AUSTRAC has finalised the Enforceable Undertaking (EU) with National Australia Bank (NAB) after the bank satisfied its obligations under the agreement.
The EU, accepted in April 2022, was entered into by NAB and 4 other NAB related companies to address shortcomings in compliance with Australia's anti-money laundering and counter-terrorism financing (AML/CTF) laws.
The EU specifically aimed to address concerns regarding NAB's customer identification procedures, ongoing customer due diligence and the adoption and maintenance of a compliant AML/CTF program.
AUSTRAC CEO Brendan Thomas said NAB has demonstrated 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 EU, highlighting the bank's commitment to transparency, accountability and commitment to sustainable remediation.
The external auditor also made recommendations outside the EU scope to further enhance the bank's AML/CTF program, including around transaction monitoring and assurance frameworks. NAB has accepted all 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.
