking officials in either the legislative, executive, or judiciary branches of government. This can range from members of parliament and supreme court judges to ambassadors and diplomats.
  • Organizational Roles: Individuals holding prominent positions in governmental commercial enterprises or political parties. This could include board members of a central bank, party leaders, or high-ranking military officials.
  • Associations: Close associates, either through social or professional connections, to a PEP. This could encompass family members, close relatives, or individuals holding beneficial ownership of a legal entity in which the government is a stakeholder.

Types of PEP Defined by FATF

Bearing in mind the broad scope of what is a PEP, the FATF has further divided PEPs into three primary categories, namely Foreign, Domestic, and International Organization PEPs.

  • Foreign PEPs: These are individuals who hold or have held prominent public positions in a foreign country. The risk associated with foreign PEPs is generally higher due to the challenges in obtaining accurate and timely data about these individuals.
  • Domestic PEPs: These refer to individuals who hold or have held significant public functions within their home country. While they also pose a risk, it is generally lower than that of their foreign counterparts due to better access to information.
  • International Organization PEPs: These are individuals who hold or have held a high-ranking position in an international organization. The risk associated with these PEPs can vary depending on factors such as the organization's transparency, the individual's role, and the level of oversight exercised.
HOW FATF CLASSIFIES PEPs

PEP Risk Levels

Understanding the PEP definition is only the first step in managing financial crime risks. The subsequent step involves a detailed risk assessment, which is crucial for regulated corporations dealing with PEPs. 

Risk associated with PEPs is generally assessed on multiple factors including the corruption level of the country they originate from, the nature of their role, and their access to significant financial resources. It's a tiered approach, ranging from low to high risk, and the scrutiny applied varies accordingly. The FATF outlines four levels of risk for PEPs:

  • Low-level risk: This encompasses supranational or international business officials and senior functionaries, as well as members of local, state, district, and urban assemblies.
  • Medium/low-level risk: This category includes top officials of government boards and state-owned enterprises such as heads of judiciaries, banks, military, law enforcement, and high-ranked civil servants in state agencies and religious organizations.
  • Medium/high-level risk: This segment includes individuals who are members of the government, parliament, judiciary, banks, law enforcement, military, and prominent political parties.
  • High-level risk: This is the highest risk category and includes heads of state or government, senior politicians, judicial or military officials, senior executives of state-owned corporations, and important party officials.

Red Flags to Watch Out for PEPs by FATF

Recognizing the potential risks associated with PEPs, the FATF has highlighted several red flags that can indicate suspicious activity. These indicators act as warning signals for possible financial abuse and can help corporations detect and control potential illegal activities involving PEPs. Here are some key red flags outlined by the FATF:

  • Unusual Wealth: A drastic and unexplained increase in a PEP's wealth can be a significant red flag.
  • Offshore Accounts: Frequent use of offshore accounts without a logical or apparent reason.
  • Shell Companies: Involvement in operations through shell companies that lack transparency.
  • Identity Concealment: PEPs might attempt to hide their identities to evade scrutiny. This could involve assigning legal ownership to another individual, frequently interacting with intermediaries, or using corporate structures to obscure ownership.
  • Suspicious Behavior: This could include secrecy about the source of funds, providing false or insufficient information, eagerness to justify business dealings, denial of an entry visa, or frequent movement of funds across countries.
  • Company Position: The PEP's position within the company could also raise concerns. This could include having control over the company's funds, operations, policies, or anti-money laundering/terrorist financing mechanisms.
  • Industry: Certain industries are considered high-risk due to their nature and the potential for exploitation. This could include banking and finance, military and defense, businesses dealing with government agencies, construction, mining and extraction, and public goods provision.

Changes in PEP Status: An Evolving Landscape

The PEP landscape has witnessed several changes over the years, primarily in the definition and monitoring of PEPs. The term PEP was initially used to describe senior government officials and their immediate family members only. However, the definition has since been expanded to include individuals who hold prominent positions in international organizations, as well as their close associates. This change reflects the evolving nature of the global economy, where non-governmental organizations and international institutions wield significant power and influence.

The monitoring of PEPs has also evolved. Previously, self-disclosure was the primary method to identify a PEP, which was often ineffective, as some PEPs chose to hide their status or failed to disclose it accurately. Today, governments and financial institutions have access to sophisticated databases and screening tools, thanks to advanced AML compliance software, enhancing the ability to detect potential money laundering and corruption risks associated with PEPs.

