AFC Thoughts

Regulatory Risks in Modern AML and Fraud Prevention

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Tookitaki
21 Jan 2024
5 min
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In today's complex financial landscape, regulatory compliance stands as a linchpin in maintaining the integrity of Anti-Money Laundering (AML) and fraud prevention efforts. Financial institutions are grappling with a constantly evolving regulatory environment as authorities like the Bangko Sentral ng Pilipinas (BSP), Monetary Authority of Singapore (MAS), Bank Negara Malaysia (BNM), and other ASEAN bodies introduce a stream of new regulations and updates. This dynamic regulatory landscape poses significant challenges to the financial industry, necessitating an in-depth examination of recent developments to understand the shifting sands of compliance requirements and the critical role of collective intelligence in effectively managing these risks through the AFC Ecosystem.

Evolving Regulatory Landscape

The financial industry operates under the purview of several key regulatory authorities in the ASEAN region, including the Bangko Sentral ng Pilipinas (BSP), the Monetary Authority of Singapore (MAS), and the Bank Negara Malaysia (BNM), among others. These regulatory bodies play a pivotal role in shaping the compliance landscape for financial institutions, ensuring that they adhere to stringent AML and fraud prevention guidelines.

Recent times have witnessed a flurry of regulatory changes and updates from these authorities. From the implementation of new AML regulations to the revision of existing guidelines, financial institutions are constantly required to adapt to the evolving regulatory framework. Keeping pace with these changes is paramount for organizations striving to maintain their compliance standards.

The impact of these regulatory shifts reverberates throughout financial institutions. Institutions must allocate substantial resources to stay compliant, both in terms of financial investments and manpower. Failure to do so can result in hefty fines, reputational damage, and legal consequences. As such, understanding the nuances of recent regulatory developments and their implications for the industry is of utmost importance for financial institutions looking to navigate the evolving compliance landscape successfully.

Real-Life AML and Fraud Scenarios

The real-life AML scenarios that financial organizations have encountered range from intricate money laundering schemes facilitated by sophisticated networks to the inadvertent oversight of critical AML procedures. These cases serve as stark reminders of the vulnerabilities inherent in the financial system. Similarly, real fraud scenarios expose the adaptability and cunning of fraudsters who continually devise new methods to exploit vulnerabilities. Whether it's identity theft, payment fraud, or cyberattacks, these fraud cases highlight the need for a robust and proactive approach to compliance and fraud prevention. Learning from these real-life situations is essential for financial institutions to strengthen their defences and protect themselves and their clients from financial crimes.

The Need for Collective Intelligence

The Limitations of Isolated Approaches

In the face of an ever-evolving regulatory landscape in AML and fraud prevention, isolated compliance approaches have demonstrated their shortcomings. Financial institutions that operate in isolation may find it challenging to keep pace with the rapid changes in regulatory requirements across multiple jurisdictions. Compliance teams often grapple with interpreting and implementing complex regulations, which can lead to inconsistencies and potential oversights. Moreover, the dynamic and complex nature of modern financial crimes requires a more comprehensive perspective and collective expertise to identify emerging risks effectively.

Introduction to the AFC Ecosystem and Its Mission

This is where the AFC Ecosystem steps in as a transformative platform built on the principles of collective intelligence and collaboration. The AFC Ecosystem acknowledges that the key to mitigating regulatory risks lies in bringing together the collective expertise of AML and fraud prevention professionals, regulatory bodies, and industry experts. Its mission is clear: to create an environment where the global financial community collaborates, shares insights, and collectively responds to evolving regulatory challenges. By fostering collaboration and providing access to a repository of typologies and best practices, the AFC Ecosystem empowers financial institutions to navigate the complexities of regulatory compliance with confidence.

How Collective Intelligence Mitigates Regulatory Risks

Collective intelligence within the AFC Ecosystem allows for the pooling of knowledge and experience from a diverse range of stakeholders. This collaborative approach enables financial institutions to stay ahead of regulatory changes, adapt to new requirements, and proactively identify potential risks. By sharing insights into AML typologies, fraud patterns, and compliance strategies, members of the AFC Ecosystem strengthen their collective defence against regulatory pitfalls. 

