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What is Intercompany Accounting?

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Tookitaki
05 Jan 2021
8 min
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What is Intercompany Accounting? 

Intercompany accounting stands for the processing and accounting of inter-company/internal financial activities and events that cross legal entities, branches, or national borders. This may include (but is not limited to) the sales of products and services, fee sharing, royalties, cost allocations, and financing activities. Intercompany accounting is a broader segment than accounting – it extends into various functions, which include finance, tax, and treasury. According to the accounting firm, Grant Thornton LLP, intercompany transactions account for 30-40% of the global economy, which amounts to almost $40 trillion annually, and is further ranked as the ‘5th most common cause of corporate financial restatements’.

A 3-Step Approach to Intercompany Accounting

The transactions are important for many reasons, such as compliance with local tax codes, accurate reporting, regulations, good governance in general, and accounting rules. Financial institutions that need to improve their intercompany accounting can use this 3-step approach to intercompany accounting to improve their performance:

  1. Establish Standards, Policies, and Procedures: The foremost step to improve intercompany accounting is to establish a consistent process that can help identify, authorize, and clear the intercompany transactions. Although it would be easier to go with automation as the initial step, since the manual processes serve as an issue (they do not have consistent standards), chances are that attempting to automate the intercompany accounting will turn into a failure.

The policies and procedures are meant to include a list of what products and services are supposed to be provided between subsidiaries, along with transfer pricing for each, and the level of authorization needed for any transaction. Some other specifications may include a list of designated intercompany accounts, rules to identify and complete transactions, and a schedule that has specific deadlines to clear the balances every month.

  1. Automate the processes: According to a survey by Deloitte on ‘Intercompany Accounting & Process Management’, 54% of the companies still rely on manual intercompany processing, 47% only have ad hoc netting capabilities, while 30% report a significant out-of-balance position. After the policies and procedures are integrated and followed, the next step is to go for automation. The reason behind this is that keeping up with thousands of transactions by using spreadsheets is an inefficient method – one that only increases the risk of having errors. Further, in the case of companies that have subsidiaries in various countries, it becomes even more challenging to keep track. Alongside this, dealing with the currency exchange rates, the local tax codes, and the different rules for accounting can make it impossible to complete the process on time.

Yet, not all accounting solutions can manage intercompany transactions. There is software designed for emerging companies, which does not typically support multiple business entities. This can be a critical limitation, as it makes identifying and matching the transactions between various subsidiaries a manual process.

The minimum requirement from the software is that it should be able to tag intercompany purchase orders and sales orders when they are created, and link them automatically. This will help the accounting team, as they will no longer have to search amongst thousands of transaction entries to find the matching pairs. The revenue and expenses of intercompany transactions should be removed automatically from consolidated financial statements, specifically during the closing process. Another requirement from the software system is that it should also include intercompany netting functionality, which not only saves time and effort during the settlement process, but also saves money by reducing the number of invoices that need to be generated, plus payments that have to be processed every month.

  1. Centralize: It is mainly the corporate accounting staff’s job to manage intercompany accounting, which means that most things get done as part of the closing procedure. Yet, as the accounting team has other responsibilities, it isn’t ideal to wait until the end of the month, as it would extend the close cycle. On its own, the intercompany elimination can add days to the procedure if it’s not automated, which has an impact on the timings of the reports. The added pressure to close the books at the earliest may also increase the risk of errors.

So, centralizing the intercompany accounting serves as one of the best practices, either under a select person, or, in case there is a larger volume of people, a group of individuals under the supervision of the corporate controller. While dedicating resources to manage an activity that isn’t categorized as strategic could be a bit hard to explain, the efficiencies that companies gain, along with the improved supervision of this process, eventually pays its dividends. Managing the process centrally requires visibility into all intercompany transactions, which is difficult for companies that rely on multiple, differing accounting systems. So, in case one truly wants to control the process, it’s difficult to manage the business with different subsidiaries on a single accounting platform.

Types of Intercompany Transactions 

The three main types of intercompany transactions include: downstream, upstream, and lateral. Let’s understand how each of these intercompany transactions is recorded in the respective unit’s books. Also, their impact, and how to adjust the financials that are consolidated.