Why PEP Screening is Important

Financial crimes pose a significant global concern, and organizations are obligated to comply with anti-money laundering regulations to combat such crimes. As part of this compliance, institutions must identify customers who may have a higher risk of being involved in financial crimes. PEP screening is a crucial process during account opening that helps identify high-risk customers and prevent financial crimes. Failure to adhere to these screening procedures can result in penalties from AML regulators for non-compliant organizations.

PEP screening is crucial because these individuals are at a higher risk of involvement in bribery, corruption, and money laundering due to their position and influence. Failure to conduct proper screening can result in heavy fines for the institution and reputational damage. More importantly, it can facilitate financial crimes that have societal impacts.

How Tookitaki Can Help

As an award-winning regulatory technology (RegTech) company, we are revolutionising financial crime detection and prevention for banks and fintechs with our cutting-edge solutions. We provide an end-to-end, AI-powered AML compliance platform, named the Anti-Money Laundering Suite (AMLS), with modular solutions that help financial institutions deal with the ever-changing financial crime landscape.

Our Smart Screening solution provides accurate screening of names and transactions across many languages and a continuous monitoring framework for comprehensive risk management. Our powerful name-matching engine screens and prioritises all name search hits, helping to achieve 80% precision and 90% recall levels in screening programmes of financial institutions.

The features of our Smart Screening solution include:

  • Advanced machine learning engine that powers  50+ name-matching techniques
  • Comprehensive matching enabled by the use of multiple attributes i.e; name, address, gender, date of birth, incorporation and more
  • Individual language models to improve accuracy across 18+ languages and 10 different scripts
  • Built-in transliteration engine for effective cross-lingual matching
  • Scalable to support massive watchlist data

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Final Thoughts

In order to mitigate the risks associated with PEPs, it is imperative for financial institutions to implement robust PEP screening processes within their compliance framework. By doing so, they not only shield themselves from potential involvement in illicit activities but also safeguard their reputation and actively contribute to the global fight against financial crime.

Tookitaki's innovative Smart Screening solution offers precise screening of customers and transactions against sanctions, PEPs, Adverse Media, and various watchlists in real-time across over 22 languages. With an impressive 90% accuracy rate, this cutting-edge technology utilizes 12 advanced name-matching techniques on 7 customer attributes, incorporating a multi-stage matching mechanism and cross-lingual matching capabilities. To explore more about the capabilities of Tookitaki's screening solution, schedule a consultation session by clicking the link below.

Frequently Asked Questions (FAQs)

What is a PEP according to FATF?

A PEP, according to FATF, is an individual who is or has been entrusted with a prominent public function, making them a higher risk for involvement in bribery and corruption.

What are some examples of PEPs?

Examples include politicians, high-ranking military officials, and senior executives in state-owned corporations.

Why is PEP screening important?

PEP screening is crucial for mitigating the risk of financial crimes like money laundering and corruption, which could result in severe penalties and reputational damage for the financial institution involved.

What are the types of PEPs defined by FATF?

FATF defines several types of PEPs including domestic, foreign, and those in international organisations.

What are some red flags to watch for in PEPs?

Red flags include sudden wealth accumulation, frequent use of offshore accounts, and involvement with shell companies.

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Blogs
18 Nov 2025
6 min
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Fraud Detection System: How Malaysia Can Stay One Step Ahead of Digital Crime

As Malaysia’s financial system goes digital, fraud detection systems are becoming the silent guardians of consumer trust.

Malaysia’s Expanding Fraud Challenge

Malaysia is experiencing a digital transformation unlike anything seen before. QR payments, e-wallets, instant transfers, digital banks, and cross-border digital commerce have rapidly become part of everyday life.

Innovation has brought convenience, but it has also enabled a wave of sophisticated financial fraud. Criminal networks are using faster payment channels, deep social engineering, and large mule networks to steal and move funds before victims or institutions can react.

The Royal Malaysia Police, Bank Negara Malaysia (BNM), and cybersecurity agencies have consistently flagged the rise in:

  • Online investment scams
  • E-wallet fraud
  • Account takeover attacks
  • Romance scams
  • Cross-border mule operations
  • Deepfake-enabled fraud
  • Social engineering targeting retirees and gig workers

Fraud not only causes financial loss but also erodes public trust in digital banking and fintech. As Malaysia accelerates toward a cashless society, the need for intelligent, proactive fraud detection has become a national priority.

This is where the evolution of the fraud detection system becomes central to protecting financial integrity.

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What Is a Fraud Detection System?

A fraud detection system is a technology platform that identifies, prevents, and responds to fraudulent financial activity. It analyses millions of transactions, user behaviours, and contextual signals to detect anomalies that indicate fraud.

