Australia – AUSTRAC Charge CBA re AML

On 3 August, AUSTRAC charged Commonwealth Bank with AML.

  • Initiated proceedings in federal court, on Commonwealth Bank of Australia (CBA).
  • For non-compliance with AML/CTF Act, using intelligent deposit machines (IDMs).

Cash Deposits via Machine

  • IDMs are ATMs that accept deposits by cash and cheque, to account of recipients.
  • Funds are then available for transfer to other accounts, domestically or overseas.
  • IDMs can accept up to 200 notes per deposit, up to $20,000 per cash transaction.
  • CBA does not limit the number of IDM transactions a customer can make in a day.
  • Allow anonymous cash deposit, if card entered in machine was not issued by CBA.
  • Cardholder details unknown to CBA, banks did not need to give depositor details.
  • Growth in CBA IOMs since roll out, from $89mn in cash in 2012 to $5.8bn in 2016.

Failure to Monitor for AML

  • Alleged 53,700 contraventions, where CBA did not comply with AML/CTF program.
  • Did not conduct assessment of AML/CTF) risk of IDMs, before their rollout in 2012.
  • Took no steps to assess ML/TF risks until mid-2015, three years after introduction.
  • In period, CBA did not comply with AML/CTF program, for monitoring transactions.
  • Did not supply 53,506 threshold transaction reports (TTRs), to AUSTRAC, on time,
    for cash trades of $10,000 or more through IDMs, total value is around $624.7mn.
  • Bank did not report suspicious matters involving transactions totalling over $77mn.
  • Even after CBA aware of suspected money laundering or structuring with accounts.
  • Did not monitor customers to mitigate and manage AML risks, doing business with.


  • Austrac sought declaratory relief, order for civil money penalties; payment of costs.