  1. Downstream Transaction: This type of transaction flows from the parent company, down to a subsidiary. With this transaction, the parent company records it with the applicable profit or loss. The transaction is made transparent and can be viewed by the parent company and its stakeholders, but not to the subsidiaries. For example, a downstream transaction would be the parent company selling an asset or inventory to a subsidiary.
  2. Upstream Transaction: This type of transaction is the reverse of downstream and flows from the subsidiary to the parent entity. For an upstream transaction, the subsidiary will record the transaction along with related profit or loss. An example would be when a subsidiary might transfer an executive to the parent company for a time period, charging the parent company by the hour for the executive’s services. For such a case, the majority and minority interest stakeholders can share the profit/loss, as they share ownership of the subsidiary.
  3. Lateral Transaction: This transaction occurs between two subsidiaries within the same parent organization. The subsidiary/subsidiaries record their lateral transaction along with profit and loss, which is similar to accounting for an upstream transaction. For example, when one subsidiary provides IT services to another, with a fee.

Intercompany Transactions Accounting Importance

Intercompany transactions are of great importance, as they can help to greatly improve the flow of finances and assets. Studies on transfer pricing help to ensure that the intercompany transfer pricing falls within reach of total pricing in order to avoid any unnecessary audits.

Such intercompany transactions accounting can help with keeping records for resolving tax disputes, mainly in the countries/jurisdictions where the markets are upcoming and new, and where there is little to no regulation governing the related parties’ transactions. The following are a few areas that are affected by the use of intercompany transactions accounting:

  • Loan participation
  • Sales and transfer of assets
  • Dividends
  • Insurance policies
  • Transactions that have member banks and affiliates
  • The management and service fees

 

What is an Intercompany Transaction? 

Intercompany transactions happen when the unit of a legal entity makes a transaction with another unit of the same entity. There are many international companies that take advantage of intercompany transfer pricing or other related party transactions. This is to influence IC-DISC, promote improved transaction taxes, and, effectively, enhance efficiency within the financial institution. The transactions are essential to maximizing the allocation of income and deduction. Here are a few examples of such transactions:

  • Between two departments
  • Between two subsidiaries
  • Between the parent company and subsidiary
  • Between two divisions

There are two basic categories of intercompany transactions: direct and indirect intercompany transactions.

  1. Direct Intercompany Transactions: These transactions may happen from intercompany transactions between two different units within the same company entity. They can aid in notes payable and receivable, and also interest expense and revenues.
  2. Indirect Intercompany Transactions: These transactions occur when the unit of an entity obtains the debt/assets issued to another company that is unrelated, with the help of another unit in the original parent company. Such transactions can help various economic factors, including the elimination of interest expense on the retired debt, create gain or loss for early debt retirement, or remove the investment in interest and bond revenue.

Intercompany Accounting Best Practices

In a survey conducted in 2016 by Deloitte, which included over 4,000 accounting professionals, nearly 80% experienced challenges related to intercompany accounting. The issue was around differing software systems within and across financial institute units and divisions, intercompany settlement processes, management of complex legal agreements, transfer pricing compliance, and FX exposure. With issues such as multiple stakeholders, large transaction volumes, complicated entity agreements, and increased regulatory scrutiny, it’s clear that intercompany accounting requires a structured, end-to-end process. Here are some of the intercompany accounting best practices:

Streamline and Optimize the Process with Technology

It is counted as intercompany accounting best practices to have technology-enabled coordination and orchestration streamline intercompany accounting across the entire financial institution. Automation removes the burden of having to identify counterparties across various ERP systems. The integrated workflows ensure that tasks are completed in the correct order and in the most efficient timeframes, with the removal of any additional managers, who would waste their time chasing the completion of this task.

With automation, users can collaborate more easily and resources are deployed more efficiently. The employees who were previously occupied by keeping the data moving are freed to perform tasks of higher-value. With this, the result is faster resolution, along with timely and accurate elimination of intercompany transactions, cost savings, reduced cycle times, and an accelerated closing.

Streamline the Intercompany Process with a Single View

The elimination of intercompany transactions as a collaborative process requires the counterparties to have full visibility of their respective balances, along with the differences between them, and the underlying transactions. In an intragroup trade, too, counterparties need shared access to a common view of their intercompany positions.

With KPI monitoring, there is an overview of intercompany accounting status, which highlights potential delays in real-time and in a visual manner. The dashboards and alerts allow for companies to manage their progress in real-time, giving accounting professionals an overview of tasks that haven’t yet started or finished. With this visibility, team leaders can review bottlenecks by task, individual, cost center, as well as entity.

Eliminate Intercompany Mismatches Early on in the Process

In order to minimize delays around the agreement of intercompany differences, one needs to start the process prior to usual in the reporting cycle. By viewing intercompany mismatches this early on in the reporting cycle, individual companies can take remedial action and correct their positions before the consolidation is attempted.

The direct integration with the ERP systems allows financial institutes to extract invoice details to help reconcile differences in a more detailed manner. After resolving the differences, adjustments can be posted directly into ERP systems through the process, without manually posting reconciling journal entries. This is why automation effectively turns the intercompany process into a preliminary close, well in advance of the normal reporting cycle, every month.