Modern fraud detection systems protect institutions against:

  • Identity theft
  • Transaction fraud
  • Synthetic identities
  • First-party fraud
  • Friendly fraud
  • Card-not-present attacks
  • Social engineering scams
  • Mule account activity
  • False merchant onboarding

In Malaysia’s dynamic financial ecosystem, the fraud detection system acts as a real-time surveillance layer safeguarding both institutions and consumers.

How a Fraud Detection System Works

A powerful fraud detection system operates through a sequence of intelligent steps.

1. Data Collection

The system gathers data from multiple sources including payment platforms, device information, customer profiles, login behaviour, and transaction history.

2. Behavioural Analysis

Models recognise normal behavioural patterns and build a baseline for each user, device, or merchant.

3. Anomaly Detection

Any deviation from expected behaviour triggers deeper analysis. This includes unusual spending, unknown device access, rapid transactions, or location mismatches.

4. Risk Scoring

Each action or transaction receives a risk score based on probability of fraud.

5. Real-Time Decisioning

The system performs instant checks to accept, challenge, or block the activity.

6. Investigation and Feedback Loop

Alerts are routed to investigators who confirm whether a case is fraud. This feedback retrains machine learning models for higher accuracy.

Fraud detection systems are not static rule engines. They are continuously learning frameworks that adapt to new threats with every case reviewed.

Why Legacy Fraud Systems Fall Short

Despite increased digital adoption, many Malaysian financial institutions still use traditional fraud monitoring tools that struggle to keep pace with modern threats.

Here is where these systems fail:

  • Static rule sets cannot detect emerging patterns like deepfake impersonation or mule rings.
  • Slow investigation workflows allow fraudulent funds to leave the ecosystem before action can be taken.
  • Limited visibility across channels results in blind spots between digital banking, cards, and payment rails.
  • High false positives disrupt genuine customers and overwhelm analysts.
  • Siloed AML and fraud systems prevent institutions from seeing fraud proceeds that transition into money laundering.

Fraud today is dynamic, distributed, and data driven. Systems built more than a decade ago cannot protect a modern, hyperconnected financial environment.

The Rise of AI-Powered Fraud Detection Systems

Artificial intelligence has transformed fraud detection into a predictive science. AI-powered fraud systems bring a level of intelligence and speed that traditional systems cannot match.

1. Machine Learning for Pattern Recognition

Models learn from millions of past transactions to identify subtle fraud behaviour, even if it has never been seen before.

2. Behavioural Biometrics

AI analyses keystroke patterns, time on page, navigation flow, and device characteristics to distinguish legitimate users from attackers.

3. Real-Time Detection

AI systems analyse risk instantly, giving institutions crucial seconds to block or hold suspicious activity.

4. Lower False Positives

AI reduces unnecessary alerts by understanding context, not just rules.

5. Autonomous Detection and Triage

AI systems prioritise high-risk alerts and automate repetitive tasks, freeing investigators to focus on complex threats.

AI-powered systems do not simply detect fraud. They help institutions anticipate it.

Why Malaysia Needs Next-Generation Fraud Detection

Fraud in Malaysia is no longer isolated to simple scams. Criminal networks have become highly organised, using advanced technologies and exploiting digital loopholes.

Malaysia faces increasing risks from:

  • QR laundering through DuitNow
  • Instant pay-and-transfer fraud
  • Cross-border mule farming
  • Scams operated from foreign syndicate hubs
  • Cryptocurrency-linked laundering
  • Fake merchant setups
  • Fast layering to offshore accounts

These patterns require solutions that recognise behaviour, understand typologies, and react in real time. This is why modern fraud detection systems integrated with AI are becoming essential for Malaysian risk teams.

Tookitaki’s FinCense: Malaysia’s Most Advanced Fraud Detection System

At the forefront of AI-driven fraud prevention is Tookitaki’s FinCense, an end-to-end platform built to detect and prevent both fraud and money laundering. It is used by leading banks and fintechs across Asia-Pacific and is increasingly recognised as the trust layer to fight financial crime.

FinCense is built on four pillars that make it uniquely suited to Malaysia’s digital economy.

1. Agentic AI for Faster, Smarter Investigations

FinCense uses intelligent autonomous agents that perform tasks such as alert triage, pattern clustering, narrative generation, and risk explanation.

These agents work around the clock, giving compliance teams:

  • Faster case resolution
  • Higher accuracy
  • Better prioritisation
  • Clear decision support

This intelligent layer allows teams to handle high volumes of fraud alerts without burning out or missing critical risks.

2. Federated Intelligence Through the AFC Ecosystem

Fraud patterns often emerge in one market before appearing in another. FinCense connects to the Anti-Financial Crime (AFC) Ecosystem, a collaborative intelligence network of institutions across ASEAN.

