Criminals use financial institutions to conceal their illegitimate funds with the aim of making ‘dirty money’ clean, this is known as money laundering. Terrorism financing is the financial support of terrorism or of those who encourage, plan, or engage in terrorist activities. Money laundering and terrorism financing (ML/TF) risk refers to the likelihood and impact of the Commonwealth Bank Group (the Group) being involved with or facilitating this unlawful activity.
The Group is committed to:
Meeting its international regulatory obligations in the identification, treatment and management of ML/TF risk;
Protecting the Group from reputational risk and breaches of regulatory requirements that may lead to severe fines and penalties; and
Safeguarding the Group, its customers and employees from becoming a victim of, or unintentional accomplice to, ML/TF activities.
The Group is intent on satisfying its local regulatory and international obligations in a sustainable manner.
The AML/CTF Group Policy determines the principles that all CBA Group entities must adhere to in their identification, treatment and management of money laundering and terrorism financing risk. The Group must comply with the AML/CTF laws in a number of different countries in which it operates due to the geographic reach of its activities and operations. All Group entities are required to comply with the policy principles irrespective of their geographic location. Where the laws of a particular jurisdiction are of a higher standard, then the higher standard must be applied.
Our policy provides key principles that all the Group’s entities must adhere to in their identification, treatment and management of money laundering and terrorism financing risk.
1. The Group operates an AML/CTF Program that:
Meets the requirements of the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (and associated laws)
Is supported by policies and procedures to combat money laundering and terrorism financing
Is monitored and tested to ensure policies and procedures remain effective and are adhered to
2. The Group identifies and reports suspicious behaviours by:
Ensuring authorities receive the necessary information to further investigate any illegal activities
Educating our employees so they can identify, monitor and report suspicious matters
Ensuring our employees are aware that suspicious matters are not limited to financial transactions
Submitting, when appropriate, suspicious matter reports to AUSTRAC (the Australian Transactions Reports and Analysis Centre).
3. The Group endeavours to protect itself from being used for illicit activities by:
Conducting customer identification and verification processes to ensure our customers and their beneficial owners are who they say they are
Only dealing with legitimate customers and to protect against our products and services being utilised by money launderers, terrorist financers or anybody that chooses to support these types of individuals
Carrying out ongoing customer due diligence.
4. The Group manages Employee Due Diligence by screening all prospective and existing employees, including contractors and temporary employees.
5. The Group retains all relevant records for seven years (or any other time period as required by law).
6. The Group’s AML/CTF training program is designed to ensure employees receive relevant and ongoing training. The program will provide an awareness of money laundering and terrorist financing, indicate how to identify and report a suspicious matter and inform our employees of our regulatory obligations under the AML/CTF Act.
The Commonwealth Bank Group identifies its customers and their beneficial owners according to the requirements of the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 and the AML/CTF Rules or local legislation as required.
The checklists below will help our customers in gathering the right information for identification requirements.