Manage Intercompany Risk

One can eliminate endless standalone spreadsheets, which are typically used by individuals to manage intercompany accounting, by using an automated system that gives companies one version of the truth, along with an audit trail of activities detailing when and by whom they were completed. The workflows give the company employees ownership of every activity and eliminate the interdependencies of these tasks.

Financial institutes are able to orchestrate and monitor intercompany accounting as a fundamental part of their internal controls. The role-based security, aligned with the company’s underlying applications, maintains the integrity of roles and access. At the same time, one can attach or store procedures and policy documents in task list items, which are made immediately available to the people performing the intercompany tasks.

Devise Bullet-Proof Centralized Governance and Policies

For effective intercompany accounting, standard global policies are required to govern critical areas, such as data or charts of accounts, transfer pricing, and allocation methods. Companies may establish a center of excellence with joint supervision from accounting, tax, and treasury. It serves as a resource to address global process standardization and issues related to intercompany accounting. Having a single company-wide process would mean that companies adhere to best practices and give all finance stakeholders immediate visibility of issues, tasks, and bottlenecks that need escalation or remediation. This can help financial institutes benchmark their performance, address underlying issues, and facilitate post-close reviews. Further, it would help them to subsequently streamline activities in order to encourage a continuous process improvement and accelerate the close.

 

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11 Nov 2025
6 min
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Compliance Transaction Monitoring in 2025: How to Catch Criminals Before the Regulator Calls

When it comes to financial crime, what you don't see can hurt you — badly.

Compliance transaction monitoring has become one of the most critical safeguards for banks, payment companies, and fintechs in Singapore. As fraud syndicates evolve faster than policy manuals and cross-border transfers accelerate risk, regulators like MAS expect institutions to know — and act on — what flows through their systems in real time.

This blog explores the rising importance of compliance transaction monitoring, what modern systems must offer, and how institutions in Singapore can transform it from a cost centre into a strategic weapon.

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What is Compliance Transaction Monitoring?

Compliance transaction monitoring refers to the real-time and post-event analysis of financial transactions to detect potentially suspicious or illegal activity. It helps institutions:

  • Flag unusual behaviour or rule violations
  • File timely Suspicious Transaction Reports (STRs)
  • Maintain audit trails and regulator readiness
  • Prevent regulatory penalties and reputational damage

Unlike simple fraud checks, compliance monitoring is focused on regulatory risk. It must detect typologies like:

  • Structuring and smurfing
  • Rapid pass-through activity
  • Transactions with sanctioned entities
  • Use of mule accounts or shell companies
  • Crypto-to-fiat layering across borders

Why It’s No Longer Optional

Singapore’s financial institutions operate in a tightly regulated, high-risk environment. Here’s why compliance monitoring has become essential:

1. Stricter MAS Expectations

MAS expects real-time monitoring for high-risk customers and instant STR submissions. Inaction or delay can lead to enforcement actions, as seen in recent cases involving lapses in transaction surveillance.

2. Rise of Scam Syndicates and Layering Tactics

Criminals now use multi-step, cross-border techniques — including local fintech wallets and QR-based payments — to mask their tracks. Static rules can't keep up.

3. Proliferation of Real-Time Payments (RTP)

Instant transfers mean institutions must detect and act within seconds. Delayed detection equals lost funds, poor customer experience, and missed regulatory thresholds.

4. More Complex Product Offerings

As financial institutions expand into crypto, embedded finance, and Buy Now Pay Later (BNPL), transaction monitoring must adapt across new product flows and risk scenarios.

Core Components of a Compliance Transaction Monitoring System

1. Real-Time Monitoring Engine

Must process transactions as they happen. Look for features like:

  • Risk scoring in milliseconds
  • AI-driven anomaly detection
  • Transaction blocking capabilities

2. Rules + Typology-Based Detection

Modern systems go beyond static thresholds. They offer:

  • Dynamic scenario libraries (e.g., layering through utility bill payments)
  • Community-contributed risk typologies (like those in the AFC Ecosystem)
  • Granular segmentation by product, region, and customer type

3. False Positive Suppression

High false positives exhaust compliance teams. Leading systems use:

  • Feedback learning loops
  • Entity link analysis
  • Explainable AI to justify why alerts are generated

4. Integrated Case Management

Efficient workflows matter. Features should include:

  • Auto-populated customer and transaction data
  • Investigation notes, tags, and collaboration features
  • Automated SAR/STR filing templates

5. Regulatory Alignment and Audit Trail

Your system should:

  • Map alerts to regulatory obligations (e.g., MAS Notice 626)
  • Maintain immutable logs for all decisions
  • Provide on-demand reporting and dashboards for regulators

How Banks in Singapore Are Innovating

AI Copilots for Investigations

Banks are using AI copilots to assist investigators by summarising alert history, surfacing key risk indicators, and even drafting STRs. This boosts productivity and improves quality.