Through privacy-preserving federated learning, models benefit from:

  • Regional typologies
  • New scam patterns
  • Real-time cross-border trends
  • Behavioural signatures of mule activity

This gives Malaysian institutions early visibility into fraud patterns seen in Singapore, the Philippines, Indonesia, and Thailand.

3. Explainable AI for Trust and Compliance

Regulators expect not just accuracy but clarity. FinCense generates explanations for every flagged event, detailing the data points and logic used in the decision.

This ensures:

  • Full transparency
  • Audit readiness
  • Confidence in automated decisions
  • Better regulatory communication

Explainability is essential for AI adoption, and FinCense is designed to meet these expectations.

4. Unified Fraud and AML Detection

Fraud often transitions into money laundering. FinCense unifies fraud detection and AML transaction monitoring into one decisioning platform. This allows teams to:

  • Connect fraud events to laundering flows
  • Detect mule activity linked to scams
  • Analyse both behavioural and transactional trends
  • Break criminal networks instead of individual incidents

This unified view creates a powerful defence that legacy siloed systems cannot match.

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Real-World Scenario: Detecting Cross-Border Investment Fraud

Consider a popular scam trend. Victims in Malaysia receive calls or WhatsApp messages promising high returns through offshore trading platforms. They deposit funds into mule accounts linked to foreign syndicates.

Here is how FinCense detects and disrupts this:

  1. The system identifies unusual inbound deposits from unrelated senders.
  2. Behavioural analysis detects rapid movement of funds between multiple local accounts.
  3. Federated intelligence matches this behaviour with similar typologies in Singapore and Hong Kong.
  4. Agentic AI generates a complete case narrative summarising:
    • Transaction velocity
    • Peer network connections
    • Device and login anomalies
    • Similar scenarios seen in the region
  5. The institution blocks the outbound transfer, freezes the account, and prevents losses.

This entire process occurs within minutes, a speed that traditional systems cannot match.

Benefits for Malaysian Financial Institutions

Deploying an AI-powered fraud detection system like FinCense has measurable impact.

  • Significant reduction in false positives
  • Faster alert resolution times
  • Better protection for vulnerable customers
  • Higher detection accuracy
  • Lower operational costs
  • Improved regulator trust
  • Better customer experience

Fraud prevention shifts from reactive defence to proactive risk management.

Key Features to Look for in a Modern Fraud Detection System

Financial institutions evaluating fraud systems should prioritise five core capabilities.

1. Intelligence and adaptability
Systems must evolve with new fraud trends and learn continuously.

2. Contextual and behavioural detection
Instead of relying solely on rules, solutions should use behavioural analytics to understand intent.

3. Real-time performance
Fraud moves in seconds. Systems must react instantly.

4. Explainability
Every alert should be transparent and justified for regulatory confidence.

5. Collaborative intelligence
Systems must learn from regional behaviour, not just local data.

FinCense checks all these boxes and provides additional advantages through unified fraud and AML detection.

The Future of Fraud Detection in Malaysia

Malaysia is on a clear path toward a safer digital financial ecosystem. The next phase of fraud detection will be shaped by several emerging trends:

  • Open banking data sharing enabling richer identity verification
  • Real-time AI models trained on regional intelligence
  • Deeper collaboration between banks, fintechs, and regulators
  • Human-AI partnerships integrating expertise and computational power
  • Unified financial crime platforms merging AML, fraud, and sanctions for complete visibility

Malaysia’s forward-looking regulatory environment positions the country as a leader in intelligent fraud prevention across ASEAN.

Conclusion

Fraud detection is no longer a standalone function. It is the heartbeat of trust in Malaysia’s digital financial future. As criminals innovate faster and exploit new technologies, institutions must adopt tools that can outthink, outpace, and outmanoeuvre sophisticated fraud networks.

Tookitaki’s FinCense stands as the leading fraud detection system built for Malaysia. It blends Agentic AI, federated intelligence, and explainable models to create real-time, transparent, and regionally relevant protection.

By moving from static rules to collaborative intelligence, Malaysia’s financial institutions can stay one step ahead of digital crime and build a safer future for every consumer.

Fraud Detection System: How Malaysia Can Stay One Step Ahead of Digital Crime
Blogs
18 Nov 2025
6 min
read

What Is APRA? A Simple Guide to Australia’s Banking Regulator

If you live, work, or bank in Australia, your financial safety is protected by an agency you may not know well: APRA.

Introduction

Most Australians interact with banks every day without ever thinking about the rules and systems that keep the financial sector stable. Behind the scenes, one regulator plays a critical role in ensuring banks are safe, resilient, and well managed: the Australian Prudential Regulation Authority, better known as APRA.

