Ann: ASX Query Letters re ISX suspension & termination by Visa, page-219

There are more questions that we don't yet have answers for; it's not that simple.

If Visa suddenly found ISX had issues because of the ASX investigations, what was Visa doing all along? Isn't there a regular audit process?

The way Visa has qualified the issues is alarming: they are so bad that it requires a significant change in corporate structure and a rework of the entire AML risk framework. I find this very hard to believe as ISX is the subject of regular audits (including PCI DSS) and is a member of several card schemes. Is ISX not regularly audited, or are the audits inadequate, or what is going on exactly? Visa is entitled to its own opinions, decisions and enforcement but I think there's a lot more to this saga than meets the eye.

It appears ISX did not disclose the full details to the market as it obviously didn't agree with Visa's assessment. Let's note Visa itself isn't a regulator on AML; it may have an opinion but only a regulator e.g. AUSTRAC can make a formal assessment.

I guess we all have to wait and see what AUSTRAC (or its equivalent in Europe) comes up with.

I have no faith in ASIC since it's been mute for 12 months and heads are starting to roll at the top due to corruption. Most of the cases ASIC has raised against small businesses have been selective and mostly lost in court. ASIC is due for a complete cleanup from the top.

AUSTRAC has a different track record taking on the big banks (with all their financial resources) and winning.