Scenario Simulation Before Deployment

Top systems offer a sandbox to test new scenarios (like pig butchering scams or shell company layering) before applying them to live environments.

Federated Learning Across Institutions

Without sharing data, banks can now benefit from detection models trained on broader industry patterns. Tookitaki’s AFC Ecosystem powers this for FinCense users.

ChatGPT Image Nov 7, 2025, 12_55_33 PM

Common Mistakes Institutions Make

1. Treating Monitoring as a Checkbox Exercise

Just meeting compliance requirements is not enough. Regulators now expect proactive detection and contextual understanding.

2. Over-Reliance on Threshold-Based Alerts

Static rules like “flag any transfer above $10,000” miss sophisticated laundering patterns. They also trigger excess false positives.

3. No Feedback Loop

If investigators can’t teach the system which alerts were useful or not, the platform won’t improve. Feedback-driven systems are the future.

4. Ignoring End-User Experience

Blocking customer transfers without explanation, or frequent false alarms, can erode trust. Balance risk mitigation with customer experience.

Future Trends in Compliance Transaction Monitoring

1. Agentic AI Takes the Lead

More systems are deploying AI agents that don’t just analyse data — they act. Agents can triage alerts, trigger escalations, and explain decisions in plain language.

2. API-First Monitoring for Fintechs

To keep up with embedded finance, AML systems must offer flexible APIs to plug directly into payment platforms, neobanks, and lending stacks.

3. Risk-Based Alert Narration

Auto-generated narratives summarising why a transaction is risky — using customer behaviour, transaction pattern, and scenario match — are replacing manual reporting.

4. Synthetic Data for Model Training

To avoid data privacy issues, synthetic (fake but realistic) transaction datasets are being used to test and improve AML detection models.

5. Cross-Border Intelligence Sharing

As scams travel across borders, shared typology intelligence through ecosystems like Tookitaki’s AFC Network becomes critical.

Spotlight: Tookitaki’s FinCense Platform

Tookitaki’s FinCense offers an end-to-end compliance transaction monitoring solution built for fast-evolving Asian markets.

Key Features:

  • Community-sourced typologies via the AFC Ecosystem
  • FinMate AI Copilot for real-time investigation support
  • Pre-configured MAS-aligned rules
  • Federated Learning for smarter detection models
  • Cloud-native, API-first deployment for banks and fintechs

FinCense has helped leading institutions in Singapore achieve:

  • 3.5x faster case resolutions
  • 72% reduction in false positives
  • Over 99% STR submission accuracy

How to Select the Right Compliance Monitoring Partner

Ask potential vendors:

  1. How often do you update typologies?
  2. Can I simulate a new scenario without going live?
  3. How does your system handle Singapore-specific risks?
  4. Do investigators get explainable AI support?
  5. Is the platform modular and API-driven?

Conclusion: Compliance is the New Competitive Edge

In 2025, compliance transaction monitoring is no longer just about avoiding fines — it’s about maintaining trust, protecting customers, and staying ahead of criminal innovation.

Banks, fintechs, and payments firms that invest in AI-powered, scenario-driven monitoring systems will not only reduce compliance risk but also improve operational efficiency.

With tools like Tookitaki’s FinCense, institutions in Singapore can turn transaction monitoring into a strategic advantage — one that stops bad actors before the damage is done.

Compliance Transaction Monitoring in 2025: How to Catch Criminals Before the Regulator Calls
Blogs
10 Nov 2025
6 min
read

The Psychology of Compliance: Why People Drive AML Success

Behind every suspicious transaction alert is a human decision — and understanding the psychology behind those decisions may be the key to building stronger AML programs in Australian banks.

Introduction

Anti-Money Laundering (AML) compliance is often described in technical terms: systems, scenarios, thresholds, and reports. Yet the success of any AML framework still depends on something far less predictable — people.

Human psychology drives how analysts interpret risk, how leaders prioritise ethics, and how institutions respond to pressure. When compliance teams understand the why behind human behaviour, not just the what, they can build cultures that are not only compliant but resilient.

In the end, AML is not about machines catching crime — it’s about people making the right choices.

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The Human Factor in AML

Technology can process millions of transactions in seconds, but it takes human judgment to interpret the patterns.

From onboarding customers to filing Suspicious Matter Reports (SMRs), every stage of compliance involves human insight. Analysts connect dots that algorithms can’t see. Investigators ask questions that automation can’t predict.