APRA oversees the health of the financial system, ensuring that banks, credit unions, insurers, and superannuation funds operate responsibly. While AUSTRAC focuses on preventing money laundering and financial crime, APRA focuses on stability, governance, risk, and long-term protection.

In a fast-changing financial world, understanding APRA is becoming increasingly important for businesses, compliance teams, fintechs, and even everyday consumers.

This simple guide explains what APRA does, who it regulates, and why its work matters.

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What Does APRA Stand For?

APRA stands for the Australian Prudential Regulation Authority.

The term “prudential regulation” refers to the rules and oversight that ensure financial institutions remain safe, stable, and financially sound. That means APRA’s job is to make sure financial organisations can weather risks, protect customer deposits, and operate sustainably.

Why Was APRA Created?

APRA was formed in 1998 following major reforms to Australia’s financial regulatory system. These reforms recognised the need for a dedicated agency to supervise the financial health of institutions.

APRA’s creation brought together prudential functions from:

  • The Reserve Bank of Australia
  • The Insurance and Superannuation Commission

The goal was simple: Protect customers and promote a stable financial system.

What Organisations Does APRA Regulate?

APRA supervises institutions that hold and manage Australians’ money. These include:

1. Banks and Authorised Deposit-Taking Institutions (ADIs)

  • Major banks
  • Regional and community-owned banks
  • Credit unions
  • Building societies
  • Digital banks

2. Insurance Companies

  • Life insurers
  • General insurers
  • Private health insurers

3. Superannuation Funds

  • Retail, industry, corporate, and public sector funds

4. Some Non-Bank Financial Institutions

Entities that hold financial risk but are not traditional banks.

In total, APRA oversees more than 600 financial institutions that collectively hold trillions of dollars in assets.

APRA’s Main Responsibilities

While APRA has a wide mandate, its work centres around four major responsibilities:

1. Promoting Financial Stability

APRA ensures banks and insurers are strong enough to survive economic shocks.
This includes monitoring capital levels, liquidity, and risk exposure.

If a bank faces difficulties, APRA steps in early to prevent instability from spreading through the system.

2. Ensuring Sound Risk Management

APRA expects all regulated institutions to have strong systems for managing:

  • Credit risk
  • Market risk
  • Operational risk
  • Technology risk
  • Outsourcing risk
  • Climate risk
  • Governance breaches

Banks must prove they can identify, measure, and control risks before they cause harm.

3. Supervising Governance and Accountability

APRA sets expectations for:

  • Board responsibilities
  • Senior management oversight
  • Internal audit frameworks
  • Remuneration linked to risk
  • Fit and proper evaluations

A strong governance culture is considered essential for long-term stability.

4. Protecting Depositors, Policyholders, and Superannuation Members

Perhaps APRA’s most important mandate is protecting the financial interests of Australians.

If a bank fails, APRA ensures deposits are protected up to the government guarantee amount.
If a super fund is mismanaged, APRA intervenes to safeguard members.

How APRA Supervises Banks

APRA uses a structured approach called supervision by risk.
This allows the regulator to focus resources on institutions that pose the greatest potential impact to the system.

APRA’s supervision toolkit includes:

1. Regular Reporting and Compliance Checks

Banks submit detailed financial, operational, and risk data on a scheduled basis.

2. On-Site Reviews

APRA examiners visit institutions to assess governance, risk culture, and operational controls.

3. Prudential Standards

Strict rules and guidelines covering:

  • Capital adequacy (APS 110)
  • Liquidity requirements (APS 210)
  • Remuneration (CPS 511)
  • Operational risk (CPS 230)
  • Outsourcing (CPS 231)
  • Business continuity (CPS 232)

These standards set the baseline for safe and responsible operations.

4. Stress Testing

APRA conducts industry-wide and institution-specific stress tests to simulate economic downturns or market shocks.

5. Enforcement Action

If a bank breaches expectations, APRA may impose:

  • Additional capital requirements
  • Remediation programs
  • Licence restrictions
  • Public warnings
  • Management changes

While APRA rarely uses penalties, it expects rapid action when weaknesses are identified.

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APRA vs AUSTRAC: What’s the Difference?

APRA and AUSTRAC are often mentioned together, but they enforce very different areas of compliance.

APRA

  • Focuses on financial safety and stability
  • Ensures institutions can survive economic or operational risk
  • Regulates governance, culture, capital, liquidity, and risk management

AUSTRAC

  • Focuses on preventing financial crime
  • Enforces AML/CTF laws
  • Oversees monitoring, reporting, and customer verification

Together, they form a complementary regulatory framework.

