NAB has confirmed it has entered into an enforceable undertaking (EU) with financial crimes regulator AUSTRAC.
It comes after AUSTRAC launched a formal investigation into the major bank’s compliance with AML/CTF laws in June last year, flagging “potential serious and ongoing non-compliance” with customer identification procedures and ongoing customer due diligence.
On Monday, 2 May, NAB CEO Ross McEwan said the bank takes the AML/CTF obligations seriously and will continue to work closely with AUSTRAC.
“We recognise it has taken us longer to fix the concerns raised than it should have. We welcome AUSTRAC’s acknowledgement that NAB has undertaken significant work to date – and we accept that there is more to do,” Mr McEwan said.
“It is essential that everyone in our bank is focused on getting the basics right, every time, and keeping our customers and bank safe. Keeping criminals out of the financial system is a top priority for NAB. We recognise our opportunity to better detect, deter and disrupt the flow of illegal money at a time when the threat is evolving at an incredible rate.
“We have a plan to make our bank simpler for customers to use, while safeguarding against the criminal threat. The EU provides a clear timeline as we further build capability, increase resourcing, continue to modernise our systems and improve controls and governance.”
Under the terms of the EU, NAB and relevant members are required to complete a remedial action plan, to be approved by AUSTRAC, by 31 December 2024 and appoint an external auditor who will provide a final report by 31 March 2025.
The delivery of the RAP will be overseen by NAB’s dedicated financial crime executive committee.
“National Australia Bank has demonstrated a commitment to uplifting its AML/CTF controls, and has undertaken significant work identifying and implementing improvements to its programs,” AUSTRAC CEO Nicole Rose said in a separate statement.
“NAB has worked collaboratively with AUSTRAC throughout the investigation, and this enforceable undertaking will help to ensure NAB meets its compliance and reporting obligations.”




Banker commit fraud – no problem, just pay the fine, anyone else – do not pass go, straight to jail
Imagine if an adviser hadn’t signed a AML form. Maybe a 5 year ban…..
Gosh! – anyway – rollout the platitudes re “taking our …….obligations seriously etc etc” and move on.
No individuals penalised, executives retain their bonuses and the game continues.
What this means for anyone licensed under a NAB subsidiary is the following. It’s determined in 2022, and set to be finalized in 2025. So if it’s like ASIC’s look back program, I’ll get a letter in 2032 (seven years after the event) asking for evidence of AML/CTF for the period 2002 till 2022 (some TEN years ago). That’s exactly what I experienced with ASIC fee for no service program.
Yawn!
Anyone lost their job over this? Of course not, only financial planners are named, shamed, banned and jailed for breaches. Banks and union funds can have serious and ongoing non-compliance and the regulators handle them with kid gloves. What a punishment, having to write a remedial plan in two years time? What a joke.
Heads should roll at board level. The NAB directors have all been in their roles for at least 2 years, so they have had plenty of time to deal with this.