Understanding the psychology of those people — what motivates them, what overwhelms them, and what influences their decisions — is essential for building truly effective compliance environments.

Why Psychology Belongs in Compliance

1. Bias and Decision-Making

Every investigator brings unconscious bias to their work. Prior experiences, assumptions, or even fatigue can affect how they assess alerts. Recognising these biases is the first step to reducing them.

2. Motivation and Purpose

Employees who see AML as a meaningful mission — protecting society from harm — perform more diligently than those who see it as paperwork. Purpose transforms compliance from a task into a responsibility.

3. Behaviour Under Pressure

High-stress environments, tight deadlines, and complex cases can lead to cognitive shortcuts. Understanding stress psychology helps leaders design better workflows that prevent mistakes.

4. Group Dynamics

How teams share information and challenge each other shapes detection quality. Healthy dissent produces better outcomes than hierarchical silence.

5. Moral Reasoning

Ethical reasoning determines how people act when rules are ambiguous. Building moral confidence helps employees make sound decisions even without explicit guidance.

Lessons from Behavioural Science

Behavioural economics and organisational psychology offer valuable lessons for compliance leaders:

  • The “Nudge” Effect: Small environmental cues — such as reminders of AML’s societal purpose — can significantly influence ethical behaviour.
  • The Bystander Effect: When responsibility is unclear, people assume someone else will act. Clear accountability counters inaction.
  • Cognitive Load Theory: Too many simultaneous alerts or complex systems reduce analytical accuracy. Simplifying interfaces improves judgment.
  • Feedback Loops: Immediate, constructive feedback strengthens learning and performance far more effectively than annual reviews.

Incorporating behavioural insights turns compliance programs from rigid processes into adaptive, human-centred systems.

The Cost of Ignoring the Human Mind

When psychology is ignored, AML programs suffer quietly:

  • Alert Fatigue: Overloaded analysts stop noticing anomalies.
  • Reactive Thinking: Teams prioritise speed over depth, missing subtle red flags.
  • Blame Culture: Fear of mistakes discourages escalation.
  • Rule Dependence: Staff follow checklists without critical thinking.
  • Disengagement: Compliance becomes mechanical rather than meaningful.

These symptoms indicate not system failure, but human exhaustion.

Building Psychological Resilience in Compliance Teams

  1. Promote a Growth Mindset: Mistakes become learning opportunities, not punishments.
  2. Encourage Reflective Practice: Analysts periodically review past cases to identify thinking patterns and biases.
  3. Provide Mental Health Support: Burnout is real in compliance; psychological safety improves vigilance.
  4. Simplify Decision Workflows: Reduce unnecessary steps that create cognitive friction.
  5. Recognise Ethical Courage: Celebrate employees who raise difficult questions or spot emerging risks.

Resilient teams think clearly under pressure — and that clarity is the foundation of AML success.

Leadership Psychology: The Compliance Multiplier

Leaders influence how their teams perceive compliance.

  • Visionary Framing: Leaders who connect AML work to a larger social purpose inspire intrinsic motivation.
  • Fairness and Transparency: Perceived fairness in workloads and recognition drives engagement.
  • Authenticity: When executives themselves model integrity, ethical norms cascade naturally.
  • Empowerment: Giving analysts autonomy over low-risk decisions increases accountability and confidence.

In short, leadership behaviour sets the emotional climate for compliance performance.

ChatGPT Image Nov 7, 2025, 11_36_58 AM

Culture Through a Psychological Lens

Culture is the collective expression of individual psychology. When people feel safe, valued, and informed, they act responsibly even without supervision.

Psychologically healthy AML cultures share three traits:

  1. Trust: Employees believe management supports their judgment.
  2. Purpose: Everyone understands why compliance matters.
  3. Voice: Individuals feel empowered to challenge and contribute ideas.

Without these traits, even the best AML technology operates in an emotional vacuum.

Case Example: Regional Australia Bank

Regional Australia Bank provides a compelling example of how cultural psychology drives compliance success.

Its community-owned structure fosters deep accountability — staff feel personally invested in protecting their members’ interests. By prioritising transparency and open dialogue, the bank has cultivated trust and ownership across teams.

The result is not just better compliance outcomes but a stronger sense of shared responsibility, proving that mindset can be as powerful as machine learning.

Technology That Supports Human Thinking

Technology can either reinforce or undermine good psychological habits.

