Leading through change: Success strategies and the future of financial crime

Part 3 of 3: Australia regulatory reform webinar insights series (see Part 1 and Part 2)

With Australia’s landmark AML/CTF reforms taking effect in just months, financial crime leaders face a defining moment. The regulatory landscape is shifting beneath their feet. Technology is evolving faster than many organisations can absorb. Customer expectations are rising. And the threat landscape grows more sophisticated daily.  

In this environment, what separates organisations that will thrive from those that will merely survive? Our webinar with industry leaders from Deloitte, AMP, and SymphonyAI concluded with insights on the leadership mindset, strategic choices, and collaborative approaches that will define success through 2026 and beyond.  

Keep your eye on the ball: advice for leaders

When asked for the single most important piece of advice for leaders navigating AML reform and scam regulation over the next 18 months, Lisa Dobbin, Partner and Australia and APAC Financial Crime Lead at Deloitte, was direct: “Keep your eye on the ball.”  

But what does that mean in practice? Dobbin elaborated: “Above all else, you’ve got to continue to manage your risk. That’s the prime thing to do. But within all of that, make space for the potential innovation in the future, even if you can’t get to it now.”  

Dobbin highlighted AUSTRAC’s openness to engagement as a critical resource leaders should leverage: “Just be really open to engaging with AUSTRAC on how you’re thinking about navigating these challenges you’re having. They’re the first to admit they don’t have all the answers, and they’re very willing and keen and open learners of what everyone’s dealing with and how they’re grappling with both the challenges and the opportunities in this space.”  

This represents a significant shift in regulatory approach. AUSTRAC CEO, Brendan Thomas, has been explicit about moving from regulation that primarily checks for compliance to regulation focused on substantive risks and harms. Rather than mandating specific solutions, AUSTRAC is inviting industry collaboration on addressing shared challenges.  

For leaders, this creates both opportunity and responsibility. The opportunity: influence how outcomes-based regulation is interpreted and applied in practice. The responsibility: demonstrate genuine commitment to managing money laundering and terrorism financing (ML/TF) risk, not just meeting minimum requirements.  

Be clear about what you’re trying to achieve

Craig Robertson, Financial Crime and Compliance SME – APAC at SymphonyAI, offered complementary advice focused on strategic clarity: “Be very clear about what are you trying to achieve. Are you trying to reduce harm? Be more efficient? Are you trying to make sure you can manage change?”  

Robertson’s point is that organisations should “be very choosy about what it is that you’re going to do in this next period,” while recognising that “those three things need to feature in an extended timeframe beyond 2026.”  

This means making hard choices:  

• If reducing harms is the priority, focus on improving detection capability and threat intelligence, even if it means accepting some operational inefficiency in the short term.  
• If efficiency is the goal, prioritise automation of high-volume, low-complexity processes to free capacity for strategic work, even if sophisticated detection enhancements wait.  
• If managing change is paramount, invest in change management, training, and organisational readiness, even if technical implementations are more modest initially.  

The key is ensuring leadership alignment on priorities, communicating those priorities clearly across the organisation, and measuring progress against stated goals rather than trying to be all things at once.  

A vision of success: what does the future of financial crime look like?

When asked what success looks like for Australia’s financial crime community, the panellists offered distinct but complementary visions.  

Collaboration and intelligence sharing

Michelle Reinisch, Director of Small Business/Personal Banking – Customer Success and Enterprise Customer Protection at AMP, painted an ambitious picture: “For me, I’d like to see a sector that’s really collaborative, data smart, customer-led. I’d also love sort of real-time intelligence sharing. I think success is really about having a total mindset shift across everybody that contributes to this regime.”  

This vision moves beyond individual institutional success to industry-wide transformation. Reinisch described a future where organisations aren’t just managing their own risks in isolation but “threat hunting together.”  

“If we’re still talking about an uplift instead of sort of that outcome risk space which was touched on throughout this whole conversation, I feel like we might have missed the mark,” she explained. The goal is moving from compliance-focused conversations to outcome-focused collaboration.  

This aligns with emerging initiatives around public-private partnerships and information sharing. The Fintel Alliance in Australia already brings together law enforcement, regulators, and industry to share intelligence and coordinate responses to financial crime threats. Success means expanding and deepening these collaborations.  

Real-time intelligence sharing faces hurdles – privacy considerations, competitive concerns, technical integration challenges – but the regulatory environment is evolving to enable it. The scam prevention framework, for instance, includes provisions for information sharing across banks, telcos, and digital platforms to identify and disrupt scams faster.  

Prevention as a defining characteristic

Robertson’s one-word answer to what defines next-generation financial crime capability was simple: “Prevent.”  

He elaborated: “A lot more financial crime controls can live what I’d call upstream of where they might live today. I think that is an important way to think about embedding in product design and those types of aspects, how you achieve a more end-to-end kind of effective use of both technology as well as controls.”  

This shift from detection and response to prevention represents a fundamental evolution in how financial crime is managed. Currently, most controls operate downstream—screening customers after they’ve been onboarded, monitoring transactions after they’ve occurred, investigating suspicious activity after it’s been flagged.  

A prevention mindset asks different questions:  

• How do we design products and services that are harder to misuse?  

• How do we identify and stop bad actors before they become customers?  

• How do we use intelligence about emerging threats to adapt controls proactively?  

• How do we partner across the ecosystem to block criminals from exploiting the financial system?  

Robertson referenced Australia’s E-Safety Commissioner and the concept of “safety by design” as an instructive parallel. Rather than trying to police harmful content after it’s published, platforms are increasingly expected to design systems that prevent harm from occurring in the first place.  

