TECH
)
RMIT white paper identifies gap In Australia’s anti-scam architecture
Scam losses in Australia remain above $2 billion annually, and despite a range of government-led measures introduced in recent years, scams continue to take a toll on individuals across the country, particularly those in vulnerable communities.
A new white paper from RMIT University argues that a gap persists in the national anti-scam framework – one that sits at the very moment a victim is about to hand over funds, but before those funds have been irreversibly transferred.
A window between prevention and response...The paper, Completing Australia’s anti-scam architecture, was authored by RMIT’s Associate Deputy Vice-Chancellor of Strategy, International and Engagement in the College of Business and Law, Professor Mathews Nkhoma, in partnership with community finance organisation, Good Shepherd.
It contends that while Australia’s scam defences have improved, the current architecture is weighted toward two ends of the scam lifecycle: preventing initial contact with potential victims and responding after losses have already occurred. Between those two stages, the paper argues, lies a less formally recognised window where targeted intervention could stop funds from leaving a victim’s hands.
Professor Nkhoma describes this window as the “pre-transaction stage” – the period when a person, under pressure or deception, is seeking access to funds but has not yet sent them.
“The national anti-scam system is currently at its strongest either before contact is made or after loss has occurred,” he explained. “Between these points lies a stage that is less formally recognised – the pre-transaction stage – when a victim of fraud and under pressure or deception, seeks access to funds.”
“This is the point at which behavioural intervention can prevent a scam from progressing and funds have not yet been irreversibly transferred.”
A missing layer in the framework...The white paper’s central argument is that despite its importance, this pre-transaction stage has not been formally recognised as a distinct intervention layer within the national anti-scam architecture.
That means the current system lacks a structured mechanism for intervening at the point where deception meets financial decision-making – a moment the paper frames as one where behavioural intervention could still change the outcome.
“Despite its significance, the pre-transaction stage is not formally recognised as a distinct intervention layer within the national anti-scam architecture,” Professor Nkhoma noted.
The implication, as the paper lays it out, is that victims who have been psychologically manipulated but have not yet completed a transfer are passing through a stage where no formal intervention pathway exists to reach them.
Using existing infrastructure...Rather than calling for a new institution to fill this gap, the white paper proposes that a pre-transaction intervention strategy could be delivered through services that already exist within the community finance sector.
“A proposed pre-transaction stage strategy would operate through existing service infrastructure rather than requiring a new institution, with the purpose of interrupting scam-related harm at the moment when deception intersects with financial decision-making,” Professor Nkhoma outlined.
Community finance services, the paper argues, already sit at the point where individuals make financial decisions and could serve as a practical layer for this type of intervention. These services interact with people at moments of financial need or vulnerability, positioning them to identify warning signs that a transaction may be scam-related.
“Community finance services operate precisely at this point of decision,” he added. “A staged pilot would test and refine this intervention layer, assessing its effectiveness, safeguards and integration within the broader anti-scam framework.”
A staged pilot approach...The white paper recommends a staged pilot program to test the proposed intervention model before any broader rollout. The pilot would focus on evaluating the effectiveness of pre-transaction intervention, determining what safeguards are needed and assessing how the approach could be integrated within Australia’s existing anti-scam framework.
The intent, the paper argues, is not to replace any part of the current system but to complete it – adding a formally recognised layer at the stage where losses can still be prevented.
Professor Nkhoma has held his current role at RMIT since 2021, overseeing strategy, international and engagement initiatives within the College of Business and Law.
The gap in Australia’s anti-scam architecture...Australia's national response to scams has strengthened in recent years through government-led anti-scam measures. Yet losses remain above $2 billion, and scams continue to have a significant and devastating impact on individuals, particularly those in vulnerable communities. In a new white paper, RMIT professor Mathews Nkhoma has identified the critical gap in anti-scam architecture before funds have been irreversibly transferred.
Professor Mathews Nkhoma, Associate Deputy Vice Chancellor Strategy International & Engagement, College of Business and Law:
"The national anti-scam system is currently at its strongest either before contact is made or after loss has occurred. Between these points lies a stage that is less formally recognised - the pre-transaction stage - when a victim of fraud and under pressure or deception, seeks access to funds.
"This is the point at which behavioural intervention can prevent a scam from progressing and funds have not yet been irreversibly transferred.
"Despite its significance, the pre-transaction stage is not formally recognised as a distinct intervention layer within the national anti-scam architecture.
"A proposed pre-transaction stage strategy would operate through existing service infrastructure rather than requiring a new institution, with the purpose of interrupting scam-related harm at the moment when deception intersects with financial decision-making.
"Community finance services operate precisely at this point of decision. A staged pilot would test and refine this intervention layer, assessing its effectiveness, safeguards and integration within the broader anti-scam framework."
Professor Mathews Nkhoma has authored a white paper Completing Australia’s anti-scam architecture in partnership with Good Shepherd.