Why APRA Matters for Businesses and Consumers

APRA’s work affects everyone in Australia.
Here’s how:

For Consumers

  • Ensures deposits and savings are safe
  • Protects insurance claims
  • Holds super funds accountable
  • Prevents sudden collapses that disrupt the economy

For Businesses

  • Ensures stable banking and payment systems
  • Reduces the likelihood of credit shocks
  • Promotes trust in financial institutions

For Banks and Financial Institutions

  • Drives stronger risk management practices
  • Requires investments in data, technology, and training
  • Influences board-level decision-making
  • Sets expectations for responsible innovation

A strong APRA means a stable financial future for Australia.

APRA in Today’s Banking Landscape

Australia’s financial ecosystem is undergoing major change:

  • Digital onboarding
  • Instant payments
  • Artificial intelligence
  • Cloud migration
  • Open banking
  • Increasing cyber threats

APRA’s role has expanded to include careful oversight of technology, operational resilience, and data integrity.

Its most influential modern standards include:

CPS 230 — Operational Risk Management

One of the most significant reforms in the last decade.
CPS 230 modernises expectations around:

  • Critical operations
  • Third-party risk
  • Service resilience
  • Technology oversight
  • Incident management

CPS 234 — Information Security

Requires institutions to:

  • Maintain strong cyber defences
  • Protect sensitive information
  • Respond quickly to incidents
  • Test security controls regularly

CPS 511 — Remuneration

Aligns executive and employee incentives with non-financial outcomes such as ethics, conduct, and risk behaviour.

Why APRA Standards Matter for AML Teams

While APRA does not directly enforce AML/CTF laws, its standards strongly influence AML programs.

1. Strong Governance Expectations

AML decisions must align with risk appetite and board oversight.

2. Data Integrity Requirements

Accurate AML monitoring depends on clean, governed, high-quality data.

3. Operational Resilience

AML systems must remain stable even in the face of outages, disruptions, or cyber events.

4. Outsourcing Accountability

Banks must demonstrate they understand and control risks related to third-party AML technology providers.

5. Model and Algorithm Accountability

APRA expects explainability and oversight of any automated system used in compliance.

This is where Tookitaki’s emphasis on transparency, explainability, and federated learning aligns strongly with APRA principles.

Real-World Example: Regional Australia Bank

Regional Australia Bank, a community-owned financial institution, shows how APRA’s expectations translate into practical action.

By focusing on:

  • Transparent systems
  • Strong data practices
  • Responsible innovation
  • Clear governance

Regional Australia Bank demonstrates that even mid-sized institutions can meet APRA’s standards while modernising with AI.

This balance between technology and accountability reflects the future direction of Australian compliance.

The Future of APRA’s Role in Australian Banking

APRA is evolving alongside the financial system. Here are key areas where its influence is growing:

1. Technology and AI Governance

APRA is now more interested in how models operate, how decisions are made, and how risks are controlled.

2. Operational Resilience

Expectations around continuity, redundancy, and incident response will continue to rise.

3. Third-Party Risk Oversight

Banks must prove they manage outsourced technology with the same rigour as internal systems.

4. Cybersecurity and Data Governance

Data controls and security frameworks will become even more significant.

5. Climate and Sustainability Risk

APRA is exploring how climate events could affect financial stability.

These themes reinforce that prudential regulation is broadening, and institutions must be ready to adapt.

Conclusion

APRA plays a foundational role in shaping the strength, safety, and stability of Australia’s financial system. While consumers may rarely see its work, APRA’s influence touches every bank account, insurance claim, and superannuation balance.

For financial institutions, understanding APRA is not just a regulatory requirement. It is essential for sustainable operations and long-term trust.

As banks modernise their systems, adopt AI, and prepare for instant payments, APRA’s guidance offers a clear framework for responsible innovation.
Institutions like Regional Australia Bank show that meeting APRA expectations and modernising with advanced technology can go hand in hand.

Pro tip: In Australia, a strong AML and fraud strategy begins with a strong prudential foundation. APRA sets the rules that keep that foundation intact.

What Is APRA? A Simple Guide to Australia’s Banking Regulator
Blogs
17 Nov 2025
6 min
read

Connected Intelligence: How Modern AML System Software Is Redefining Compliance for a Real-Time World

The world’s fastest payments demand the world’s smartest defences — and that begins with a connected AML system built for intelligence, not just compliance.

Introduction

In the Philippines and across Southeast Asia, financial institutions are operating in a new reality. Digital wallets move money in seconds. Cross-border payments flow at massive scale. Fintechs onboard thousands of new users per day. Fraud and money laundering have become more coordinated, more invisible, and more intertwined with legitimate activity.

