AUSTRAC has closed its Enforceable Undertaking with National Australia Bank after the lender fulfilled the remediation required under the agreement, but the financial intelligence agency cautioned the bank that extensive compliance work remains.
The undertaking, accepted in April 2022, was agreed by NAB and four related entities to address shortcomings in compliance with Australia’s anti-money laundering and counter-terrorism financing laws. It focused on customer identification procedures, ongoing customer due diligence and the adoption and maintenance of a compliant AML/CTF program.
AUSTRAC chief executive Brendan Thomas said the bank had shown a commitment to ongoing compliance and to tackling the risks and harms posed by serious and organised crime. “The closure of this EU reflects the progress NAB has made but it still doesn’t give the business a clean bill of health,” Mr Thomas said.
“The EU set NAB on the right path, but compliance is not a one off task – it requires ongoing, incremental change. AUSTRAC expects NAB to continue to improve its systems and processes.”
An independent external auditor found NAB had satisfied the terms of the undertaking, and noted the bank’s transparency, accountability and commitment to sustainable remediation. The auditor also made recommendations beyond the EU’s scope to further strengthen the lender’s AML/CTF program, including enhancements to transaction monitoring and assurance frameworks. NAB has accepted all of those recommendations.
“We welcome NAB’s decision to take on this additional remediation work. It builds on the changes made under the EU and strengthens the bank’s overall AML/CTF program.
“However, finalising an EU is not the end of the assurance and integration work required by NAB. Elements of AML programs are interconnected, so deficiencies in one element can affect the effectiveness of another.
”Now that NAB has uplifted its AML/CTF program and procedures related to customer identification and due diligence, we’d like the business to consider what these changes may mean for the strength of other elements of its program, such as transaction monitoring,” he said.
