Typological Risk Traceability
Mapping Typological Risk to Rules: A Foundational Transaction Monitoring Requirement
Transaction Monitoring (TM) is essential for detecting financial crime, yet many organisations struggle to connect typological risk intelligence with the rules and scenarios driving detection. This article explains why contextualising risk signals matters for operational efficiency and compliance, clarifies the difference between rules and scenarios, and introduces an 8-layer Typological Risk Traceability Model. The model provides a structured way to link source publications to detection logic, improving governance, defensibility, and explainability. Practical examples and architectural guidance help Reporting Entities align monitoring systems with assessed risk.
Navigating the Nexus of Financial Crime Prevention and Financial Inclusion in the Age of Technology
This ADBI policy brief explores the growing tension between financial crime compliance and financial inclusion in Asia and the Pacific. With rising costs of compliance and increasing digital scams, the paper highlights how stringent anti-money laundering regulations can inadvertently exclude vulnerable populations. It advocates for clearer guidance from the Financial Action Task Force and promotes the use of FinTech, RegTech, and SupTech to balance risk management with inclusive access to financial services.
Submission to the Public Consultation on AML/CFT and Financial Inclusion
Updated FATF Guidance on AML/CFT Measures and Financial Inclusion
On 4 April 2025, the Academy of Excellence in Financial Crime Investigation and Compliance prepared a submission to the Financial Action Task Force (FATF) in response to their Updated FATF Guidance on AML/CFT Measures and Financial Inclusion.
The submission was co-authored by Academy Director, Professor Andreas Chai and Research Fellow from Griffith University's Griffith Asia Institute, Dr Shawn Hunter.
Senate Inquiry into the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024
On 19 September 2024, the Senate referred the provisions of the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 to the Legal and Constitutional Affairs Legislation Committee for inquiry and report by 13 November 2024. This Bill aims to reform Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime, which establishes the regulatory framework for combatting money laundering, terrorism financing, and other serious financial crimes. Notably, the Bill proposes to extend the AML/CTF regime to include real estate professionals, lawyers, accountants, and dealers in precious stones and metals.
The Academy of Excellence in Financial Crime Investigation and Compliance prepared and submitted a detailed submission for this inquiry on 14 October 2024. Additionally, the Legal and Constitutional Affairs Legislation Committee invited the Academy to attend the public hearing for the Inquiry into the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024. Representing the Academy at the hearing were Director, Professor Andreas Chai; Deputy Director, Professor Shireenjit Johl; and Senior Industry Fellow, Dr Gordon Hook.
The Academy’s submission, updated on 2 September 2025, addresses the re-referral of the inquiry to the Parliamentary Joint Committee on Law Enforcement, focusing on law enforcement capability to respond to money laundering and financial crime. Key recommendations include:
- Establishing a National Financial Crime Technology Hub.
- Expediting the implementation of tranche two AML/CTF obligations.
- Enhancing AI adoption and workforce development in law enforcement.
- Promoting public-private partnerships and research into financial crime as a national priority.
White Paper Series: No. 01.2024 - De-Banking in the Asia-Pacific Region
The Academy of Excellence in Financial Crime Investigation and Compliance, explore how policymakers, banks and other financial institutions in the Asia-Pacific region can manage the trade-off between financial inclusion and compliance with regulations on anti-money laundering/combating the financing of terrorism.
This White Paper was produced in conjunction with the International Law Institute and the Commonwealth Bank of Australia.
Capability of Law Enforcement to Respond to Money Laundering and Financial Crime
On 19 June 2024, the Joint Committee on Law Enforcement initiated an inquiry into the capability of law enforcement to respond to money laundering and financial crime. The committee welcomed submissions to this inquiry, with The Academy of Excellence in Financial Crime Investigation and Compliance preparing a submission for the committee which was submitted in July 2024.
The submission was co-authored by the following researched and practitioners:
- Dr. Gordon Hook, former APG Executive Secretary and Industry Fellow at the Academy of Excellence in Financial Crime Investigation and Compliance, Griffith Business School, Griffith University.
- Craig Robertson, Financial Crime Subject Matter Expert (Asia Pacific), Symphony AI and Industry Fellow at the Academy of Excellence in Financial Crime Investigation and Compliance, Griffith Business School, Griffith University.
- Professor Andreas Chai, Director of the Academy of Excellence in Financial Crime Investigation and Compliance, Griffith Business School, Griffith University.
- Professor Louis de Koker, La Trobe Law School, La Trobe University.
More information about the inquiry can be found here.
Senate Standing Committees on Environment and Communications – Inquiry into greenwashing
In March 2023, the Senate referred an inquiry into greenwashing with the following terms of references:
- the environmental and sustainability claims made by companies in industries including energy, vehicles, household products and appliances, food and drink packaging, cosmetics, clothing and footwear;
- the impact of misleading environmental and sustainability claims on consumers;
- domestic and international examples of regulating companies' environmental and sustainability claims;
- advertising standards in relation to environmental and sustainability claims;
- legislative options to protect consumers from green washing in Australia; and
- any other related matters
Dr L. Fernando Distadio of the Academy of Excellence in Financial Crime Investigation and Compliance prepared a submission in response to this inquiry which was submitted in December 2024.
More information about the inquiry can be found here.
Modernising Australia's anti-money laundering and counter-terrorism financing regime
In April 2023, The Attorney-General's Department (AGD), released the first of two consultation papers on Modernising Australia’s anti-money laundering and counter-terrorism financing regime. Following this announcement, The Academy of Excellence in Financial Crime Investigation and Compliance prepared a submission in response to this paper.
The objective of the proposal is to simplify and modernise AML & CTF Regulation, noting the current challenges. Overall the Academy strongly supported the proposal released by the AGD and submitted their detailed response on Friday, 16 June 2023.
Productivity Commission's Philanthropy Inquiry Submission
Griffith Business School, in conjunction with the Academy of Excellence in Financial Crime Investigation and Compliance prepared a submission to the Productivity Commission's Philanthropy Inquiry on 5 May 2023.
The aim of the inquiry is to boost donations to charities and meet the Australian Government's goal of doubling philanthropic giving by 2030. A draft report will be released by the Commission towards the end of November 2023.