www.austrac.gov.au/sites/default/files/20170803-concise-statement-cba-s.pdf
They did eventually get this info to Austrac in Sep 2015, which is a mitigating factor, but all the same, this bit looks very bad considering this channel was being used from June 2012.
Extract via my OCR
10. CommBank failed to give 53,506 TTRs to AUSTRAC on time for cash transactions of $10,000 or more that were processed through lDMs from 5 November 2012 to 1 September 2015 (the Late TTRs). The Late TTRs represent about 95% of threshold transactions that occurred through IDMs in that period and have a total value of $624.7 million. 1,640 of the Late TTRs (totalling about $17.3 million) related to transactions connected with money laundering syndicates being investigated and prosecuted by the Australian Federal Police (AFP) or accounts connected with those investigations. A further 6 of the Late TTRs related to 5 customers who had been assessed by CommBank as posing a potential risk of terrorism or terrorism financing. Two of the Late TTRs were lodged with AUSTRAC on 24 August 2015 and the remaining 53,504 were lodged with AUSTRAC on 24 September 2015.
Failure to file SMRs and to carry out ongoing due diligence
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