It should be remembered that IT people, generally, are just...

It should be remembered that IT people, generally, are just that. There are not Banking people. They rely on Banking people telling them what is required and they do the best they can to meet the Banking needs. At best, the IT outcome can only be as good as the Banking people's knowledge.

The attachments spell out the 3 tier approach to managing risk. In my interpretation (I have experience in 2nd and 3rd tier credit risk overview), nothing happened in the 2nd and 3rd tier overviews until 2017 and even then, it just bubbled along without end to end resolution and the Board's risk committee did not prioritise resolution.

Well before I retired in 2008 (not from WBC), APRA had questionaires put to the Bank's Board annually on a full range of compliance issues that required Board members to drill down into end to end processes to be able to answer them. The real thing is what did WBC tell APRA about compliance with AML/CTF compliance up to 2017?

My view is that a cultural deficiency existed in WBC in respect to AML/CTF compliance from the Board down to the Banking people until 2017. The price of that culture will be borne by us shareholders and most of the people causing it, in all likelihood, left the Bank in the past. Financial censure of people, from 2017, who seem to have been willing to tell the Board it wasn't right, seems a bit of scapegoating.