For financial crime, prevention might mean:  

• Using identity verification technology that stops synthetic identities and fraudulent applications upfront  

• Blocking mule account creation through biometric checks and device intelligence  

This doesn’t eliminate the need for detection and response, but it shifts the centre of gravity in financial crime programs.  

Effective, risk-based, and outcomes-focused

Dobbin’s vision of success centred on effectiveness: “Success is organisations that have moved from ‘do we have a program?’ to ‘does our program work?’ That means being able to demonstrate that controls prevent or detect issues, that risk-based approaches direct resources to where they matter most, and that the organisation can show outcomes not just processes.”   

This directly mirrors the language in FinCEN’s 2024 proposed rule for AML program effectiveness in the United States and AUSTRAC’s messaging around outcomes-based regulation in Australia. The question is no longer whether you have customer due diligence procedures, but whether those procedures result in you actually knowing your customers and understanding their risk.  

Five key metrics for success

1. Meaningful metrics: Tracking not just volumes (reports filed, alerts generated, customers screened) but outcomes (threats prevented, criminals identified, funds recovered, harm reduced).  
2. Evidence of impact: Demonstrating through case studies, statistical analysis, and regulator feedback that programs are making a difference.  
3. Continuous improvement: Using metrics, feedback, and lessons learned to refine approaches over time rather than treating compliance as static.  
4. Risk alignment: Showing that resources, controls, and attention align with assessed risks rather than being spread uniformly.  
5. Mindset shift: From compliance to outcomes  

Risk management with customer protection

A common thread running through all three panellists’ perspectives is the need for a fundamental mindset shift, from viewing financial crime as a compliance exercise to understanding it as risk management with customer protection at its core.  

Reinisch captured this: “For me, financial crime isn’t just a compliance issue in my world, it’s a customer promise. And for us, it’s not just about we get it right so that we don’t lose money. We get it right because we don’t want to lose customers and confidence.”  

Leaders who successfully drive this mindset shift position their organisations not just to meet 2026 requirements but to excel in an evolving landscape where customer trust and effective risk management differentiate winners from the rest.  

As organisations move from strategy to execution on AI and risk-based approaches, several principles are emerging:  

• Start with the foundation: Prioritise data infrastructure, governance frameworks, and risk assessment methodologies before deploying advanced AI.  
• Prove value incrementally: Begin with high-impact, lower-complexity use cases that deliver quick wins and build organisational confidence.  
• Invest in people: Technology succeeds or fails based on the people using it. Training, change management, and capability building are as important as the technology itself.  
• Engage early with AUSTRAC: The regulator has signalled openness to innovation and learning. Organisations pioneering new approaches should engage proactively.  
• Measure what matters: Track outcomes—detection rates, investigation efficiency, customer impact—not just outputs like number of alerts or reports filed.  
• Build for evolution: Threats change, regulations evolve, and technology advances. Build systems designed to adapt rather than requiring replacement.  

The role of industry collaboration

One of the most striking themes from the webinar was the emphasis on collaboration as essential to success. Dobbin’s vision of “lifting all the boats” and Reinisch’s call for “threat hunting together” reflect growing recognition that financial crime can’t be solved by individual institutions alone.  

This collaborative imperative manifests in several ways:  

Information sharing: Sharing intelligence about scams, fraud typologies, money laundering methods, and emerging threats enables faster, more effective responses across the sector.  

Industry Standards: Developing common approaches to challenges such as payee confirmation, biometric verification, and dynamic risk assessment reduces duplication and improves interoperability.  

Public-private partnership: Working with AUSTRAC, law enforcement, and other government agencies to ensure intelligence flows in both directions and efforts are coordinated.  

Cross-sector coordination: Collaborating with telecommunications providers, digital platforms, and other sectors under the scam prevention framework to address threats holistically.  

Success by 2026 won’t be individual banks declaring victory, but the Australian financial crime ecosystem demonstrating collective capability to prevent, detect, and disrupt threats more effectively than it does today.  

Final reflections: The gateway to next-generation financial crime

The webinar title – “Australia’s Regulatory Reforms: Gateway to the Next Generation of Financial Crime” – proved prophetic. What emerged clearly is that these reforms represent far more than a compliance hurdle to overcome.  

For organisations that approach them thoughtfully, the reforms are indeed a gateway:  

• To modernised technology stacks that enable rather than constrain financial crime prevention  
• To risk-based approaches that direct resources where they matter most  
• To outcomes-focused programs that demonstrably prevent harm  
• To collaborative ecosystems that make financial systems harder for criminals to exploit  
• To competitive advantages grounded in customer trust and operational excellence  

But gateways must be walked through. The opportunity exists, but realising it requires leadership, the kind that keeps eyes on ongoing risk management while making space for innovation, that sets clear priorities while building for the long term, that pursues transformation while meeting immediate obligations.  

As Australia’s financial crime community navigates the turbulent waters ahead, the organisations that will define what success looks like by 2026 and beyond are those taking action now, not to simply comply, but to transform.  

The question for every leader is no longer whether change is coming, but what they will make of the opportunity it presents.  

Related resources

Australia’s Regulatory Reforms: Gateway to the Next Generation of Financial Crime

From Compliance to Transformation: How Australia’s AML Reforms Are Reshaping Financial Crime Strategy (Part 1)

Operationalising AI and Building Risk-Based Approaches for Next-Generation Financial Crime Prevention (Part 2)