Regulatory reform is coming thick and fast – is it time to rethink, reset and transform your approach to financial crime?

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  • Insight
  • 7 minute read
  • August 19, 2025

By Penny Dunn and Simon Taylor

Financial crime is changing – and it’s changing fast. Criminals are using artificial intelligence, cryptocurrencies and complex trade networks to exploit vulnerabilities in financial systems. Scams alone in Australia cost consumers over $2 billion annually.1

Regulators are responding with increased scrutiny and reform. AUSTRAC reforms (expected March 2026) will aim to strengthen anti-money laundering and counter-terrorism financing through modernising the existing framework and expanding its reach. The newly enacted Scam Prevention Framework Bill (Feb 2025) introduces new obligations for banks, telecommunications providers and digital platforms to actively detect, disrupt and prevent scams via a whole of ecosystem approach. ASIC and APRA are also sharpening their focus on financial crime as part of broader governance and resilience mandates.

These developments signal a clear shift: financial crime is no longer just a compliance issue – it’s a strategic risk that touches every part of the organisation. In this article, we’ll explore why now is the time to rethink your financial crime prevention strategy beyond compliance and build a system that is unified and intelligence-led. By creating an Operating Model, which ties together data, technology, processes and culture, it will help make things easier, less complex and more impactful.

Why now?

Increasingly, financial crime risk has become a core business issue. Why? Because it intersects with:

  • Customer trust: A single breach or scam can erode years of brand equity and negatively disrupt customer growth outcomes.
  • Operational resilience: Financial crime can disrupt systems, processes and supply chains.
  • ESG and reputation: Organisations are increasingly held accountable for ethical conduct and transparency.
  • Digital transformation: As services become more digitised, new vulnerabilities emerge and the experience of customers must be balanced with customer protection measures.

Yet many organisations still treat financial crime as a siloed function – managed by compliance teams, reviewed periodically and disconnected from broader strategic priorities. And, with those major regulatory reforms coming into effect over the next 12 to 18 months, this approach is no longer viable. These reforms, from different regulators, will overlap in some areas creating new complexities for your organisation. What has worked for the past 15 years will not meet the demands of the next decade. Now is the time to rethink, reset, and transform your approach to financial crime.

Common stumbling blocks

In our work with financial institutions, we see common stumbling blocks. Might any of these sound familiar?

Fragmented compliance: AML/CTF, fraud and scam sanctions, cyber, insider threat and tax evasion are often handled by different teams, with little communication between them. This creates inefficiencies, gaps in coverage, and a lack of coordination across risk management functions.

Reactive and static risk management: Organisations often wait for red flags before assessing risk, relying on fixed, periodic assessments. This reactive, static approach means risks are evaluated only when issues arise, preventing a dynamic, real-time understanding of evolving threats and leaving organisations playing catch-up. 

Underutilisation of technology: Some organisations don’t fully leverage advanced technologies like AI and machine learning, sticking to manual processes or outdated systems. This limits detection capabilities and scalability.

Lack of holistic data use: Data exists in a fragmented state across multiple systems. This leads to challenges in obtaining a comprehensive view of risk profiles or detecting interconnected threats and emerging vulnerabilities.

Mismatch in training and culture: There can be insufficient emphasis on training for compliance teams, leading to gaps in knowledge, skills and adaptability. A culture that doesn’t prioritise continuous improvement and innovation can also stifle progress.

An organisation-wide approach will bring significant and extended gains into the future.

Compliance is commonly reactive – why not shift to proactive and transformative? This means taking a whole-of-ecosystem perspective, creating an integrated, intelligent and future-ready operating model. 

It’s a unified system where data, technology and people collaborate seamlessly across all financial crime risk areas. No more silos.
 

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Here’s why it matters:

  • Collaboration: By aligning teams across departments in an integrated system connects all aspects of financial crime risk (AML, fraud, sanctions and scams etc) into a single, unified view, allowing you to better understand the interconnected nature of risks and identify emerging threats early. It streamlines efforts, ensures faster responses and eliminates gaps.

  • Smarter decisions using high-quality data and advanced analytics: Centralising data means you always have a real-time, accurate view of risk at your fingertips – and across the customer journey. 

  • Efficiency and reduced compliance costs: It minimises manual tasks and enables more automated, intelligent decision-making. Think automated routine tasks like reporting and investigations.

  • Continuous risk monitoring: With integrated systems like dCRA (dynamic Customer Risk Assessment) you can shift from periodic risk assessments to continuous, dynamic monitoring of customer risk profiles, enabling real-time adjustments.

  • Drives culture change: With the right training, you can support your people to not just follow procedures but to think differently – to challenge assumptions, connect dots across data sources and respond with speed. Crucially, fostering innovative ‘risk-based’ thinking shifts the dial from a prescriptive, checklist-driven approach to one where risks are assessed dynamically and strategically.

  • Stay ahead of threats and regulations: artificial intelligence (AI), advanced analytics and real-time data platforms help with horizon-scanning and can identify trends and predict emerging risks, allowing you to adapt quickly. It also means you can pre-emptively respond removing the need to do a wholesale change every time new reforms emerge. 

It’s also important to note that modern financial crime doesn’t respect industry boundaries. Criminals exploit vulnerabilities across banking, fintech, telecommunications, retail, real estate and even professional services. Cross-industry and sector collaboration is key to enabling a more complete view of the threat landscape and closing the gaps that criminals exploit across the ecosystem. No single organisation can tackle this alone.2

“Financial crime is rarely isolated. A single scheme can span multiple domains –fraudulent onboarding (KYC failure), suspicious transactions (AML trigger), phishing or malware (cyber breach), and identity theft (fraud risk). When these functions operate in silos, each team sees only a fragment of the threat, missing the full picture.”

Penny Dunn,Risk and Advisory, Partner, PwC Australia

Ready to lead the change?

Financial crime is evolving faster than ever, waiting to react can put your organisation at risk. With multiple regulatory changes on the horizon, now is the time to rethink, reset and transform your compliance strategy. By embracing an integrated, future-ready approach – you’ll not only meet today’s challenges but be ready for what’s next. 

This transformation doesn’t just benefit your organisation. It strengthens the entire ecosystem, improving outcomes for your customers by protecting their assets and enhancing trust. And as financial crime risks are better managed, wider society benefits from a more secure, transparent financial system.

Recommendations:

The following four actions can help reframe your financial crime approach: 

  • Elevate financial crime risk to a strategic priority.
  • Invest in intelligence-led capabilities and integrated platforms.
  • Foster a culture of vigilance, accountability and collaboration.
  • Engage with regulators and peers to shape the future of compliance.

1 NASC Targeting Scams Report, March 2025: https://www.scamwatch.gov.au/system/files/targeting-scams-report-2024.pdf

2 Celent, BMO: Using Big Data to Transform the AML/ KYC Function, April 2020 https://www.celent.com/en/insights/134174954

Contact us

Penny Dunn
Penny Dunn

Partner, Assurance, Forensics and Financial Crime, PwC Australia

Simon Taylor
Simon Taylor

Partner, Assurance, Forensics and Financial Crime, PwC Australia

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