Beyond the acronyms: How AML/CTF is evolving

Highlights

• AML/CTF is a whole-of-business issue, not just a regulatory checkbox.
• Financial crime is evolving and businesses must adapt to these changes.
• BNDRY helps businesses orchestrate their AML/CTF programs in real-time.

It has been said that financial crime is faceless, an elusive monster not easily captured, but that’s far from the reality. There are countless faces behind the crimes that are financed through Money Laundering and Terrorism Financing (ML/TF), the issue lies in detecting them because perpetrators of financial crime are finding increasingly intelligent ways to hide their illicit funds.

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The Many Faces of Financial Crime

Financial crime certainly isn’t a new concept and has existed for centuries with the first known case being one of insurance fraud recorded in 300 BC, when two Greek sea merchants (mistakenly) thought they could get away with pocketing loaned money by sinking their own cargo ship. The scallywags. FinCrime has since developed to include identity fraud, embezzlement, bribery, and money and document counterfeiting to name a few, with new methods developing all the time. In this vein, the financial crime landscape is unrecognisable compared to what it looked like in 2008, it’s a new beast that’s bleeding the global economy and threatening businesses and individuals at a prolific rate. Meanwhile, the status quo around Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) needs a serious overhaul to ensure compliance and regulation procedures effectively combat these crimes.

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Since the rise of the internet, money laundering has become far more sophisticated and evolved to accommodate numerous, almost undetectable crimes, including but not limited to credit card fraud and terrorism financing. Even though traditional crimes may have been simpler to track, it’s never been an easy task and chasing paper trails and hidden capital was, and can still be, a laborious and time-heavy task – a compelling reason why businesses choose to avoid it all together, but that’s a choice they can no longer make. With the evolving nature of financial crime, regulators have been forced to rethink how to most effectively combat these crimes; however, the challenge has been to bring companies into the fold to help.

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Because modern ML/TF has seen a rapid development in how criminals work and how they acquire their funds, businesses also need to adapt to safeguard themselves against these threats. Perpetrators of financial crime are intelligent, they have the capital, tools and personnel to find where vulnerabilities lie in both businesses and consumers, which is why AUSTRAC and many regulatory organisations across the world have had to adapt to fight the threat ML/TF poses to the global community. So far AUSTRAC have made good on their word with many Australian businesses copping hefty fines for non-compliance. Australian casinos have been hit particularly hard with Crown Casinos in both Melbourne and Perth, The Star Entities in Queensland and most recently SkyCity Casino in Adelaide, all receiving multi-million dollar penalties from AUSTRAC for non-compliance. In his speech at the Clubs NSW 2025 Conference AUSTRAC CEO, Brendan Thomas, pointed out “gambling businesses – including pubs and clubs – have taken a ‘tick and flick’ approach” to compliance which has resulted in major fines handed out to venues who haven’t met their AML/CTF obligations. This is one of the reasons why the Australian government has taken measures to align with regulatory compliance set by the Financial Action Task Force (FATF).

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FATF is the global money laundering and terrorist financing watchdog that aims to prevent money laundering and terrorism financing. Illicit funds amassed through financial crime support some of the worst crimes imaginable, including financing weapons of mass destruction and human trafficking, which is why the FATF has taken serious measures to ensure the global community is protected from these crimes. Articles like this one by The Guardian reveal how Australia has been lagging behind in progress toward combating money laundering and terrorist financing, pushing the government to make stronger commitments to improving AML/CTF laws. Brendan Thomas has outlined the regulatory expectations that will follow the new reforms rolling out in 2026, which affect both the current regulated entities and the Tranche 2 services. He has stated these expectations are informed by:

• The financial crime risks businesses need to manage.
• The time available to prepare for the AML/CTF reforms.

Ensuring risk and compliance procedures and related tools are capable of handling and detecting potential risk is key to helping businesses stay ahead of their regulatory obligations, and in keeping industries and citizens safe from criminal harm.

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Financial Crime is Smart, Businesses Need to be Smarter

Global scam economies are flourishing, driven by the digital economy and the increasing intelligence of criminal enterprises, with some perpetrators even setting up illegal labour camps. These camps consist of abducted migrants, where victims are held against their will and forced to perform online scams. One such syndicate involving Prince Holding Group chair, Chen Zhi, has been seized by the US government and labelled "one of the largest investment fraud operations in history". It’s believed Chen Zhi had been using forced labour to deceive hopeful investors in on-going "pig-butchering" scams. Meanwhile, in Australia it’s a popular practice by scammers to take over bank accounts from legitimate users for a price and use these accounts to launder money.

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As mentioned, AML/CTF obligations have historically been an overly manual and often overlooked aspect of business functions, where customer information is scattered and can fall through compliance cracks. This has made it difficult, and sometimes impossible, to locate required information. Businesses, especially those governed by regulatory laws, need to recognise this and adapt their compliance processes to the changing AML/CTF landscape. Developing the right policies and procedures including staff training, running ongoing monitoring and audits and managing a solid compliance program is crucial to meeting regulatory obligations and mitigating risk and detecting fraud.

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Thankfully, the tools available to detect risk and discover the source of financial crimes have become far more sophisticated, a necessary development to meet the sophistication used by FinCrime syndicates, with new technologies providing regulators and government bodies the intelligence to counter the methods used by modern criminals.

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Before considering which tools to implement and engage with, businesses must first rethink how they handle risk and compliance. Some considerations include:

• Where threats are most likely to appear.
• Which systems are at risk.
• Who is responsible for recognising potential risk (hint – everyone).
• Whether clients and vendors are properly screened.
• Geographical location of transactions.

These compliance tasks have too often filed under the “will get to later” umbrella attached to an obligatory checklist, but as AUSTRAC has stated, the new reforms are less about tick-box compliance and more focussed on recognising risk that’s tailored to your business. AUSTRAC’s 2025–26 priorities mark a major shift toward proactive enforcement and data-led detection and if businesses shift their focus from task-oriented obligations to protecting their assets, their philosophy behind managing AML/CTF will change and compliance and regulation will become an integral part of business functions not only by law, but by necessity.

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How BNDRY Tech Combats Financial Crime

AML/CTF, fraud and cybersecurity are all connected so your compliance systems and regulation technology should be closely connected too. “Cybercrime leads to or enables financial crime by exposing the data of individuals or organisations, which in turn leads to fraud or scam activities,” says Ben Jackson, BNDRY’s Chief Information Officer. This is why businesses need to adopt intelligent compliance technologies that work with existing tools to minimise disruption to business as usual. Combating financial crime should safeguard against potential threats, not slow a business down.

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BNDRY was built by people who have fought fraud, scams and cyber criminals, and who know what's required to implement sound fraud detection and combat financial crime. The platform is at the forefront of smarter financial crime compliance and works with existing business tools to ensure a smooth transition to a more enhanced compliance environment that works in real-time.

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The platform features:

• Bring structure and speed to how regulated businesses fight financial crime.
• Are designed to help regulated businesses orchestrate their AML/CTF programs in real-time.
• Enable smarter automated decision-making and proactive monitoring, allowing teams to manage by exception and focus on the greatest risks.

Think of BNDRY as your personal scout, performing reconnaissance tasks and only bringing you into battle when absolutely necessary. Because that’s what combatting financial crime is, a fight against bad actors who exist to exploit your business.

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From decision makers to risk and compliance officers, if you want help building a strong compliance ecosystem to meet your regulatory needs...