Tookitaki’s FinCense and FinMate are designed to work with human cognition, not against it:

  • Explainable AI: Investigators see exactly why alerts are triggered, reducing confusion and second-guessing.
  • Agentic AI Copilot (FinMate): Provides contextual insights and suggestions, supporting decision confidence rather than replacing judgment.
  • Simplified Interfaces: Reduce cognitive load, allowing analysts to focus on interpretation rather than navigation.
  • Federated Learning: Encourages collaboration and shared learning across institutions — the psychological equivalent of collective intelligence.

When technology respects the human mind, compliance becomes faster, smarter, and more sustainable.

Applying Behavioural Insights to Training

Traditional AML training focuses on rules; behavioural AML training focuses on mindset.

  1. Storytelling: Real cases connect emotion with purpose, improving recall and empathy.
  2. Interactive Scenarios: Let analysts practice judgment in realistic simulations.
  3. Immediate Feedback: Reinforces correct reasoning and identifies bias early.
  4. Peer Learning: Discussion groups replace passive learning with shared discovery.
  5. Micro-Training: Short, frequent sessions sustain attention better than long lectures.

Training designed around psychology sticks — because it connects with how people actually think.

The Psychology of Ethical Decision-Making

Ethical decision-making in AML is often complex. Rules may not cover every situation, and context matters.

Institutions can strengthen ethical reasoning by:

  • Encouraging employees to consider stakeholder impact before outcomes.
  • Building “decision diaries” to capture thought processes behind key calls.
  • Reviewing ambiguous cases collectively to normalise discussion rather than punishment.

These practices replace fear with reflection, creating confidence under uncertainty.

Behavioural Metrics: Measuring the Mindset

You can’t manage what you don’t measure. Forward-thinking banks are beginning to track cultural and behavioural indicators alongside technical ones:

  • Employee perception of compliance purpose.
  • Escalation rates versus audit findings.
  • Participation in training discussions.
  • Quality of narrative in SMRs.
  • Survey scores on trust and transparency.

These human-centric metrics offer a real-time view of cultural health — and predict long-term compliance success.

When Psychology Meets Regulation

Regulators are paying closer attention to culture and human behaviour.

  • AUSTRAC now assesses whether compliance programs embed awareness and accountability at all levels.
  • APRA links leadership behaviour and decision-making to operational resilience under CPS 230.
  • ASIC has begun exploring behavioural supervision models, analysing how tone and conduct affect governance outcomes.

This convergence shows that compliance psychology is no longer an internal philosophy — it is a measurable regulatory expectation.

The Road Ahead: Designing Human-Centric Compliance

  1. Build for Clarity: Simplify interfaces, rules, and communications.
  2. Empower Decision-Makers: Trust analysts to act with autonomy within guardrails.
  3. Integrate Behavioural Insights: Include psychologists or behavioural scientists in compliance design.
  4. Foster Empathy: Remind teams that every transaction may represent a real person at risk.
  5. Reward Curiosity: Celebrate those who question data or assumptions.

Human-centric compliance is not soft — it is strategic.

The Future of AML Psychology

  1. Cognitive-Assisted AI: Systems that adapt to human thought patterns rather than force users to adapt to code.
  2. Behavioural Dashboards: Real-time tracking of morale, workload, and cognitive risk.
  3. Emotional AI Coaching: Copilots that detect stress or fatigue and suggest interventions.
  4. Interdisciplinary Teams: Psychologists, ethicists, and data scientists working together on AML models.
  5. Global Standardisation: Regulators incorporating behavioural metrics into compliance maturity assessments.

The future of AML will belong to institutions that understand people as deeply as they understand data.

Conclusion

Technology will continue to transform compliance, but psychology will define its success.

Understanding how humans think, decide, and act under pressure can help Australian banks design AML programs that are not only accurate but empathetic, resilient, and trustworthy.

Regional Australia Bank has already shown how culture and human connection create an edge in compliance.

With Tookitaki’s FinCense and FinMate, institutions can harness both human insight and AI precision — achieving a partnership between people and technology that turns compliance into confidence.

Pro tip: The future of AML success lies not in machines that think, but in people who care.

The Psychology of Compliance: Why People Drive AML Success
Blogs
07 Nov 2025
6 min
read

From Guesswork to Intelligence: How AML Risk Assessment Software is Transforming Compliance in the Philippines

n an age where financial crime evolves faster than regulation, risk assessment is no longer an annual report — it’s an intelligent, always-on capability.

Introduction

The financial landscape in the Philippines has never been more connected — or more complex.
With digital wallets, instant payments, and cross-border remittances dominating transactions, banks and fintechs are operating in an environment where risk changes by the hour.

Yet, many compliance frameworks are still built for a slower world — one where risk was static, predictable, and reviewed once a year.
In today’s reality, this approach no longer works.