This transformation has put enormous pressure on compliance teams.
The legacy model — where screening, monitoring, and risk assessment sit in isolated tools — simply cannot keep pace with the velocity of today’s financial crime. Compliance can no longer rely on siloed systems or rules built for slower times.

What institutions need now is AML system software: an integrated platform that unifies every layer of financial crime prevention into one intelligent ecosystem. A system that sees the whole picture, not fragments of it. A system that learns, explains, collaborates, and adapts.

This is where next-generation AML platforms like Tookitaki’s FinCense are rewriting the rulebook.

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What Is AML System Software?

Unlike standalone AML tools that perform single tasks — such as screening or monitoring — AML system software brings together every major component of compliance into one cohesive platform.

At its core, it acts as the central nervous system of a financial institution’s defence strategy.

✔️ A modern AML system typically includes:

  • Customer and entity screening
  • Transaction monitoring
  • Customer risk scoring
  • Case management
  • Investigative workflows
  • Reporting and audit trails
  • AI-driven detection models
  • Integration with external intelligence sources

Each of these modules communicates with the others through a unified data layer.
The result: A system that understands context, connects patterns, and provides a consistent source of truth for compliance decisions.

✔️ Why this matters in a real-time banking environment

With instant payments now the norm in the Philippines, detection can no longer wait for batch processes. AML systems must operate with:

  • Low latency
  • High scalability
  • Continuous recalibration
  • Cross-channel visibility

Without a unified system, red flags go unnoticed, investigations take longer, and regulatory risk increases.

Why Legacy AML Systems Are Failing

Most legacy AML architectures — especially those used by older banks — were built 10 to 15 years ago. While reliable at the time, they cannot meet today’s demands.

1. Fragmented modules

Screening is handled in one tool. Monitoring is handled in another. Case management sits somewhere else.
These silos prevent the system from understanding the relationships between activities.

2. Excessive false positives

Static rules trigger alerts based on outdated thresholds, overwhelming analysts with noise and increasing operational costs.

3. Outdated analytical models

Legacy engines cannot ingest new data sources such as:

  • Mobile wallet activity
  • Crypto exchange behaviour
  • Cross-platform digital footprints

4. Manual investigations and reporting

Analysts often copy-paste data between systems, losing context and increasing risk of human error.

5. Poor explainability

Traditional models cannot justify decisions — a critical weakness in a world where regulators require full transparency.

6. Limited scalability

As transaction volumes surge (especially in fintechs and digital banks), old systems buckle under load.

The outcome? A compliance function that’s reactive, inefficient, and vulnerable.

Core Capabilities of Next-Gen AML System Software

Modern AML systems aren’t just upgraded tools — they are intelligent ecosystems designed for speed, accuracy, and interpretability.

1. Unified Intelligence Hub

The platform aggregates data from:

  • KYC
  • Transactions
  • Screening events
  • Customer behaviour
  • External watchlists
  • Third-party intelligence

This eliminates blind spots and enables end-to-end risk visibility.

2. AI-Driven Detection

Machine learning models adapt to emerging patterns — identifying:

  • Layering behaviours
  • Round-tripping
  • Smurfing
  • Synthetic identity patterns
  • Crypto-to-fiat movement
  • Mule account networks

Instead of relying solely on rules, the system learns from real behaviour.

3. Agentic AI Copilot

The introduction of Agentic AI has transformed AML investigations.
Unlike traditional AI, Agentic AI can reason, summarise, and proactively assist investigators.

Tookitaki’s FinMate is a prime example:

  • Investigators can ask questions in plain language
  • The system generates investigation summaries
  • It highlights relationships and risk factors
  • It surfaces anomalies and inconsistencies
  • It supports SAR/STR preparation

This marks a seismic leap in compliance productivity.

4. Federated Learning

A breakthrough innovation pioneered by Tookitaki.
Federated learning enables multiple institutions to strengthen models without sharing confidential data.

This means a bank in the Philippines can benefit from patterns observed in:

  • Malaysia
  • Singapore
  • Indonesia
  • Rest of the World

All while keeping customer data secure.

5. Explainable AI

Modern AML systems embed transparency at every step:

  • Why was an alert generated?
  • Which behaviours contributed to risk?
  • Which model features influenced the score?
  • How does this compare to peer behaviour?

Explainability builds regulator trust and eliminates black-box decision-making.

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Tookitaki FinCense — The Intelligent AML System

FinCense is Tookitaki’s end-to-end AML system software designed to unify monitoring, screening, scoring, and investigation into one adaptive platform.

