ASIC Commences Proceedings Against ISX and JK, page-585

The exchanges or actions between and by Visa and ISX are themselves selective in regard to what is made public when.

Visa is known to have had an agreement with ISX.
Visa is known to have changed the rules.
(a) Visa is known to have shared information with ASX and or ASIC directly or indirectly.
(b) Visa is known to have THEN (after the rule change) said ISX don't meet the NEW rules.
Not sure if (b) actually occurred before (a), because the public information is not conclusive (IMO, happy for clarification)
Visa apparently required ISX to perform some of the direct oversight of AML typically applied by Regulators. (According to ISX)
ISX is known to have then made attempts to satisfy Visa on some basis, but we don't know whether at Tier 1 or Tier 2.
Visa then told ISX to take a hike.
ISX then said they weren't/had not been, prepared to perform what was asked of them in regard to AML.

What matters is
1. Visa is being challenged in regarded to its conduct.
2. ISX is still dealing with Mastercard and others without the Visa imposed requirement on AML.
3. ASIC have tripped up ASX' defence on some matters in SOC regarding disclosure, and on a fair reading it comes down to "misleading" with regard to the disclosure content AND WHEN.
4. ASIC have to get over the disclosure by ISX that the purpose of the integration was not only to get paid for the integration but to have a framework for bringing on others more expeditiously. I expect ISX lawyers will present that as a fair reading of disclosures made.
5. ISX lawyers will be citing cases of matters considered not relevant for disclosure, or where there are those of similar import where no action was taken by ASX or ASIC.
I am pretty comfortable with ISX position. JK probably needs some counseling on when to say what, and how to say it.
JK you only have to win, just.