This collective intelligence doesn't just benefit individual institutions; it elevates the industry as a whole, enhancing the financial sector's ability to maintain compliance and protect against financial crimes. In the following sections, we will delve deeper into the AFC Ecosystem's role in addressing specific regulatory challenges and how it empowers financial institutions to stay resilient in the face of evolving regulatory risks.

The AFC Ecosystem in Action

AFC Network: Connecting Regulatory Experts

The AFC Network is the lifeblood of the AFC Ecosystem, connecting regulatory experts, AML professionals, and financial institutions across the globe. This collaborative platform facilitates real-time communication and knowledge sharing among members, enabling them to discuss emerging regulatory trends, share experiences, and seek guidance from peers. Experts from different corners of the financial world can engage in meaningful dialogues, exchange insights, and collectively address the challenges posed by evolving AML and fraud regulations. Whether it's discussing the impact of recent regulatory changes, sharing best practices, or seeking advice on specific compliance issues, the AFC Network serves as a dynamic hub for regulatory experts to connect and collaborate.

The Typology Repository: A Valuable Resource for Compliance

At the heart of the AFC Ecosystem lies the Typology Repository, a comprehensive and continually evolving database of regulatory insights and typologies. This repository serves as a valuable resource for financial institutions looking to enhance their compliance efforts. It contains a vast collection of typologies, each designed to address specific money laundering and fraud risks associated with different industries, regions, or transaction types. Members of the AFC Ecosystem can access this repository to gain a deeper understanding of evolving typologies, regulatory expectations, and proven compliance strategies. 

The collective intelligence within the repository empowers compliance professionals to make informed decisions, tailor their risk assessments, and implement effective mitigation measures. In the next section, we will explore how the AFC Ecosystem strengthens the financial industry's ability to mitigate regulatory risks through collective intelligence and real-world applications.

AFC Ecosystem

Preparing for the Future of Compliance

In an ever-evolving regulatory landscape, anticipating future changes is crucial for financial institutions. They must keep a watchful eye on regulatory authorities' agendas, trends in global financial regulations, and emerging technologies that could impact compliance requirements. By staying proactive and forward-thinking, institutions can prepare for upcoming regulatory shifts and ensure they are well-positioned to adapt to new compliance challenges.

To navigate the dynamic landscape of regulatory risks, financial institutions should develop robust compliance strategies. This involves continuous monitoring, updating policies and procedures, and investing in cutting-edge compliance tools. It also means fostering a culture of compliance within the organization and providing ongoing training to employees. Staying compliant requires a combination of vigilance, adaptability, and a commitment to best practices.

As a powerful ally in the fight against regulatory risks, the AFC Ecosystem offers financial institutions a unique advantage. By embracing the AFC Ecosystem, institutions can tap into collective intelligence, access a wealth of typological data, and connect with regulatory experts. This collaborative approach empowers them to strengthen their compliance operations, proactively address regulatory changes, and build resilience against future challenges. In the concluding section of this blog, we will emphasize the transformative potential of the AFC Ecosystem and its role in shaping the future of compliance.

The Crucial Role of Collective Intelligence in Mitigating Risks

In conclusion, the modern regulatory landscape in AML and fraud prevention is constantly evolving, driven by regulatory authorities like BSP, MAS, BNM, and others in the ASEAN region. Recent developments have brought about a heightened focus on compliance, making it imperative for financial institutions to adapt. Real-life AML and fraud scenarios illustrate the challenges faced by these institutions and the significant impact of regulatory actions. To effectively manage these evolving risks, there is an urgent need for collective intelligence. 

The AFC Ecosystem emerges as the solution, connecting regulatory experts, providing a repository of valuable typological data, and fostering collaboration. As we look to the future of compliance, anticipating regulatory changes, developing dynamic strategies, and embracing the AFC Ecosystem will be instrumental in staying resilient and prepared for what lies ahead. We invite financial institutions and experts to join the AFC Ecosystem's mission, where collective intelligence is the shield against regulatory uncertainties.