That’s where AML risk assessment software comes in.
By combining artificial intelligence, contextual data, and explainable models, it enables financial institutions to assess, score, and mitigate risks in real time — creating a compliance function that’s agile, transparent, and trusted.

For the Philippines, where the Anti-Money Laundering Council (AMLC) has shifted its focus to risk-based supervision, this evolution is not optional. It’s essential.

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Understanding AML Risk Assessment

An AML risk assessment determines how vulnerable an institution is to money laundering or terrorism financing.
It examines every dimension — customers, products, services, delivery channels, geographies, and transaction behaviour — to assign measurable levels of risk.

Under the FATF’s 2012 Recommendations and AMLC’s Guidelines on Money Laundering/Terrorist Financing Risk Assessment, Philippine institutions are expected to:

  • Identify and prioritise risks across their portfolios.
  • Tailor mitigation controls based on those risks.
  • Continuously review and update their risk models.

But with millions of daily transactions and shifting customer patterns, performing these assessments manually is nearly impossible.

Traditional approaches — spreadsheets, static scoring rules, and periodic reviews — are not built for a real-time financial system.
They lack the intelligence to detect how risk evolves across interconnected data points, leaving institutions exposed to regulatory penalties and reputational harm.

Why Traditional Tools Fall Behind

Legacy systems often frame risk assessment as a checklist, not an intelligent process.
Here’s why that approach no longer works in 2025:

  1. Static Scoring Models
    Manual frameworks assign fixed scores to risk factors (e.g., “High Risk Country = +3”). These models rarely adapt as new data becomes available.
  2. Inconsistent Judgement
    Different analysts often interpret risk criteria differently, leading to inconsistent scoring across teams.
  3. Limited Data Visibility
    Legacy systems rely on siloed data — KYC profiles, transactions, and watchlists aren’t connected in real time.
  4. No Explainability
    When regulators ask why a customer was rated “high risk,” most legacy systems can’t provide a clear rationale.
  5. High Operational Burden
    Risk reports are manually compiled, delaying updates and diverting time from proactive controls.

The result is a compliance posture that’s reactive and opaque, rather than dynamic and evidence-based.

What AML Risk Assessment Software Does Differently

Modern AML risk assessment software replaces intuition with intelligence.
It connects data across the organisation and uses AI-driven models to evaluate risk with precision, consistency, and transparency.

1. Continuous Data Integration

Modern systems consolidate information from multiple sources — onboarding, screening, transaction monitoring, and external databases — to give a unified, current risk view.

2. Dynamic Risk Scoring

Instead of assigning fixed ratings, AI algorithms continuously adjust scores as new data appears — for example, changes in transaction velocity, counterparty geography, or product usage patterns.

3. Behavioural Analysis

Machine learning models identify deviations in customer behaviour, helping detect emerging threats before they trigger alerts.

4. Explainable Scoring

Each risk decision is traceable, showing the exact data and reasoning behind a score. This creates audit-ready transparency regulators expect under AMLC and FATF frameworks.

5. Continuous Feedback

Investigator input and real-world outcomes feed back into the system, improving model accuracy over time — an adaptive loop that legacy systems lack.

The end result? A living risk model that evolves alongside the financial ecosystem, not months after it changes.

Agentic AI: From Reactive Scoring to Intelligent Reasoning

Traditional AI models predict outcomes; Agentic AI understands them.
In AML risk assessment, this distinction matters enormously.

Agentic AI combines reasoning, planning, and interaction. It doesn’t just calculate risk; it contextualises it.

Imagine a compliance officer asking the system:

“Why has this customer’s risk rating increased since last month?”

With Tookitaki’s FinMate Copilot, the AI can respond in natural language:

“Their remittance volume to high-risk jurisdictions rose 35% and three linked accounts displayed similar behavioural shifts.”

This reasoning ability helps investigators understand the story behind the score, not just the number — a critical requirement for effective supervision and regulator confidence.

Agentic AI also improves fairness by removing bias through transparent logic. Every recommendation is backed by evidence, making compliance not only smarter but also more accountable.

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Tookitaki FinCense: Intelligent AML Risk Assessment in Action

FinCense, Tookitaki’s end-to-end AML compliance platform, is built to transform how institutions assess and manage risk.
At its core lies the Customer Risk Scoring and Model Governance Module, which redefines the risk assessment process from static evaluation to continuous intelligence.

Key Capabilities

  • Unified Risk Profiles: Combines transactional, demographic, and network data into a single customer risk score.
  • Real-Time Recalibration: Automatically updates scores when patterns deviate from expected behaviour.
  • Explainable AI Framework: Provides regulator-ready reasoning for every decision, including visual explanations and data lineage.
  • Federated Learning Engine: Ensures model improvement across institutions without sharing sensitive data.
  • Integration with AFC Ecosystem: Constantly refreshes risk logic using new typologies and red flags contributed by industry experts.

