CBA is committed to meeting its regulatory obligations in identifying, mitigating and managing money laundering and terrorist financing risk. It seeks to protect its customers, employees and the community from ML/TF activities and recognises that it plays a critical role in this regard.
CBA continues to invest significantly in its AML/CTF compliance programme. Recent projects have included upgrading and enhancing its AML/CTF technology, updating its AML/CTF policies and process documentation, investing in further resourcing and strengthening the training of its personnel.
The CBA Group AML/CTF Policy sets out the AML/CTF principles which apply to all entities of CBA and its subsidiaries. The policy contains principles in relation to:
The identification, mitigation and management of ML/TF risk
Training and Awareness
Customer Due Diligence including On-going Customer Due Diligence
Employee due diligence
Outsourcing and agents
The Customers and transactions that are outside the Group’s ML/TF risk tolerance
All CBA Group entities are required to comply with the Group AML/CTF Policy irrespective of their geographic location. Where the laws of a particular overseas jurisdiction are of a higher standard than that prescribed in the Australian Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), then the higher standard is to be applied.
The principles contained within CBA’s Group AML/CTF Policy are to be read in conjunction with CBA’s Joint AML/CTF Program.
CBA’s Joint Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Program (the Program) has been prepared for the purposes of complying with obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the Act) and the Anti-Money Laundering and Counter-Terrorism Financing Rules.
The Program is comprised of two Parts: Part A and Part B. The primary purpose of Part A is to identify, mitigate and manage the risk of being involved in or facilitating (whether inadvertently or otherwise) money laundering or the financing of terrorism. Part B documents the Program requirements in relation to Customer Due Diligence information and verification for AML/CTF purposes.
CBA’s Joint AML/CTF Program will apply to overseas subsidiaries in so far as the Act applies. Other policies and procedures may be put in place to assist an overseas subsidiary to comply with local AML/CTF laws.
The Program is supported by CBA’s Group AML/CTF Policy and AML/CTF Group Standards.