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Our Thought Leadership Guides

AFC Thoughts
18 Jul 2024
4 min
read

Typology Tales July 2024: Account Takeover Surveillance

We are pleased to share the latest edition of "Typology Tales" for July 2024. This edition highlights the new typologies that our Anti-Financial Crime (AFC) community has carefully analysed and selected. Our community's collective efforts are crucial in staying ahead of evolving financial crime threats, and we are grateful for your continued participation and contributions.

AFC Community’s Role

Each month, our dedicated AFC community comes together to analyze and evaluate newly created typologies, selecting those that can significantly enhance the ecosystem's ability to prevent and combat financial crime. The typologies chosen for publication are those that offer the most promise in terms of effectiveness and applicability across various scenarios.

Key Highlights from July 2024 

These typologies have been meticulously curated to ensure they provide robust and actionable insights, ultimately helping to safeguard the financial ecosystem.

Theme of the Month: Account Takeover Fraud (ATO)

Theme of the month

Account takeover fraud (ATO) is a type of cybercrime where unauthorised people access a user's account and use it for harmful purposes. This dangerous activity has increased significantly in recent times, posing a growing threat to both individuals and organisations. 

In this edition...

In this edition of Typology Tales, we delve into two typologies that compliance professionals can incorporate into their transaction fraud monitoring systems to proactively prevent account takeover in real time.

Typology 1: Surge in Multi-Party Transactions in Sizeable Values

Typology-multiple counterparty

A pattern of multiple parties making high-value transactions with one entity in a short period of  time suggests possible account takeover fraud. This requires a strategic review of transaction behaviours.

How It Works

  • The typology monitors transactions involving a single customer who receives or transfers funds with multiple parties within a short time span.
  • To identify potential account takeover risks, the typology groups transactions by the unique identifiers of senders and receivers within a specified time frame. By tracking these identifiers over a defined period, it can determine how many different parties have transacted with a particular entity.

  • Simultaneously, the typology aggregates the transaction amounts linked to unique senders and receivers.

  • It flags any entity that engages in transactions with a large number of different parties and exceeds a cumulative transaction threshold. This signals potential account takeover risks due to unauthorised access and high-value transactions.

Typology 2: Monitoring High-Value Transactions Across Multiple Payment Modes

15 - 2024 July Edition TT Typology tales-1-1-1-1

Financial institutions may implement advanced monitoring to detect high-value transactions between senders and receivers through various modes, aiming to uncover potential account takeover fraud.

How It Works

  • To effectively oversee the flow of funds, the typology tracks and aggregates transaction amounts based on the mode of transfer.
  • Transaction amounts, including those made through cash or alternative payments, are further aggregated by the unique identifiers of the sender and receiver over a specific period.
  • Entities showing high-value transactions across multiple payment modes over specified time frames are potentially flagged as suspicious. This increased activity may indicate that an account has been compromised and is being used to funnel funds illegally.

From the Media: Account Takeover Attacks Overtake Ransomware as Leading Security Concern

Research by cybersecurity firm Abnormal Security highlights that account takeover (ATO) attacks have become a top concern for security leaders. The 2024 State of Cloud Account Takeover Attacks report reveals that 83% of organisations experienced at least one ATO incident in the past year. 

Over 75% of security leaders rank ATOs among the top four global cyber threats, with nearly 50% facing more than five incidents annually and around 20% encountering over ten incidents. ATOs are now considered more significant than other threats such as spear phishing and ransomware.

Read More

Unite in the Fight Against Financial Crime

Financial crime is a pervasive issue that requires a collective, centralised approach to intelligence gathering. That's why we have created the Anti-Financial Crime (AFC) Ecosystem, a network of experts who work together to share knowledge and develop strategies for combating financial crime.

If you are an AFC expert, we invite you to join our efforts and help us grow the AFC Ecosystem. And if you know any other AFC experts, please refer them to us so we can continue to expand and strengthen our network. Together, we can make a real difference in the fight against financial crime.

Typology Tales July 2024: Account Takeover Surveillance
AFC Thoughts
01 Jul 2024
3 min
read

Account Takeover Fraud: Monitoring Entities Incorporated Long Back

In the evolving landscape of financial crime, financial institutions need to intensify their scrutiny of transactions from entities with a long history of incorporation but sporadic or recent activity. This increased vigilance aims to detect and thwart potential account takeover fraud within savings accounts, ensuring the safety and integrity of financial systems.