FinCense helps institutions move from compliance-driven assessments to intelligence-led risk management — where every decision is explainable, adaptive, and globally aligned.

Case in Focus: A Philippine Bank’s Risk Evolution Journey

A major Philippine bank and wallet provider undertook a major transformation by implementing Tookitaki’s FinCense platform, replacing its legacy solution.

The goal was clear: achieve consistent, explainable, and globally benchmarked risk management.

Within six months, the institution achieved:

  • >90% reduction in false positives
  • >95% alert accuracy
  • 10x faster scenario deployment
  • 75% reduction in alert volume
  • Enhanced customer segmentation and precise risk-tiering

What stood out wasn’t just the numbers — it was the newfound transparency.
When regulators requested risk model validation, the bank was able to trace every score back to data points and model logic — a capability made possible through FinCense’s explainable AI framework.

The bank’s compliance head summarised it best:

“For the first time, we don’t just know who’s risky — we know why.”

The AFC Ecosystem: Collective Intelligence in Risk Assessment

No institution can identify every risk alone.
That’s why Tookitaki built the Anti-Financial Crime (AFC) Ecosystem — a collaborative platform where AML experts, banks, and fintechs share red flags, typologies, and scenarios.

For Philippine institutions, this collective intelligence provides a competitive edge.

Key Advantages

  • Localised Typology Coverage: New scenarios on cross-border mule networks, crypto layering, and trade-based laundering are continuously added.
  • Federated Insight Cards: Summarise new threats in digestible, actionable form for immediate risk model updates.
  • Privacy-Preserving Collaboration: Data stays within each institution, but learnings are shared collectively through federated models.

By integrating this intelligence into FinCense’s risk assessment engine, institutions gain access to the collective vigilance of the region — without compromising confidentiality.

Why AML Risk Assessment Software Matters Now More Than Ever

The global compliance environment is shifting from “rules” to “risks.”
This transformation is being led by three converging forces:

  1. Regulatory Pressure: AMLC and BSP have explicitly mandated ongoing, risk-based monitoring and model explainability.
  2. Digital Velocity: With payments, remittances, and crypto volumes surging, risk exposure can shift in hours — not months.
  3. Trust as a Differentiator: Banks that can demonstrate credible, data-driven risk management are gaining stronger regulator and market trust.

AML risk assessment software bridges these challenges by enabling continuous visibility — ensuring institutions are not merely compliant, but confident.

Key Benefits of Implementing AML Risk Assessment Software

1. Holistic Risk Visibility

See all customer, transactional, and behavioural data in one dynamic risk view.

2. Consistency and Objectivity

Automated models standardise how risk is scored, removing human bias and inconsistency.

3. Real-Time Adaptation

Dynamic scoring adjusts automatically as behaviour changes, keeping risk insights current.

4. Regulatory Transparency

Explainable AI generates evidence-backed documentation for audits and regulatory reviews.

5. Operational Efficiency

Automated scoring and reporting reduce manual review time and free analysts to focus on strategic cases.

6. Collective Intelligence

Through the AFC Ecosystem, risk models stay updated with the latest typologies and emerging threats across the region.

The Future of AML Risk Assessment: Predictive, Transparent, Collaborative

Risk assessment is moving beyond hindsight.
With advanced data analytics and Agentic AI, the next generation of AML tools will predict risks before they materialise.

Emerging Trends

  • Predictive Modelling: Forecasting customer and transaction risk based on historical and peer data.
  • Hybrid AI Models: Combining machine learning with domain rules for greater interpretability.
  • Open Risk Intelligence Networks: Secure data collaboration between regulators, banks, and fintechs.
  • Embedded Explainability: Standardising interpretability in AI systems to satisfy global oversight.

As the Philippines accelerates digital transformation, financial institutions adopting these intelligent tools will not just meet compliance — they’ll lead it.

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

In today’s interconnected financial system, risk isn’t a snapshot — it’s a moving target.
And the institutions best equipped to manage it are those that combine technology, intelligence, and collaboration.

AML risk assessment software like Tookitaki’s FinCense gives banks and fintechs the clarity they need:

  • The ability to measure risk in real time.
  • The confidence to explain every decision.
  • The agility to adapt to tomorrow’s threats today.

For the Philippines, this represents more than regulatory compliance — it’s a step toward building a trusted, transparent, and resilient financial ecosystem.

The future of compliance isn’t about reacting to risk.
It’s about understanding it before it strikes.

From Guesswork to Intelligence: How AML Risk Assessment Software is Transforming Compliance in the Philippines