Modular yet integrated architecture

FinCense brings together:

  • FRAML Platform
  • Smart Screening
  • Onboarding Risk Suite
  • Customer Risk Scoring

Every component feeds into the same intelligence backbone — ensuring contextual, consistent outcomes.

Designed for compliance teams, not just data teams

FinCense provides:

  • Intuitive dashboards
  • Natural-language insights
  • Behaviour-based analytics
  • Risk heatmaps
  • Investigator-friendly interfaces

Built on modern cloud-native architecture

With support for:

  • Kubernetes (auto-scaling)
  • High-volume stream processing
  • Real-time alerting
  • Flexible deployment (cloud, on-prem, hybrid)

FinCense supports both traditional banks and high-growth digital fintechs with minimal infrastructure strain.

Agentic AI and FinMate — The Heart of Modern Investigations

Traditional case management is slow, repetitive, and prone to human error.
FinMate — Tookitaki’s Agentic AI copilot — changes that.

FinMate helps investigators by:

  • Highlighting suspicious behaviour patterns
  • Analysing multi-account linkages
  • Drafting case summaries
  • Recommending disposition actions
  • Explaining model decisions
  • Answering natural-language queries
  • Surfacing hidden risks analysts may overlook

Example

An investigator can ask:

“Show all connected accounts with unusual transactions in the last 60 days.”

FinMate instantly:

  • Analyses graph relationships
  • Summarises behavioural anomalies
  • Highlights risk factors
  • Visualises linkages

This accelerates investigation speed, improves accuracy, and strengthens regulatory confidence.

Case in Focus: How a Philippine Bank Modernised Its AML System

A leading bank and digital wallet provider in the Philippines partnered with Tookitaki to replace its legacy FICO-based AML system with FinCense.

The transformation was dramatic.

The Results

  • >90% reduction in false positives
  • >95% alert accuracy
  • 10× faster scenario deployment
  • 75% reduction in alert volume
  • Screening over 40 million customers
  • Processing 1 billion+ transactions

What made the difference?

  • Integrated architecture reducing fragmentation
  • Adaptive AI models fine-tuning detection logic
  • FinMate accelerating investigation turnaround
  • Federated intelligence shaping detection scenarios
  • Strong model governance improving regulator trust

This deployment has since become a benchmark for large-scale AML transformation in the region.

The Role of the AFC Ecosystem: Shared Defence for a Shared Problem

Financial crime doesn’t operate within borders — and neither should detection.

The Anti-Financial Crime (AFC) Ecosystem, powered by Tookitaki, serves as a collaborative platform for sharing:

  • Red flags
  • Typologies
  • Scenarios
  • Trend analyses
  • Federated Insight Cards

Why this matters

  • Financial institutions gain early visibility into emerging risks.
  • Philippine banks benefit from scenarios first seen abroad.
  • Typology coverage remains updated without manual research.
  • Models adapt faster using federated learning signals.

The AFC Ecosystem turns AML from a siloed function into a collaborative advantage.

Why Integration Matters in Modern AML Systems

As fraud, compliance, cybersecurity, and risk converge, AML cannot operate in isolation.

Integrated systems enable:

  • Cross-channel behaviour detection
  • Unified customer risk profiles
  • Faster investigations
  • Consistent controls across business units
  • Lower operational overhead
  • Better alignment with enterprise governance

With Tookitaki’s cloud-native and Kubernetes-based architecture, FinCense allows institutions to scale while maintaining high performance and resilience.

The Future of AML System Software

The next wave of AML systems will be defined by:

1. Predictive intelligence

Systems that forecast crime before it occurs.

2. Real-time ecosystem collaboration

Shared typologies across regulators, banks, and fintechs.

3. Embedded explainability

Full transparency built directly into model logic.

4. Integrated AML–fraud ecosystems

Unified platforms covering fraud, money laundering, sanctions, and risk.

5. Agentic AI as an industry standard

AI copilots becoming central to investigations and reporting.

Tookitaki’s Trust Layer vision — combining intelligence, transparency, and collaboration — is aligned directly with this future.

Conclusion

The era of fragmented AML tools is ending.
The future belongs to institutions that embrace connected intelligence — unified systems that learn, explain, and collaborate.

Modern AML system software like Tookitaki’s FinCense is more than a compliance solution. It is the backbone of a resilient, fast, and trusted financial ecosystem.

It empowers banks and fintechs to:

  • Detect risk earlier
  • Investigate faster
  • Collaborate smarter
  • Satisfy regulators with confidence
  • And build trust with every transaction

The world is moving toward real-time finance — and the only way forward is with real-time, intelligent AML systems guiding the way.

Connected Intelligence: How Modern AML System Software Is Redefining Compliance for a Real-Time World