Given below is a typology from Tookitaki's AFC Ecosystem. It details how to ensure your monitoring system triggers alerts transactions from entities with a long history of incorporation

Understanding the Typology

Setting Up Entity Historical Profiles

Financial institutions employ a function known as the "Incorporation Date of the Entity" to track and record the incorporation dates and transaction activities of entities. This function helps identify entities that have been established long ago but have shown recent or sudden transaction activities, which could be indicative of fraud.

Function Configuration and Data Aggregation

  • Aggregate Fields: The system aggregates data on 'sender incorporation date' and 'receiver incorporation date.'
  • Aggregate Function: Using the collect_set function, the system compiles a unique set of incorporation dates for each sender and receiver, providing a comprehensive historical perspective of each entity's transaction timeline.
  • Group By: Transactions are grouped by unique identifiers like 'sender_hashcode' and 'receiver_hashcode,' linking each entity’s transaction history to specific account profiles.

Monitoring and Anomaly Detection

The system continuously monitors the transaction activities of these entities, comparing current transactions against historical data. Entities that have shown no or minimal transaction activities for a significant period since their incorporation are closely watched. A sudden spike in transactions, especially those of significant volume or frequency, triggers an alert. This scrutiny is particularly heightened if the entity's previous activity has been minimal or non-existent for years.

Group 16190-1

Flagging and Review Process

Transactions involving long-dormant entities resuming activity are flagged as high-risk. These flagged transactions undergo a detailed review to ascertain the legitimacy of the activity and to rule out any potential account takeover or other fraudulent intentions.

Investigative Measures

For flagged transactions, financial institutions conduct thorough investigations involving:

  • Background Checks: Verifying the entity's background.
  • Transaction Legitimacy: Confirming the legitimacy of the transaction.
  • Entity Ownership: Ensuring the entity's ownership and operational status.

Preventative Actions and Customer Interaction

If fraudulent activity is confirmed, financial institutions take immediate steps to:

  • Block further transactions.
  • Secure the affected accounts.
  • Possibly reverse fraudulent transactions.
  • Contact entity representatives for further clarification and to ensure all parties are informed of the situation.

Compliance and Reporting Obligations

All suspicious activities are documented and reported in compliance with regulatory requirements. This ensures that the institution remains compliant with anti-fraud regulations and aids in broader efforts to combat financial crime.

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Enhancement of Monitoring Systems

Based on findings and trends observed from monitoring these entities, financial institutions continually refine their detection algorithms and update their monitoring systems to better identify and prevent potential fraud.

By closely monitoring the activities of entities incorporated long ago but recently active, banks can effectively spot unusual patterns that may indicate fraudulent activities, such as account takeovers. This proactive approach helps safeguard customer assets and maintain the integrity of the financial system.

Final Thoughts

Financial institutions must remain vigilant and proactive in monitoring and analyzing transaction activities, especially those involving historically dormant entities. This typology, sourced from Tookitaki's AFC Ecosystem, highlights the importance of advanced monitoring techniques in detecting potential fraud.

We encourage anti-financial crime professionals to join the AFC Ecosystem to access unique typologies and leverage community-driven insights for enhanced fraud detection and prevention. Together, we can strengthen our defenses against financial crime and protect the integrity of our financial systems.

Account Takeover Fraud: Monitoring Entities Incorporated Long Back
AFC Thoughts
22 May 2024
3 min
read

The Globalization of Fraud: The Rise of Transnational Scams

In an increasingly interconnected world, the borders that once confined criminal activities are rapidly dissolving, aided by the rise of digitalisation and the pervasive reach of online platforms. The stark reality we face today is a landscape where fraudsters exploit digital payment systems to target individuals across the globe, particularly in the Asia-Pacific region. Organised fraud syndicates are not just local threats; they operate on an international scale, executing sophisticated scams that often outpace current preventative measures.

Case Study: A Transnational Crackdown on Job Scams

On 20 March 2024, a significant breakthrough came when the Commercial Affairs Department (CAD) of the Singapore Police Force and the Bukit Aman Commercial Crime Investigation Department of the Royal Malaysia Police joined forces in Kuala Lumpur. This joint operation was the culmination of extensive cross-border investigative efforts aimed at dismantling a formidable job scam syndicate.

Between October 2023 and January 2024, this syndicate deceived over 3,000 individuals, accumulating illicit gains of approximately $45.7 million. These scams primarily targeted Singaporeans, promising lucrative job opportunities that required victims to make upfront payments or divulge sensitive information under the guise of securing employment. The rapid escalation of these scams prompted an intensive collaborative investigation, which eventually led to the arrest of five Malaysians involved in laundering the proceeds from these fraudulent activities.

This operation not only highlights the severity and reach of transnational scams but also underscores the urgent need for global cooperation and shared strategies to combat these crimes effectively.

Job Scam

The Imperative of a Collaborative Approach

As we witness a surge in transnational fraud, the isolation of financial institutions in their silos makes them particularly vulnerable. The complexity and rapid adaptation of fraud strategies require that defences be equally dynamic and interconnected.

Collective Intelligence and Shared Responsibility

To counteract the evolving menace of cross-border fraud effectively, a collaborative approach is indispensable. The AFC Ecosystem initiative represents a commitment to fostering industry-wide cooperation and information sharing. Through this collective intelligence, we aim to establish a robust defence mechanism that not only identifies but also anticipates fraudulent activities, ensuring safe and secure societies. This shared responsibility is vital in creating an impenetrable barrier against the sophisticated mechanisms of modern financial criminals.

Considering the Typology of the AFC Ecosystem

Drawing from the AFC Ecosystem's insights, let's delve into the typology of transnational job scams. This framework is instrumental in understanding how these frauds operate and what measures can be employed to thwart their attempts.

Detailed Analysis of the Typology

Transnational job scams represent a highly organized and rapidly proliferating threat that exploits the aspirations of job seekers worldwide. These scams are not just about deceit regarding employment opportunities but involve intricate financial manipulations that siphon funds across international borders.

Operational Mechanics

  • Initial Recruitment: The scam begins with contact through social media or other digital platforms, where victims are lured with high-return, low-effort job offers.
  • Deceptive Promises: The roles are advertised as lucrative yet simple enough to attract a wide demographic, from students to the unemployed.
  • Financial Prerequisites: Victims are persuaded to make upfront payments or provide personal information as a part of the onboarding process.
  • Expeditious Expansion: To maximize profits before any potential crackdown, these operations quickly scale and replicate across various regions.

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Granular Red Flags and Risk Indicators

To effectively monitor and prevent these scams, it is crucial to recognise the following detailed risk indicators:

  • Value: Transactions often involve small amounts that are usually perceived as low-risk by victims, making them less likely to raise immediate alarms.
  • Volume: A high frequency of transactions complicates tracking and analysis, as the sheer number of transactions can overwhelm standard monitoring systems.
  • Velocity: The rapid succession of payments, coupled with potential chargebacks or cancellations, creates a chaotic financial trail that is difficult to follow.
  • Channels: Scammers predominantly use digital payment platforms, online banking, and occasionally cryptocurrencies to maintain anonymity and complicate tracing.
  • Anonymity: There is often a mismatch between beneficiary details and the purported employer, signalling a red flag for transactions.
  • Recurrence: Victims are frequently solicited for multiple payments under various pretexts, each justified as necessary for job commencement or continuation.
  • High-risk Geos: Payments are directed to accounts in high-risk jurisdictions or to those that are otherwise unrelated or suspicious, lacking any logical connection to the job or employer.
  • Geographical Inconsistencies: The involved countries often have no direct connection to the alleged job or employer, exploiting the complexities of international law and jurisdictional boundaries.

Harnessing Collective Efforts for Enhanced Security

The fight against transnational fraud is not a battle that can be won in isolation. It requires the concerted efforts of financial institutions, regulatory bodies, law enforcement, and the public. By adopting the typology provided by the AFC Ecosystem and vigilantly monitoring the detailed risk indicators, we can forge a path towards a more secure and resilient financial environment. This collective approach is our best defense against the sophisticated and ever-evolving landscape of global fraud.

The Globalization of Fraud: The Rise of Transnational Scams